Twilio
Communications API · twilio.com · last read 2026-11-09
At a glance
- Is Twilio GDPR compliant?
- No tool is GDPR compliant on its own: compliance depends on what you process with it and how. What follows is what Twilio itself publishes, each answer linked to its source and the date we read it.
- Does Twilio have a data processing agreement (DPA)?
- Yes. Twilio publishes a data processing agreement at twilio.com. It gives between 10 and 30 days' notice before a new subprocessor is added, depending on the case; the terms tab gives each. It promises breach notification "without undue delay", with no number of hours. Source and date
- Which version of the Twilio DPA is current?
- On 2026-11-09, Twilio's DPA at twilio.com printed “Last Updated: April 9, 2026”. Source and date
- Does Twilio have a SOC 2 report?
- Twilio states SOC 2 (no type given) on its own page, but does not say there how to get a report. We read this on 2026-10-05. Source and date
- Is Twilio ISO 27001 certified?
- Twilio states ISO/IEC 27001 on its own page, but does not say there how to get the certificate. We read this on 2026-10-05. Source and date
- Where is Twilio's trust center?
- Twilio publishes a page it calls “Trust Center” at security.twilio.com. Some of its documents sit behind a request or sign-in: the page says “Get access”. The page mentions SOC 2, ISO 27001, a penetration test, subprocessors and security questionnaires. We read it on 2026-11-03. Source and date
- How does Twilio transfer personal data out of the EU?
- Twilio's agreement relies on the EU standard contractual clauses, the EU-U.S. Data Privacy Framework, Binding Corporate Rules and the UK transfer addendum. Twilio Inc. is on the official Data Privacy Framework List (status: Active). Source and date
- Does Twilio offer EU data residency?
- The vendor documents an EU region but states nothing about which plan reaches it or what it costs. Source and date
- Who are Twilio's subprocessors?
- Twilio lists 38 third-party subprocessors; 35 of them name at least one processing country outside the EEA. We last read the list on 2026-10-05. Source and date
The same questions for any vendor, and the rule behind each: the vendor due diligence checklist.
Identity
| Legal entity | Twilio Inc. |
|---|---|
| HQ | US |
| Parent company | — |
| Ultimate ownership | — |
| EU contracting entity | Twilio Ireland Limited |
| LEI | 5493004W8TRGD63APX93 |
| US CLOUD Act reach | Contracting entity incorporated in the US |
| Source | twilio.com · 2026-10-08 |
Legal entity from the vendor's own terms. LEI, registered country and parent company from the Global LEI Index (GLEIF); ownership is left empty where GLEIF names no parent. The CLOUD Act row is arithmetic over those countries, not an assessment of risk.
Twilio data residency
| Region | EU data location | Minimum plan | Source | Observed |
|---|---|---|---|---|
| EU | Terms not stated | Regional Twilio, supported products only | twilio.com | 2026-09-18 |
EU: Ireland (IE1) is documented as a Twilio region. This does not displace the subprocessor page footnote recorded separately: Regional Twilio keeps Customer Content in the selected region, while account data continues to be processed in the United States.
The same question for every vendor: where SaaS vendors store EU data.
Twilio's subprocessor list names AWS and Google for hosting or infrastructure. Which SaaS vendors run on which cloud, and the sovereign offerings of each: sovereign clouds.
Subprocessor chain
38 third parties · 1 of the vendor's own group companies · 35 with a country outside the EEA · all read 2026-10-05
| Subprocessor | Country | If hosted in the EU | Purpose |
|---|---|---|---|
| Adaptive Mobile (ENEA) | US | — | Message safety, spam filtering, threat detection and abuse prevention (Programmable Messaging) |
| Amazon Bedrock | US | — | AI functionality including LLM models (All AI Products) |
| Anthropic | US | — | AI functionality including LLM models (All AI Products) |
| AWS | US | — | Automated text-to-speech conversion, speech recognition, and natural language text processing (Programmable Voice) |
| AWS | US | — | Automation and storage services for marketing campaigns (Marketing Campaigns (SendGrid)) |
| AWS | US, EU, AU | — | Core cloud hosting and data storage infrastructure (All Services & Products) |
| AWS | US, EU | — | Route and transmit emails (Email (SendGrid)) |
| AWS | US | — | Streaming and interactive video functionality (Programmable Video) |
| Clickhouse | US, EU | — | Hosting and data storage infrastructure (All Products) |
| DataBank | — | — | Hosting services and storage (Sendgrid Services) |
| Datadog | US | — | Monitoring of platform security and system health (Segment, Stytch by Twilio) |
| Deepgram | US | — | Transcribes voice media into text via automated speech recognition (Programmable Voice) |
| Digital Realty | EU | — | Hosting services and storage (Sendgrid Services) |
| DVELP/Sabio | GB, BE, FI, DE, NL, PL | — | Integration connectivity to customer Google CCAI instances (Twilio Flex) |
| Elastic | US | — | Support system indexing, search query optimisation, and operational log analytics (Stytch by Twilio) |
| ElevenLabs | US, EU | — | Automated speech summarisation, audio synthesis, and sentiment detection (Conversational Intelligence) |
| Fivetran | US | — | Automates data synchronisation between operational systems for internal business reporting (Stytch by Twilio) |
| GoodData Corporation | US | — | Data analytics, custom reporting dashboards, and business intelligence visualisation (Twilio Flex) |
| US, CH, GB | CH, GB | Database storage, compute resources, and query processing (Segment; Twilio Engage) | |
| US | — | Transcribes voice media into text via automated speech recognition (Programmable Voice; Twilio Flex) | |
| Google RCS | US, CL, IE, NL, DK, FI, BE, TW, JP, SG | — | Delivers inbound and outbound authentication messages (Verify) |
| Hex | US | — | Internal business intelligence, data visualization, and collaborative analytics (Stytch by Twilio) |
| Honeycomb | US | — | Real-time system observability, application debugging, and performance tracing (Stytch by Twilio) |
| Lakera | US | — | Security monitoring, data leakage prevention, and real-time threat detection within automated workflows (All AI Products) |
| Lumen | — | — | Hosting services and storage (Sendgrid Services) |
| Meta | US | — | Routes, transmits and delivers messages (Whatsapp Channel; Stytch by Twilio) |
| Microsoft Azure | US | — | AI functionality including Large Language Models (All AI Products) |
| Microsoft Azure | US, EU | — | Transcribes voice media into text via automated speech recognition (Conversational Intelligence) |
| Mintlify | US | — | Service documentation management (Stytch by Twilio) |
| OpenAI | US | — | AI functionality including Large Language Models (All AI Products) |
| Plain | GB | — | Manages multi-channel customer support communication and service ticket resolution (Stytch by Twilio) |
| Postmark | US | — | Routes, transmits, and delivers outbound email communications (Stytch by Twilio) |
| Sinch | US | — | Routes, transmits, and delivers outbound SMS communications (Stytch by Twilio) |
| Slack | US | — | Customer Support chat/messaging solutions (Stytch by Twilio) |
| Snowflake | US | — | Manages campaign data storage and executes email marketing automation (Marketing Campaigns (SendGrid)) |
| Svix | US | — | Delivers real-time system alerts and notifications (Stytch by Twilio) |
| Temporal Cloud | US | — | Schedules and executes the customer defined workflows (Flex) |
| VoiceBase | US | — | Transcribes voice media into text via automated speech recognition (Programmable Voice; Flex) |
Twilio's own group companies listed as subprocessors (1)
| Company | Country | Purpose |
|---|---|---|
| Twilio Inc. | US | Provision of the Twilio Services (All Services) |
The count outside the EEA is arithmetic over the country column, not a judgement about lawfulness. A transfer outside the EEA can be perfectly lawful; whether this one is depends on your use, not on the vendor.
Every subprocessor in the registry, and which vendors name it: subprocessors.
Processing terms
From the vendor's data processing agreement · read 2026-10-09 · twilio.com
| Term | What the agreement says |
|---|---|
| Transfer mechanism | Binding Corporate Rules |
| Transfer mechanism | EU-U.S. DPF |
| Transfer mechanism | SCC module 1 |
| Transfer mechanism | SCC module 2 |
| Transfer mechanism | SCC module 3 |
| Transfer mechanism | UK Addendum |
| Transfer mechanism | UK IDTA |
| Transfer mechanism | other |
| Notice of new subprocessors | Prior written notice of sub-processor changes (SCC Clause 9 Option 2); notice period as set forth in Section 6.2 of the DPA |
| Notice of new subprocessors | Written notice at least 10 days before a change in sub-processors that are not infrastructure providers |
| Notice of new subprocessors | Written notice at least 30 days before a change in infrastructure-provider sub-processors (list at twilio.com/legal/sub-processors with subscription mechanism) |
| If you object to one | Written objection on reasonable data-protection grounds within notice period; good-faith discussion of alternatives; if unresolved, customer may discontinue use of affected Services by written notice (fees already incurred still due); no objection = deemed authorization |
| Obligations passed to subprocessors | Contractual data protection obligations imposed on sub-processors, including appropriate technical and organizational measures, to the standard required by applicable data protection law |
| Breach notification | without undue delay after discovery, by email to designated addresses |
| Deletion when the service ends | On termination, stored Customer Content is deleted automatically 30 days after the termination effective date, and copies on back-up systems after 60 days; archived backups are isolated from further processing unless the law requires otherwise |
| Getting your data back | Customer has 30 days after the termination effective date to obtain a copy of stored Customer Content through the Services |
| Requests from data subjects | self-service features to delete, copy or restrict data at no additional cost; reasonable additional and timely assistance on Customer's written request where self-service cannot resolve the request |
| Audit | Customer audit only where Twilio's Audit Program (s.11.1) cannot satisfy legally required audit rights; mutually agreed audit plan: independent third-party auditor, reasonable prior written notice, access during business hours only, customer pays Twilio's then-current rates, no more than once per calendar year, confidentiality of findings |
| Audit | summary of most recent annual third-party audit report on written request; written responses to information requests no more than once per calendar year |
| Processing on your instructions | As processor, processes Customer Personal Data in accordance with Customer's instructions (per Section 4.2), terms Customer has accepted for certain Services, or Customer's use and configuration of Service features |
| Confidentiality of staff | Authorized persons have agreed to protect the data under Twilio's confidentiality obligations in the Agreement |
| Security measures | Technical and organizational security measures set forth in the Agreement, with additional information in Schedule 2 (Technical and Organizational Security Measures) |
Terms as the agreement states them. Where it is silent on a term, there is no row; that is not a statement that the vendor does not offer it.
Which version applies
On 2026-11-09, the agreement printed: Last Updated: April 9, 2026
at twilio.com
Last updated 2026-04-09
This version is in our copies from 2026-10-09.
These terms side by side for every vendor: data processing agreements compared. What vendors give you for a transfer impact assessment: transfer impact assessments.
Assurance
Does Twilio have a SOC 2 report?
Twilio states SOC 2 (no type given) on its own page, but does not say there how to get a report. We read this on 2026-10-05.
Of the 114 vendors in this registry whose own pages mention SOC 2, 57 say the report is available on request, 1 links to the report itself, and 56 state it without saying how to get it. The type is the one the vendor names.
Is Twilio ISO 27001 certified?
Twilio states ISO/IEC 27001 on its own page, but does not say there how to get the certificate. We read this on 2026-10-05.
On the same list Twilio also names ISO/IEC 27017 and ISO/IEC 27018. Each standard's page says how it relates to ISO/IEC 27001.
Of the 122 vendors in this registry whose own pages state ISO/IEC 27001, 16 link to the certificate, 43 say it is available on request, and 63 state it without saying how to get it. A certificate names the certification body, the scope and the expiry date: those are the three things to check.
| Scheme | Status | Scope | Source | Observed |
|---|---|---|---|---|
| CCPA | Claimed | — | security.twilio.com | 2026-10-05 |
| CPRA · CCPA | Claimed | — | security.twilio.com | 2026-10-05 |
| GDPR | Claimed | — | security.twilio.com | 2026-10-05 |
| HIPAA | Claimed | — | security.twilio.com | 2026-10-05 |
| ISO/IEC 27001 · ISO27001 | Claimed | — | security.twilio.com | 2026-10-05 |
| ISO/IEC 27017:2015 · ISO27017 | Claimed | — | security.twilio.com | 2026-10-05 |
| ISO/IEC 27018:2019 · ISO27018 | Claimed | — | security.twilio.com | 2026-10-05 |
| PCI DSS · PCIDSS | Claimed | — | security.twilio.com | 2026-10-05 |
| PCI DSS v4.0.0 · PCIDSS | Claimed | — | security.twilio.com | 2026-10-05 |
| SOC 2 · SOC2 | Claimed | — | security.twilio.com | 2026-10-05 |
Claimed means the vendor asserts the scheme on its own page and offers nothing further. Available on request means the report or certificate exists but sits behind a request, a login or an NDA. Neither is a certificate we have seen. That is a distinction an auditor makes, so we make it too.
SecNumCloud, C5, ENS and HDS for every vendor, with the pages for ISO standards, SOC 2 and TISAX: certifications compared.
Official registers
| Register | Offering, as the register names it | Status | Level | Valid until | Observed |
|---|---|---|---|---|---|
| Data Privacy Framework List (US) | EU-U.S. Data Privacy Framework · Twilio Inc. | Active | non-HR data | 2027-04-20 | 2026-10-05 |
| Data Privacy Framework List (US) | Swiss-U.S. Data Privacy Framework · Twilio Inc. | Active | non-HR data | 2027-04-20 | 2026-10-05 |
| Data Privacy Framework List (US) | UK Extension to the EU-U.S. DPF · Twilio Inc. | Active | non-HR data | 2027-04-20 | 2026-10-05 |
| Global LEI Index (GLEIF) | TWILIO INC. · TWILIO INC. | ISSUED | US-DE | 2027-03-08 | 2026-10-08 |
| Global LEI Index (GLEIF) | TWILIO IRELAND LIMITED · TWILIO IRELAND LIMITED | ISSUED | IE | 2027-03-11 | 2026-10-08 |
- ACN qualified cloud (Italy): checked 2026-11-09, no entry under Twilio; Twilio Inc.; Twilio Ireland Limited; Twilio Ireland Ltd
- ISO 27001 on the basis of IT-Grundschutz (BSI, Germany): checked 2026-11-09, no entry under Twilio; Twilio Inc.; Twilio Ireland Limited; Twilio Ireland Ltd
- CISPE Data Protection Code of Conduct (GDPR Art. 40): checked 2026-11-09, no entry under Twilio; Twilio Inc.; Twilio Ireland Limited; Twilio Ireland Ltd
- DORA critical ICT third-party providers (ESAs): checked 2026-11-09, no entry under Twilio; Twilio Inc.; Twilio Ireland Limited; Twilio Ireland Ltd
- Data Privacy Framework List (US): checked 2026-11-09, 3 entries under Twilio; Twilio Inc.; Twilio Ireland Limited; Twilio Ireland Ltd
- ENS certificates of conformity (CCN, Spain): checked 2026-11-09, no entry under Twilio; Twilio Inc.; Twilio Ireland Limited; Twilio Ireland Ltd
- EU Cloud Code of Conduct (GDPR Art. 40): checked 2026-11-09, no entry under Twilio; Twilio Inc.; Twilio Ireland Limited; Twilio Ireland Ltd
- FedRAMP Marketplace (US): checked 2026-11-09, no entry under Twilio; Twilio Inc.; Twilio Ireland Limited; Twilio Ireland Ltd
- GPAI Code of Practice signatories (European Commission): checked 2026-11-09, no entry under Twilio; Twilio Inc.; Twilio Ireland Limited; Twilio Ireland Ltd
- SecNumCloud qualified services (ANSSI, France): checked 2026-11-09, no entry under Twilio; Twilio Inc.; Twilio Ireland Limited; Twilio Ireland Ltd
What the authority publishes, not what the vendor claims. An entry covers the offering it names and nothing else: a FedRAMP authorisation for a government edition says nothing about the commercial service. No entry is not a finding about security - most vendors never apply - and an entry filed under a name not listed above would not have been found.
What an entry on the Data Privacy Framework List covers, and which vendors hold one: EU-US Data Privacy Framework.
Support window
| Product | Support period | State | SBOM | Source | Observed |
|---|---|---|---|---|---|
| Twilio API (SaaS) | — | Service only | unknown | twilio.com | 2026-09-18 |
Vulnerability reporting: the well-known path returns an HTML page, not a security.txt (read 2026-10-17)
How other vendors publish theirs: security.txt across the registry.
Documents
Where is Twilio's trust center?
Twilio publishes a page it calls “Trust Center” at security.twilio.com. Some of its documents sit behind a request or sign-in. The page mentions SOC 2, ISO 27001, a penetration test, subprocessors and security questionnaires. We read it on 2026-11-03. Open security.twilio.com
- Name “Welcome to Twilio's Trust Center, a reflection of our unwavering commitment to secure communications and the embodiment of the Twilio Magic. Our values”
- Request step “Get access”
Source: security.twilio.com, 2026-11-03. Read from the page's text, without a model; every vendor's trust center.
| Document | Disclosure | Transcription | HTTP | Observed |
|---|---|---|---|---|
| dpa | Public | full | 200 | 2026-10-09 |
| subprocessors | Public | full | 200 | 2026-09-18 |
| tia | Public | full | 200 | 2026-10-20 |
History
| Detected | What moved | Why | Source |
|---|---|---|---|
| 2026-09-18 | Note rewritten | we read a better page | twilio.com |
Every reviewed change across the registry, newest first: vendor changes.