CommunicationsTwilio and the GDPR: agreement, role and data location.
Twilio is a communications tool. Most customers use it as a processor, it publishes its data processing agreement, and the data location depends on your account. Below: what to check and how to declare it.
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In short
- Category
- Communications
- Usual role
- Usually a processor
- Data location
- Set per account or project
- Agreement
- Published by the vendor
What does Twilio do with personal data?
Send text messages, verification codes and notifications through Twilio’s communication services. That is how Privacyboard describes a typical use of Twilio, as a starting point you can edit.
The data usually involved: phone numbers, message content, call metadata and delivery status.
Is Twilio a processor or a controller?
Most customers use Twilio as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for communications tools and it is what Privacyboard suggests.
As a processor, it needs a written agreement with you under Article 28, and you should know which subprocessors it uses. Confirm the role against your own agreement, because the way you use a tool can change it.
Where does Twilio store personal data?
Twilio does not have one fixed location for every customer. US by default, with Ireland and Australia available for some products.
How to find yours: Account → Region settings shows the processing region for the products that offer one.
Even when the main location is in the EU, ask whether subprocessors or support access involve a transfer outside the EEA, and record it if so.
Does Twilio have a data processing agreement?
Checked on 1 November 2026. Vendors change their pages, so check the date.
Yes. Twilio publishes the text of its data processing agreement on its own website. Article 28 of the GDPR requires a written contract with every processor, so this is the document to read and keep.
What we noted when we opened the page: Called Data Protection Addendum. Updated Apr 2026. About the last fifth of the text, with the final schedules, was not read. Also covers SendGrid.
A page that exists does not mean you are covered. Whether the agreement applies to you depends on your plan and on what you accepted, so record the decision yourself in your vendor list.
Read the Twilio agreementHow to declare Twilio
- 1
In your privacy policy
Name Twilio as a recipient, say what it is used for (send text messages, verification codes and notifications through Twilio’s communication services) and mention any transfer outside the EEA. Articles 13 and 14 ask you to tell people who receives their data.
- 2
In your vendor list
Add Twilio with its purpose, the data involved, its role, its region and a link to the agreement. Privacyboard prefills all of this, you confirm or correct it.
- 3
In your processing register
Link Twilio to the activities that use it, so each record shows its recipients. Article 30 asks the register to list the categories of recipients.
What to check before relying on Twilio
- Confirm the region and any transfer outside the EEA.
- Keep the agreement text you accepted and its date.
- List the provider in your privacy policy and your processing register.
Questions, answered.
Is Twilio GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Twilio is configured and used, on the agreement you have with it and on your own practices. What can be checked is documented here: it publishes a data processing agreement, the usual role and the data location. Read the agreement itself before relying on it.
Does Twilio have a DPA?
Yes. Twilio publishes the text of its data processing agreement on its own website. Article 28 of the GDPR requires a written contract with every processor, so this is the document to read and keep. You can read it at https://www.twilio.com/en-us/legal/data-protection-addendum.
Is Twilio a data processor?
Usually, yes. Most customers use Twilio as a processor that acts on their instructions. Check your own agreement and how you use the tool, because the role can differ.
Where does Twilio store data?
Twilio does not have one fixed location for every customer. US by default, with Ireland and Australia available for some products. How to find yours: Account → Region settings shows the processing region for the products that offer one.
Do I need to mention Twilio in my privacy policy?
Yes, if Twilio handles personal data for you. The GDPR asks you to tell people who receives their data (Articles 13 and 14). Name the vendor or its category, say what it is used for and mention any transfer outside the EEA.
How do I add Twilio to my vendor list?
In Privacyboard, pick Twilio from the catalog. The purpose, the data, the suggested role and a link to its agreement are prefilled, and you confirm each one. Creating a workspace is free.
Privacyboard is not affiliated with Twilio. Names and logos belong to their owners and are used only to identify the tool. This page summarises public documents as checked on 1 November 2026; it is guidance, not legal advice, and it does not certify any vendor.