CRMLusha and the GDPR: agreement, role and data location.
Lusha is a crm tool. Its role depends on the activity, it publishes its data processing agreement, and the data location depends on your account. Below: what to check and how to declare it.
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In short
- Category
- CRM
- Usual role
- Depends on the activity
- Data location
- Set per account or project
- Agreement
- Published by the vendor
What does Lusha do with personal data?
Manage prospect and customer relationships and sales activities. That is how Privacyboard describes a typical use of Lusha, as a starting point you can edit.
The data usually involved: business contact names, email addresses, company details and sales communications.
Is Lusha a processor or a controller?
Lusha is a data provider acting as a controller for its contact database and as a processor for customer-supplied data.
Privacyboard does not prefill a role for this vendor on purpose. You are asked to choose, since the answer changes what your privacy policy says and which agreement matters.
Where does Lusha store personal data?
Lusha does not have one fixed location for every customer. The location depends on the plan, the account and the services you enable.
How to find yours: Check your account settings or Lusha’s data processing terms for where your data is stored.
Even when the main location is in the EU, ask whether subprocessors or support access involve a transfer outside the EEA, and record it if so.
Does Lusha have a data processing agreement?
Checked on 1 November 2026. Vendors change their pages, so check the date.
Yes. Lusha publishes the text of its data processing agreement on its own website. Article 28 of the GDPR requires a written contract with every processor, so this is the document to read and keep.
What we noted when we opened the page: Data Processing Addendum dated April 2025 with Part 1 (Lusha as processor) and Part 2 (Lusha as controller). Entity Lusha Systems, Inc. With the Europe Service, data is processed in Israel; no data centers named.
A page that exists does not mean you are covered. Whether the agreement applies to you depends on your plan and on what you accepted, so record the decision yourself in your vendor list.
Read the Lusha agreementHow to declare Lusha
- 1
In your privacy policy
Name Lusha as a recipient, say what it is used for (manage prospect and customer relationships and sales activities) and mention any transfer outside the EEA. Articles 13 and 14 ask you to tell people who receives their data.
- 2
In your vendor list
Add Lusha with its purpose, the data involved, its role, its region and a link to the agreement. Privacyboard prefills all of this, you confirm or correct it.
- 3
In your processing register
Link Lusha to the activities that use it, so each record shows its recipients. Article 30 asks the register to list the categories of recipients.
What to check before relying on Lusha
- Define a retention period for inactive leads and contacts.
- Make sure you can find, export and delete one contact across the CRM.
- Record the legal basis for outreach, and respect objections to marketing.
- Record the region and any transfer outside the EEA.
Questions, answered.
Is Lusha GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Lusha is configured and used, on the agreement you have with it and on your own practices. What can be checked is documented here: it publishes a data processing agreement, the usual role and the data location. Read the agreement itself before relying on it.
Does Lusha have a DPA?
Yes. Lusha publishes the text of its data processing agreement on its own website. Article 28 of the GDPR requires a written contract with every processor, so this is the document to read and keep. You can read it at https://www.lusha.com/legal/dpa-2-2/.
Is Lusha a data processor?
It depends on the activity. Lusha is a data provider acting as a controller for its contact database and as a processor for customer-supplied data.
Where does Lusha store data?
Lusha does not have one fixed location for every customer. The location depends on the plan, the account and the services you enable. How to find yours: Check your account settings or Lusha’s data processing terms for where your data is stored.
Do I need to mention Lusha in my privacy policy?
Yes, if Lusha handles personal data for you. The GDPR asks you to tell people who receives their data (Articles 13 and 14). Name the vendor or its category, say what it is used for and mention any transfer outside the EEA.
How do I add Lusha to my vendor list?
In Privacyboard, pick Lusha from the catalog. The purpose, the data, the suggested role and a link to its agreement are prefilled, and you confirm each one. Creating a workspace is free.
Privacyboard is not affiliated with Lusha. Names and logos belong to their owners and are used only to identify the tool. This page summarises public documents as checked on 1 November 2026; it is guidance, not legal advice, and it does not certify any vendor.