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Black Snow Report

Twilio

Method v1.6As At 2026-08-1131 Surfaces Read1 Offering Assessed

Your own published record, as at 2026-08-11.

Your Details

The Macro Picture17

Red · Adverse
2
of 17 banded observations across 1 offering band Adverse. 1 was never measured.

2 conditional rows (Hosting Locality = Customer Content in Ireland or Australia; all other account and usage data in the United States · Deployment Mode = SendGrid Services and Private Beta Offerings -- same platform, same instruments, except that the BCR route is expressly unavailable) sit outside these counts. A Variant is a stated deployment mode, not a published offering, and the Grid Standard holds it to its own band.

What Is Published8

Your Own Words3

These transfer mechanisms will apply in following order of precedence, as set forth in this Schedule 3: (a) the Data Privacy Framework; (b) Twilio BCRs; (c) the EU Standard Contractual Clauses; (d) the UK International Data Transfer Agreement; (e) the Brazil Standard Contractual Clauses; (f) the Twilio Global CBPR or Global PRP Certifications
Schedule 3 s2.1 · Source
Prior to the termination of the Agreement, (a) Twilio will process stored Customer Content for the purposes set forth in Section 4.2 (Customer Instructions) until Customer elects to delete such Customer Content via the Services and (b) Customer agrees that it is solely responsible for deleting Customer Content via the Services.
Schedule 1 s6.1 · Source
Twilio uses the third party companies below (each, a 'sub-processor') 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.
https://www.twilio.com/en-us/legal/sub-processors · Source

Parties You Name33

See which of these are assessed in this register

Register Check3

AI Role By Offering1

Assessment Basis

Produced under Method v1.6 from the entity's fact record. 8 of 8 observations were measured under that generation; the rest read Not Measured, which is a fact about this register's coverage and not a finding about the entity.

Read from 31 first-party surface(s) across 1 assessed offering(s), found by the entity's own link graph and sitemap rather than by guessed paths.

Fact Record
Version 1.0, dated 2026-08-11
Standards Commit
66058de9d9a2
Register Control Quality
Both Views

Verification And Challenge

Every finding on this record is a statement about what could be read on your own published surfaces as at 2026-08-11. Correspondence route as recorded on this card input: ror@blacksnowintel.com.

What A Machine Could Not Establish1

1 question is open and 7 are established, read as at 2026-08-11 under method v1.6.

The One Thing To Publish First

Publish it: publish a retention period.

Amber · PartialData Retention

Disclosed, but incompletely.

Where To Put It

This was read on your own page at https://www.twilio.com/en-us/legal/privacy. That is the page a reader already reaches for and does not find it on, so it is the page to correct first.

Where Others Stand

21 organisations in the register publish a retention period. You publish on it, but not completely.

What A Published Answer Looks Like

Messages: 1 Year live, 7 years archive. Contacts, Distribution Lists, Events, Assets: Ongoing live, 7 years archive. Activity Stream, Activity Logs, Database: 1 year live, 7 years archive. Detailed Message Logs, Message Logs, Web Logs, Application Logs, Database Logs: 7 years archive.

A question answered plainly in public, by an organisation read as Strong on it. It is not an endorsement of the position the sentence states — Black Snow reads what is published and never recommends what to practise. Read on published terms. Claim tier Quoted. The organisation that published it is not named.

One is named here, and one is deliberate. The rest of the open questions are listed below without a prescription; what to publish for each, in what order, and drafted machine-readable evidence for all of them, is the Deep Dive.

Still Open

Deep Dive

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