Marketing

ManyChat

ManyChat is a chat marketing platform for automating conversations on Instagram, Facebook Messenger, WhatsApp and SMS. Businesses use it to answer questions, capture leads and run campaigns. On a website, its widgets and growth tools load scripts from ManyChat and may load Meta's SDK, which set cookies and share data with third parties, so prior consent is required.

Overview

What does ManyChat do?

ManyChat, founded in 2015 in San Francisco, is the leading conversational marketing platform with over a million businesses connected. Originally built on Facebook Messenger, it now spans Instagram DMs, WhatsApp Business, Telegram and SMS. It is widely used for lead capture, abandoned cart recovery, customer support automation and influencer campaigns.

What ManyChat does

ManyChat connects to Meta and Twilio APIs to send and receive messages on behalf of the customer. The visual flow builder lets non technical users design conversations, drip campaigns, AI replies and conditional logic. Growth Tools include opt in widgets, popups, landing pages, QR codes and Comment Reply triggers that turn an Instagram comment into a DM conversation.

Data and cookies collected

On the messaging side, ManyChat stores the subscriber Meta or phone identifier, the conversation history, custom fields, tags, and event logs. On the website side, embedded Growth Tools load JavaScript from manychat.com and may set cookies (mc_*, _ga forwarded). The Comment Reply automations forward Instagram comments to ManyChat servers in the US. The platform also captures the visitor IP and user agent.

GDPR and ePrivacy implications

Direct marketing via SMS or messaging apps requires prior explicit consent under Art. 13 ePrivacy and Art. 6(1)(a) GDPR. WhatsApp Business Messaging only allows automated marketing to users who explicitly opted in and is subject to Meta business rules. The embedded Growth Tools require ePrivacy consent for their cookies. ManyChat is a joint sub processor for the operator alongside Meta.

Data transfers and Meta

All ManyChat data is stored in the United States. Because the platform proxies messages through Meta APIs, Meta also receives subscriber identifiers and message content. Both ManyChat and Meta rely on the EU US Data Privacy Framework. A Transfer Impact Assessment should cover both transfers and the cumulative risk for the data subject.

Practical compliance steps

Capture explicit opt in with granular descriptions of purposes (welcome, transactional, marketing) before the first message. Record consent (timestamp, channel, IP, version). Block embedded Growth Tools behind a CMP category. Sign DPAs with both ManyChat and Meta. Provide a working STOP keyword and a webform unsubscribe. Document both processors and the US transfer mechanism in your records of processing.

Compliance

ManyChat and the GDPR

ManyChat is classified as “Marketing”. On a site that targets European visitors, it must only load after the visitor consents, and it must be listed in your cookie policy.

Legal basis
Consent (Art. 6(1)(a) GDPR and Art. 5(3) ePrivacy Directive) for the embedded Growth Tools, popups, opt in widgets and any tracking cookies. Performance of a contract (Art. 6(1)(b)) for messages exchanged after explicit opt in. Special rules apply to WhatsApp (Meta Business Messaging Policy).
Risk level
high
Applicable regulations
GDPR, ePrivacy Directive, TDDDG, LSSI CE, CCPA/CPRA, Meta Business Messaging Policy, WhatsApp Business Messaging Policy, EU US Data Privacy Framework
Cookies and trackers

What ManyChat sets and contacts

Tracking method
Conversational marketing platform. ManyChat connects to Meta (Instagram, WhatsApp, Messenger), Telegram, SMS and TikTok and orchestrates automated conversations. The platform also exposes embedded Growth Tools (popups, landing pages) on customer websites that drop cookies and forward identifiers to Meta.
Server location
ManyChat, Inc., San Francisco, California, United States. Subscriber data, conversation histories and analytics are stored on AWS infrastructure in the United States. No European data residency option is available today.
Data transferred outside the EU
All conversation data, subscriber identifiers and analytics are stored on ManyChat US servers. Because ManyChat communicates with Meta APIs, Meta in the United States also receives identifiers and messages. Transfers rely on the EU US Data Privacy Framework or on Standard Contractual Clauses with supplementary measures.

Cookies set (3)

NameTypeDurationPurpose
mc_visitorthird_party1 yearVisitor identifier set by the embedded ManyChat Growth Tools for cross channel attribution.
mc_sessionthird_partySessionSession identifier used to keep state across embedded ManyChat Growth Tools.
_gathird_party2 yearsGoogle Analytics identifier forwarded to ManyChat for funnel analytics on Growth Tools.

Third-party domains contacted (5)

  • manychat.com
  • static.manychat.com
  • m.me
  • wa.me
  • graph.facebook.com
Questions

Frequently asked questions about ManyChat

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Which cookies does ManyChat set?

Embedded ManyChat Growth Tools (popups, opt in widgets, landing pages) load JavaScript from manychat.com and may set first or third party cookies including mc_visitor, mc_session and forward Google Analytics identifiers. All require prior consent under Art. 5(3) ePrivacy.

Is consent required to use ManyChat?

Yes. Explicit prior consent is required for the messaging itself (Art. 13 ePrivacy, Art. 6(1)(a) GDPR), for the embedded Growth Tools and for any tracking cookie. WhatsApp Business messaging has stricter rules under the Meta Business Messaging Policy.

What is the legal basis for processing?

Consent (Art. 6(1)(a) GDPR) for marketing messages and tracking cookies. Performance of a contract (Art. 6(1)(b)) for transactional or customer support messages after explicit opt in. Soft opt in for similar product follow up is usually not sufficient for messaging.

Is data transferred to the United States?

Yes. ManyChat and Meta both store data on US infrastructure. Both rely on the EU US Data Privacy Framework. A Transfer Impact Assessment must cover both processors and the cumulative impact on the data subject.

Do I need a DPIA for ManyChat?

A DPIA is mandatory when ManyChat is used at scale, combined with profiling, behavioural segmentation or sensitive content. The DPIA must cover Meta as a joint sub processor, the US transfers, the WhatsApp Business Messaging Policy and the embedded Growth Tools.

How do I implement ManyChat correctly?

Capture explicit opt in before the first message with granular purposes (welcome, transactional, marketing). Record consent (timestamp, channel, IP, version). Block embedded Growth Tools behind consent. Provide a working STOP keyword. Sign DPAs with both ManyChat and Meta. Document everything in the records of processing.

Which alternatives to ManyChat should I consider?

EU based: Chatfuel (registered in Cyprus but US team), Botpress (Canada, self hostable), Tidio (Poland), Userlike (Germany). For WhatsApp specifically: Charles (Germany), MessengerPeople by Sinch (Germany), Heltar (Netherlands).

How do I update the cookie policy when ManyChat changes?

Subscribe to ManyChat changelog and trust centre. When sub processors, certifications or messaging policies change, update your cookie table, privacy notice and records of processing, and bump the consent banner version.

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