Description of Processing Activities for WhatsApp under SMS Agreement and Annex I to the SCCs

Data Exporter: WhatsApp Ireland Limited, an Ireland based provider of messaging, calling and related services.

Data Importer: WhatsApp LLC, a U.S. based provider of messaging, calling and related services.

Sub-processor: The relevant Provider, as identified in the SMS Agreement.

Data subjects: The Personal Data transferred relates to European region users of the WhatsApp service.

Categories of data: The mobile phone numbers of European region users of the WhatsApp service and verification codes sent to such users.

The frequency of the transfer: Ad-hoc transfers. Such transfers will only take place when an SMS message is needed to be sent to a WhatsApp user.

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 SMS Agreement. Namely:

• transfer of data via the Short Message Peer-to-Peer (SMPP) 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 is to enable the sending of SMS messages to WhatsApp users and specifically the following:

• Communicating with users via mobile network services, including:
  • carrying out two factor authentication;
  • 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 SMS Agreement, whichever is the earlier.