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This provision identifies Meta Platforms, Inc. as a feature-specific Sub-Processor engaged to support the connection of WhatsApp Business accounts to the HubSpot conversations inbox, with all data centers listed as US-based.
This analysis describes what HubSpot's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision discloses that Customer Data associated with WhatsApp Business communications routed through HubSpot's conversations inbox may be accessible to Meta Platforms, Inc. as a Sub-Processor, with no EU or regional data center alternative listed. This is operationally significant for customers who process communications from EU or other non-US users through the WhatsApp Business integration.
Interpretive note: The specific scope of Customer Data accessible to Meta Platforms as a Sub-Processor versus data Meta independently processes as a platform provider is not defined in this document.
Under this provision, Customer Data processed through the WhatsApp Business integration in HubSpot's conversations inbox is handled by Meta Platforms, Inc. using US-based infrastructure. EU and other non-US customers using this integration should evaluate applicable cross-border transfer mechanisms for personal data shared with Meta's US infrastructure.
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"Meta Platforms, Inc. Conversation Functionality Support the connection of your WhatsApp Business account to the conversations inbox United States United States United States United StatesExcerpt from HubSpot's Sub-Processors
(1) REGULATORY LANDSCAPE: This provision engages GDPR Article 28 for EU customers, as Meta Platforms, Inc. is a US-based entity subject to US surveillance and data access laws. EU transfers to Meta's US infrastructure require Standard Contractual Clauses or equivalent mechanisms. The Irish Data Protection Commission has previously engaged with Meta's data transfer practices, and customers should be aware of the regulatory history around EU-US data transfers involving Meta. The ePrivacy Directive may also apply to communications data processed through WhatsApp Business integrations. (2) GOVERNANCE EXPOSURE: Medium. Meta Platforms is a US entity with a history of EU regulatory scrutiny over cross-border data transfers. Customers routing EU resident communications through the WhatsApp Business integration in HubSpot should confirm that adequate transfer mechanisms are in place and assess whether the nature of communications data processed triggers additional obligations (such as ePrivacy Directive compliance or special category data considerations). (3) JURISDICTION FLAGS: EU and EEA customers face the highest exposure for WhatsApp Business data flows to Meta's US infrastructure. UK customers are subject to equivalent UK GDPR transfer requirements. Customers in regulated sectors processing sensitive communications through WhatsApp Business integrations should conduct heightened due diligence. (4) CONTRACT AND VENDOR IMPLICATIONS: Procurement teams should confirm the data processing terms between HubSpot and Meta Platforms applicable to this Sub-Processor relationship, and assess how Meta's own platform terms interact with HubSpot's DPA obligations. The scope of data accessible to Meta as a Sub-Processor versus Meta's independent data processing as a platform provider should be clarified. (5) COMPLIANCE CONSIDERATIONS: Customers using the WhatsApp Business integration should update their records of processing activities to reflect Meta Platforms as a Sub-Processor and confirm applicable transfer mechanisms. Customers should assess whether their end users have been informed that their WhatsApp Business communications may be processed by Meta Platforms through the HubSpot integration.
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This provision discloses that Customer Data associated with WhatsApp Business communications routed through HubSpot's conversations inbox may be accessible to Meta Platforms, Inc. as a Sub-Processor, with no EU or regional data center alternative listed. This is operationally significant for customers who process communications from EU or other non-US users through the WhatsApp Business integration.
Under this provision, Customer Data processed through the WhatsApp Business integration in HubSpot's conversations inbox is handled by Meta Platforms, Inc. using US-based infrastructure. EU and other non-US customers using this integration should evaluate applicable cross-border transfer mechanisms for personal data shared with Meta's US infrastructure.
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