Please Show Me Where I Have Consented

Individuals may be shocked to learn that Lusha does not need to obtain their active consent to process their personal information. Continue reading below to learn about how Lusha is able to lawfully process your personal information without active consent due to legitimate interest.

As data subjects, individuals have become more aware of their rights regarding collection and processing of their personal information. At Lusha, we understand that your business information may be considered personal information and that concerns regarding data privacy have become increasingly prevalent. That’s why we would like to educate individuals, especially those whose personal information we’ve gathered, about Lusha’s legitimate interest and commitment to privacy.

What is legitimate interest? Legitimate interest is one of six legal bases for the processing of personal data outlined in the General Data Protection Regulation (otherwise known as the “GDPR”). It allows organizations that don’t have a direct relationship with the individual, like Lusha, to process personal information without active consent if they have a genuine and lawful reason, and if their interests are balanced with the fundamental rights and freedoms of the data subjects.

What is Lusha’s legitimate interest? Lusha’s legitimate interest is to enable businesses to achieve commercial success through accessing limited professional and business information of individuals. With the help of first-tier law firms, Lusha conducted a Data Privacy Impact Assessment (“DPIA”). The DPIA concluded that Lusha’s legitimate interest is not outweighed by the fundamental rights and freedoms of the individuals whose data we have collected. More information about Lusha’s legitimate interest can be found in our Privacy Policy.

Why doesn’t Lusha collect active consents? In order to collect consents from individuals, Lusha would need to have a direct relationship with such individuals. In other words, Lusha is not able to collect active consents from individuals because personal information is not collected from individuals directly. Therefore, Lusha must rely on legitimate interest, and in order to be transparent and give individuals the right to control their data, we send individuals Personal Information Notices, as described below.

So, how could I have known that Lusha is processing my data? Lusha is committed to privacy compliance and wants to make sure you have control over your data. Where required by law, individuals in Lusha’s database are sent a Personal Information Notice via email or text message in order to inform them that Lusha holds their personal information. This notice provides individuals with relevant information as required by the laws that Lusha is subject to, including clear instructions for how to opt-out and to exercise other rights as required by law. Individuals are always able to opt-out using our online Removal Form.

Click here to read our article explaining why we require you to provide us with information in the Removal Form.

Although Lusha is not able to collect your active consent, we are still able to process your personal data lawfully under the GDPR due to our legitimate interest. With that in mind, Lusha aims to promote transparency and provide you with control over your data. Please visit our Privacy Center to learn more about our efforts as a privacy leader in our industry and about how you can exercise your privacy rights.