1. Personal data
A customer's name, phone number, and conversation are personal data. Health data is sensitive data (LGPD — Brazil's data protection law, Law 13.709/2018, art. 5, II): at a clinic, almost every patient message is sensitive.
Sensitive data can only be processed under the cases in art. 11, such as specific and highlighted consent. And the person can ask for human review of a decision made only by a machine (art. 20).
2. Small business
ANPD Resolution CD/ANPD No. 2/2022 simplifies obligations for micro and small businesses: simplified record-keeping (art. 9), data protection officer waived if there is a channel for the data subject (art. 11), and double deadlines (art. 14).
But anyone carrying out high-risk processing loses these simplifications (art. 3). High risk = one general criterion (large scale or significantly affecting rights) and one specific criterion, such as new technology or sensitive data (art. 4). AI reading patient messages can get there: confirm with a specialist before recommending it.
3. WhatsApp: cost
Since July 1, 2025, Meta charges for the WhatsApp Business API per delivered message, with a rate by category (marketing, utility, authentication, service) and by country; service messages have a free tier each month. Check the current rate table before estimating cost.
Free-form messages only within 24 hours after the customer wrote; outside that, only an approved template. And you only message people who agreed to receive messages.
4. WhatsApp: AI
Since January 15, 2026, the API terms prohibit general-purpose AI chatbots (an open assistant, like free conversation with a model) as the main function.
AI for service, scheduling, orders, and sales for the business itself is still allowed. Meta decides what counts as "main," so the assistant's scope must be the business, not chat about any topic.
Official channel or notA tool that connects to WhatsApp without being Meta's official API (or an official provider, that is, a company partner authorized by Meta) goes against WhatsApp's terms of use, and the company's number can be blocked. Don't recommend it. In the diagnosis, mark the channel as official or unofficial and, if it's unofficial, write down that risk.