Do I need to disclose Twilio in my privacy policy?

Yes. Twilio processes personal data on your behalf, making it a third-party data processor. You must disclose Twilio in your privacy policy, explain why you use it (SMS authentication, call recording, etc.), and inform users that their phone numbers and communication data are transferred to Twilio's servers in the United States. This disclosure is required under GDPR, CCPA, and other privacy regulations.

What specific data does Twilio collect?

Twilio collects phone numbers, SMS message content, voice call metadata (timestamps, duration, participants), voice call recordings if enabled, video session data, and user identity information. The exact data depends on which Twilio services you use. If you use Twilio for SMS authentication, phone numbers are collected. If you enable call recording, audio files are transmitted to and stored by Twilio.

Does Twilio use cookies that require consent?

No cookies have been documented for Twilio's core communication services. However, you should verify the current Twilio privacy policy at https://www.twilio.com/legal/privacy, as cookie practices may change. If Twilio uses analytics or tracking cookies in the future, you would need to update your cookie consent banner.

Who processes data with Twilio and where is it stored?

Twilio Inc., headquartered in the United States, processes data as your third-party data processor. Data is transferred to and stored on Twilio's servers in the US. Twilio holds SOC 2 Type II certification and is HIPAA-eligible, but you must ensure data transfer mechanisms (such as Standard Contractual Clauses) comply with GDPR requirements for international transfers.

Social & Communication

Privacy policy clauses for Twilio

Twilio is a cloud communications platform that enables websites and applications to send and receive SMS messages, make voice calls, conduct video sessions, and deliver messaging services. Websites use Twilio to authenticate users, send notifications, enable customer support, and facilitate real-time communications.

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What data Twilio collects

Your privacy policy must disclose each of the following data types when you use Twilio.

Phone numbers and call metadata

SMS message content

Voice call recordings (if enabled)

Video session data

User identity information

When does Twilio trigger privacy obligations?

Installation triggers immediate data collection

The moment you integrate Twilio into your app or website, you begin collecting and transmitting phone numbers, SMS content, voice metadata, and potentially call recordings to Twilio's US servers. This is not conditional—Twilio processes this data the instant a user initiates communication.

Which regulations apply

GDPR (if any EU users): Phone numbers and call metadata are personal data under GDPR Article 4(1). You must establish a lawful basis (Article 6) *before* collecting—typically consent under Article 7 or legitimate interest. SMS content may qualify as special category data if it contains health or other sensitive information (Article 9). You must provide a privacy notice under Article 13/14 *at the point of collection*.

Common compliance pitfalls

Pitfall 1: Treating SMS as low-risk, ignoring TCPA

Many indie founders view SMS as a simple notification channel and deploy Twilio without implementing TCPA compliance. The mistake: TCPA requires *express written consent* on file before sending any marketing or promotional SMS to cell phones. "Consent" buried in a terms-of-service checkbox does not satisfy TCPA. Twilio will route your messages, but you remain liable for violations. Regulators and plaintiff attorneys scrutinize SMS sender behavior closely. Consequence: each non-compliant SMS is a $500–$1,500 statutory damages liability. A 1,000-message campaign without proper consent = $500K–$1.5M exposure, regardless of intent. TCPA applies to US numbers even if your company is offshore.

Pitfall 2: Missing a Data Processing Agreement (DPA)

Under GDPR Article 28(3), every processor (including Twilio) must be bound by a written DPA. Many founders rely on Twilio's standard privacy policy and assume it covers this. It doesn't. Twilio provides a DPA template on request, but many operators never ask or never execute it. Consequence: technically non-compliant with GDPR *before* any data breach occurs. Regulators (especially UK ICO, Ireland DPC) flag missing or incomplete DPAs as a primary audit finding. Fines are separate from any breach fine—auditors view this as gross negligence in processor governance.

Pitfall 3: Recording calls without state-specific consent

Twilio's voice API makes call recording a few lines of code. Founders often assume US-wide one-party consent applies. It doesn't. California, Florida, Pennsylvania, Illinois, and others require *all parties'* written consent. Recording without it is a criminal offense in many states and triggers civil lawsuits. Consequence: liability for recorded calls with users in two-party states is immediate and severe—statutory damages, attorney fees, and potential criminal charges. Privacy policies that say "calls may be recorded" do not satisfy the written consent requirement.

Privacy policy clauses for Twilio

What data Twilio collects

When does Twilio trigger privacy obligations?

Installation triggers immediate data collection

Which regulations apply

First concrete step

Where data goes

Common compliance pitfalls

Pitfall 1: Treating SMS as low-risk, ignoring TCPA

Pitfall 2: Missing a Data Processing Agreement (DPA)

Pitfall 3: Recording calls without state-specific consent

Legal note

Sample privacy policy clause

What regulators look for

Primary audit focus: consent and transparency

Frequently asked questions

Do I need to disclose Twilio in my privacy policy?

What specific data does Twilio collect?

Does Twilio use cookies that require consent?

Who processes data with Twilio and where is it stored?

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