Depending on the circumstances, WhatsApp can be both a Data Controller or a Data Processor.
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.
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.

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