Does WhatsApp see itself as a Data Controller, Data Processor or both?

Both - depending on the circumstances. Below, we've outlined details about WhatsApp's role in each of these designations.

  • Data controller: With respect to consumer end users of WA Messenger, WhatsApp acts as a data controller, as set forth in the privacy policy applicable to WA Messenger consumer end users.
  • Data processor: Each Client is a data Controller of its customer contacts. When the Client provides its customer contacts to WhatsApp via the WhatsApp Business Solution, WhatsApp is a data Processor of those customer contacts, and processes those customer contacts for the purpose of delivering the client's WhatsApp messages to those customers.

Our Data Processing Terms align with GDPR requirements governing contracts between data controllers and data processors.