Description of Processing Activities

Part 1: WhatsApp EU Data (or Meta EU Data)

Data Exporter: WhatsApp Ireland Limited, a provider of social network products and services to users based in Europe.

Data Importer: WhatsApp LLC, a provider of advertising, marketing, technical and other support services to the data exporter.

Sub-Processor: Provider (or Operator) as identified in the Agreements.

Data subjects: The Personal Data transferred concern individuals who visit, access, use or otherwise interact with products and services of the data exporter.

Categories of data: The WhatsApp User Data as defined in the Agreement, to the extent it constitutes Personal Data which is in the controllership of WhatsApp Ireland Limited and specifically, the relevant phone number which can lead to the identification of an individual, the verification codes to be sent to such users.

The frequency of the transfer:
Continuous, as may be required from time to time to provide the services or carry out the other activities as set out in more detail in the Agreements.

Nature of the processing: The nature of the processing is the performance of such operations as may be necessary in order to carry out the services described under the Agreements. Namely:

• transfer of data via the Short Message Peer-to-Peer (SMPP) protocol or similar protocol; and
• converting the message into an SMS form for onward transmission.

Purpose(s) of the data transfer and further processing: The purpose of the processing, depending on the products and services visited, accessed, or used by the data subject, and subject to any relevant permissions, controls and other internal instructions, is the provision of services and other activities as set out in more detail in the Agreements, including:

• Communicating with users via mobile network services, including:

  - carrying out two factor authentication; and

  - sending messages to confirm phone number ownership during registration to WhatsApp

• Providing technical engineering support and trouble-shooting.

The period for which the personal data will be retained: Until the completion of the processing activities or the termination of the Agreements, whichever is the earlier.

Last updated: January 2025

Part 2: WhatsApp UK Data (or Meta UK Data)

Data Exporter: WhatsApp LLC, a US based provider of social network products and services.

Data Importer: Provider (or Operator) as identified in the Agreements.

Data subjects: The Personal Data transferred concern individuals who visit, access, use or otherwise interact with products and services of the data exporter.

Sub-Processor: Cloud services providers hereby considered as pre-approved.

Categories of data: The WhatsApp User Data as defined in the Agreements, to the extent it constitutes Personal Data which is in the controllership of WhatsApp LLC and specifically, the relevant phone number which can lead to the identification of an individual, and the verification codes to be sent to such users.

The frequency of the transfer: Continuous, as may be required from time to time to provide the services or carry out the other activities as set out in more detail in the Agreements.

Nature of the processing: The nature of the processing is the performance of such operations as may be necessary in order to carry out the services described under the Agreements. Namely:

• transfer of data via the Short Message Peer-to-Peer (SMPP) protocol or similar protocol; and
• converting the message into an SMS form for onward transmission.

Purpose(s) of the data transfer and further processing: The purpose of the processing, depending on the products and services visited, accessed, or used by the data subject, and subject to any relevant permissions, controls and other internal instructions, is the provision of services and other activities as set out in more detail in the Agreements, including:

• Communicating with users via mobile network services, including:

- carrying out two factor authentication; and

- sending messages to confirm phone number ownership during registration to WhatsApp.

• Providing technical engineering support and trouble-shooting.

The period for which the personal data will be retained: Until the completion of the processing activities or the termination of the Agreements, whichever is the earlier.

Last updated: January 2025