Is Lusha GDPR Compliant?

TL;DR

Yes, conditionally. Lusha positions itself as GDPR-compliant as a processor, with legally binding Data Processing Agreements (DPAs) including EU and UK Standard Contractual Clauses, ISO 27701/27001/27018 and SOC 2 certifications, legitimate interest basis with user notification, a self-serve privacy center for DSARs and opt-outs, full transparency, and ePrivacyTrust audits.

1. Lusha’s GDPR Compliance Framework
   1. 1. Legal Contracts & Certifications
   2. 2. Lawful Processing & Legitimate Interest
   3. 3. Data Minimization & Transparency
   4. 4. Data Subject Rights & Privacy Center
   5. 5. Subprocessor Transparency
   6. 6. Privacy Governance
2. Regulatory Context
3. Who Should Care?
4. General Caveat
5. Final Thoughts

Lusha’s GDPR Compliance Framework

1. Legal Contracts & Certifications

• Provides a pre-signed Data Processing Agreement with EU/UK SCCs. [www.lusha.com]
• Certified under ISO 27701 (privacy), ISO 27001, ISO 27018, and SOC 2 Type 2; also holds ePrivacyTrust and TrustArc seals. [www.lusha.com]

2. Lawful Processing & Legitimate Interest

• Operates under the GDPR legitimate interest legal basis.
• Performs DPIAs and sends Personal Information Notices to EU data subjects with opt-out capabilities. [www.lusha.com], [www.lusha.com]

3. Data Minimization & Transparency

• Collects only minimal business contact data from public sources.
• Discloses sources, usage, and retention policies. Offers location filters to exclude EEA/UK records per user choice. [www.lusha.com]

4. Data Subject Rights & Privacy Center

• Provides a self-service portal to access, rectify, erase, or opt out of data.
• Notifies customers when data subjects request deletion.

5. Subprocessor Transparency

• Publishes subprocessors, notifies updates, and permits customer objections.

6. Privacy Governance

• Appointed DPO and compliance manager; mandatory global privacy training for staff. Implements "privacy by design" controls.

Regulatory Context

• CNIL investigated Lusha's browser extension but concluded in 2022 that GDPR did not apply (as Lusha neither offered EU services nor targeted EU users). [www.digitalpolicyalert.org]

Who Should Care?

• B2B Users & Teams using Lusha for lead generation need to understand its processing basis and tools for opt-outs and DSARs.
• Privacy Officers and Legal Counsel should review the DPA, DPIAs, SCCs, notification processes, subprocessors list, and location filtering features.
• EU Data Subjects can request data erasure or opt-out via Lusha’s Privacy Center.

General Caveat

This summary is based on publicly available information and is not legal advice. Lusha provides strong contractual frameworks, technical safeguards, and user controls. However, GDPR compliance depends on correct configuration, lawful-basis justification, and transparent practice. Businesses using Lusha should ensure they understand and manage how personal data is processed.

Final Thoughts

Lusha maintains a robust GDPR posture for its business use: pre-signed DPA with SCCs, privacy certifications, legitimate interest with transparency, and user empowerment tools. The CNIL’s conclusion that GDPR doesn’t apply to its extension reflects jurisdiction nuance, not technical compliance. If configured properly, Lusha can be a compliant tool—but organizations must remain attentive to settings and user rights.