Twilio uses certain sub-processors to assist in providing Twilio’s services. A sub-processor is a third party company engaged by Twilio to process personal data (i) on behalf of Twilio customers; (ii) in accordance with customer instructions as communicated by Twilio; and (iii) in strict accordance with the terms of a written contract between Twilio and the sub-processor.
Twilio imposes obligations on its sub-processors to implement appropriate technical and organizational measures ensuring that the sub-processing of personal data is protected to the standards required by applicable data protection laws. Further information relating to sub-processor security measures can be found via the external links below.
Where the engagement of a sub-processor requires the cross-border transfer of personal data, Twilio has performed Transfer Impact Assessments for such data transfer.
Twilio maintains an up-to-date list of the names and locations of all sub-processors below. Twilio customers may subscribe to notifications of sub-processor changes to receive updates.
Duration of processing: For each sub-processor below, processing of personal data will be for the duration that the customer uses and continues to use the applicable Twilio service(s), and for the retention periods as set out in customer’s agreement with Twilio.
Sub-Processor List
| Sub‐processor | Applicable Twilio Service(s) | Subject matter | Nature and purpose of processing | Location | External links for additional information relating to security |
|---|---|---|---|---|---|
AWS | Infrastructure Provider — all Twilio and SendGrid services | Personal data contained in communications sent through Twilio’s services. | Infrastructure Provider providing hosting services and storage. | USA | Compliance Program; GDPR Centre; Supplementary Measures Addendum; Blog |
AWS | Programmable Voice | Personal data contained in voice communications. | Text to speech functionality for customers using Amazon Polly. | USA | Compliance Program; GDPR Centre; Supplementary Measures Addendum; Blog |
AWS | Twilio Live | Personal data contained in streamed videos. | Streaming and interactive video. | USA | Compliance Program; GDPR Centre; Supplementary Measures Addendum; Blog |
AWS | SendGrid | Personal data contained in emails. | Routing and transmission of emails. | USA | Compliance Program; GDPR Centre; Supplementary Measures Addendum; Blog |
| Appen Butler Hill | Programmable Voice; Twilio Flex | Personal data contained in voice communications. | Human annotation of voice recordings for customers who have enabled the feature on supported products. | USA, Australia, and the Philippines | |
| DVLEP/Sabio | Twilio Flex | Personal data contained in voice communications. | Connectivity services to customer’s Google CCAI instance. | USA, EU, UK | |
| GoodData Corporation | Twilio Flex | Personal data contained in communications sent through Twilio Flex. | Data analytics functionality for customers who have enabled the feature in Twilio Flex. | USA | Data Privacy; Data Security & Cloud Security |
Programmable Voice; Twilio Flex | Personal data contained in voice communications. | Speech recognition functionality for customers who have enabled the feature on supported products. | USA | Trust & Security; Data Privacy; Blog | |
| iMerit | Programmable Voice; Twilio Flex | Personal data contained in voice communications. | Human annotation of text files and human transcription of audio files for customers who have enabled the feature on supported products. | USA, India, & Bhutan | Data Security; Data Privacy |
| Snowflake | SendGrid | Personal data contained in emails. | Automation and storage services for marketing campaigns. | USA | Security Addendum; DPIA Fact Sheet |
| TranscribeMe | Programmable Voice; Twilio Flex | Personal data contained in voice communications. | Human annotation of voice recordings for customers who have enabled the feature on supported products. | USA & the Philippines | |
| VoiceBase | Programmable Voice; Twilio Flex | Personal data contained in voice communications. | Transcription services for customers who have enabled transcriptions on supported products. | USA |