Based on the purpose we process the personal data for, we process data in different roles.
As a data controller
When MessageBird determines the means and purposes of the processing of personal data, the company acts as a data controller. In this capacity, MessageBird is responsible for:
- processing personal data from electronic communications sent or received by a customer through MessageBird’s platform or via its APIs;
- processing personal data for necessary business operations, such as verifying your account usage, billing, and other administrative and technical purposes;
- detecting, preventing, and investigating the misuse of its services;
- carrying out marketing and sales campaigns.
As a data processor
When MessageBird handles personal data for the provision of its services to a customer, with the exclusion of transportation services provided to wholesale routing partners, MessageBird acts as a data processor. In its capacity as a processor MessageBird handles, stores and transfers personal data on the specific instructions of that controller or another processor acting on behalf of the controller. The entity from whom we receive the data is a MessageBird customer. As a data processor, MessageBird does not own or control the data that it processes. In this role, MessageBird has been instructed by a customer to perform the services as provided and laid down in the General Terms and Conditions or Service Agreements.
MessageBird may also be a data processor and a data controller for certain sets of personal data received from a third party at the same time. MessageBird would become a data controller should the personal data be used for a purpose other than that for which it was originally provided.
MessageBird as a wholesale routing partner
The nature of our business requires MessageBird to rely on different telecom carriers for the provision of the services. When a carrier is merely providing routing services to another carrier (i.e. providing the pipeline to transport the electronic communication) and does not further process personal data in any way, the carrier may be regarded as not being classified as a (sub)processor under the EU's data protection regulation. For other processing activities, the carrier will be deemed a controller of that specific activity. As a wholesale routing partner, MessageBird acts as an independent data controller in so far as it processes metadata for technical or billing purposes.