LUSHA – PRIVACY POLICY

Last Updated: October 31, 2019

LUSHA ALLOWS YOU TO ACCESS YOUR PERSONAL INFORMATION, EDIT IT OR OBTAIN DATA COLLECTED ABOUT YOU. JUST CLICK THIS LINK AND FILL IN YOUR REQUEST

GENERAL

This Privacy Policy outlines Lusha Systems Inc.’s (“Lusha”, “we” or “us”) practices with respect to collecting, using and disclosing information when providing our online services (collectively, the “Services) and constitutes an integral part of Lusha’s Terms of Service (“Terms”, and collectively, the “Agreement”).

Our Services are designed to help Users and vendors (e.g. HR professionals, B2B partners, sales platforms) validate and verify contact information and to find business profiles they seek in order to interact with relevant Contacts (as defined below), through access to business profiles retained in Lusha’s database (“Lusha Database”). 

The information provided by Lusha is not directly created by Lusha, but rather is retrieved from the web, public sources or from the contribution of relevant data from other users and business partners.

We respect your privacy and are committed to protecting the privacy and security of:

  • (i) Individuals’ business information, such as email address, name and telephone number (each individual, a “Contact”), which is collected and retained in the Lusha Database (“Business Profile(s)”); and
  • (ii) Our users who download, install or use the Lusha browser extension (“Plugin”) or access the Lusha’s website (“Site”) (each, a “User”).

The term “you” shall refer to Users or Contacts, as applicable.

We encourage you to read the Privacy Policy carefully and use it to make informed decisions.

In this Privacy Policy you will read about:

  • Lusha Database
  • What type of information we collect
  • Cookies
  • How we use the information we collect
  • Sharing the information with third parties
  • Marketing
  • How do we safeguard your information
  • How to contact us

LUSHA DATABASE

The Business Profiles we collect from publicly available sources and from our trusted business partners are stored in the Lusha Database. Our algorithms process this information in order to identify the most up-to-date information related to each profile. 

In addition, The Lusha Database includes Business Profiles relating to individuals, which were lawfully obtained by Lusha from business partners who own established and legitimate directories or from publicly available sources. 

We may use and share Business Profiles with our Users when they use our Plugin online for the purpose of validating and authenticating online identities by finding relevant data related to a specific individual. 

We may also disclose to our vendors and business partners (or permit their access to) Business Profiles retained in the Lusha Database for the purpose of ensuring that their current data is up to date, enriching it and allowing our partners to obtain relevant Business Profiles for employment, commercial and business opportunities. 

If you prefer that we will not share your Business Profile with our Users, vendors or business partners, you may opt-out by filling in your relevant details here. In this case, we shall not continue to use or disclose your Business Profile. To learn more on our commitment to respect your rights in accordance with applicable privacy and data protection regulations, please see “Your Rights Regarding Your Personal Information” below.

 

The following information is not collected to the Lusha Database: any information which is shared with us by our Users when downloading or using our Plugin, Salesforce App, or accessing and registering on our Site.

Specifically – If a User chooses to connect its Salesforce account to the Lusha Salesforce App, Lusha will not collect information associated with such use

In order to provide our service and match the relevant information from our database with applicable profiles Users view on supported sites, we need to read certain words (such as full name and company name of the Contacts).

We store the data in our servers temporarily and delete it after providing the Users with the service. This data is not added to our database.  

WHAT TYPE OF INFORMATION WE COLLECT

As explained in details below, we collect two main types of information. The first type (i.e. “Business Profiles”) is used to enrich the Lusha Database and allow us to share Business Profiles with our Users, vendors and business partners. The second type of information (i.e. “User’s Data”) is mainly collected to allow Users to use our Plugin and other related services and products. The information in the Lusha Database is collected and processed based on our legitimate interest in providing our Services. The information of our Users is collected and processed based on (i) Users’ consent; (ii) in order to perform a contract; and (iii) to fulfill our legitimate interest.

1. Business Profiles

We collect Business Profiles which are related to Contacts from different public sources and from our trusted business partners in order to enhance, optimize and enrich the Lusha Database and make it current and up to date as possible, thus allowing us to provide our Services. We collect information from the following third-party sources: (i) third parties who license, sell or otherwise provide data they have collected; or (ii) information from publicly available sources, such as via the Internet and social networks, including through public or licensed APIs. For example, we use open web services and APIs to complete and update the information we have about Contacts and enrich it (e.g. by adding links to Contacts’ verified social network profiles), in order to allow our Users and vendors to find relevant Business Profiles.

We do not add to the Lusha Database any Business Profiles or any other information which is shared with us by our Users when downloading or using our Plugin or accessing our Site.

2. User’s Data

We collect two categories of information from our Users:

  • The first category of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Services (“Non-personal Information”). We are not aware of the identity of the User from which the Non-personal Information was collected. Such information includes the following:
  • (a) We collect technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time and the domain name from which you linked to the Services; etc.), in order to enhance the functionality of the Services and to provide you with a better user experience.
  • (b) We may also collect information about your use of the Services, such as log files, time stamps, alerts, etc. This information is collected for amongst other things troubleshooting errors and bugs as well as for research and analytics purposes about your use of the Services.
  • (c) We may anonymize or de-identify the information collected by the Services or via other means so that the information cannot, on its own, personally identify you. Our use and disclosure of such aggregated or de-identified information are not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation and for any purpose.
  • The second category of information is information about you that specifically identifies you or when combined with other information we have, can be used to identify you. Such information is collected as part of the following activities and includes the following items:
  • (a) User activity (e.g. pages viewed, browsing activity, page viewed, etc.).
  • (b) In order to download our Plugin, you will be required to register for the Services (e.g. through our Site). As part of the registration process, we will collect your full name, email address, and telephone number. In addition, when you upgrade and purchase our paid version of the Plugin you will be requested to enter your payment information (e.g. your credit card number, PayPal account, etc.). We do not collect such information directly and the processing of such payment information is made by our trusted third party service providers.
  • (c) When you register or connect the Site or Services with your social network account (each a “Platform”), we may have access to basic information about you from such Platform, such as your name, home address, email address, contact list, as well as any other information you made publicly available on such Platform or agreed to share with us. At all times, we will abide by the terms, conditions, and restrictions of such Platforms.
  • (d) We collect information which you provide us voluntarily. For example, when you respond to communications from us, performing a purchase through our Site, communicate with us via email or the Site or share additional information about yourself or about others through your use of the Services.
  • (e) If you agree to use Lusha’s referral service to invite friends to use Lusha, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting them to visit the Site and install the Plugin.

We do not add to The Lusha Database any information which is shared with us by our Users when downloading or using our Plugin or accessing our Site.

 

COOKIES

A cookie is a small data file that is sent to your device when you first visit a website. Cookies usually include an identification number that is unique to the device you are using. Such identifier can help us better understand our Users and how they are using the Site and the Services.

Cookies also enable recognition of a User when they re-visit the Site, keeping their settings and preferences and ability to offer customized features. If you prefer, however, at any time you can reset your browser so it refuses all cookies, or notifies you when a cookie is being sent.

The Services may implement the following types of cookies:  (i) cookies implemented by us for the purposes described above (“First Party Cookie”); and (ii) third party cookies which are set by other online services who run content on the page you are viewing, for example by third party analytics companies who monitor and analyze our web access.

You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Services may not operate properly and your online experience may be limited.

HOW DO WE PROCESS AND USE THE INFORMATION?

We use the information we collect in the ways and for the purposes described above. We may also use such information in the following ways, and for additional purposes, as follows:

1. Business Profiles

We use Business Profiles which are related to Contacts for the following purposes:

  • To enable our Users, trusted vendors and business partners to access the Business Profiles retained in the Lusha Database(e.g. through API) for the purpose of providing our Service;
  • To enrich Lusha Database with current and up to date Business profiles;
  • To respond to Contacts’ inquiries, support request, feedbacks or questions;
  • To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services;
  • To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.

2. User’s Data

We use User’s Data for the following purposes:

  • To verify User’s registration to the Services and approve User’s email address;
  • To provide our Services and help Users in finding relevant Business Profiles when using top social network websites;
  • To respond to User’s inquiries, support request, feedback or questions.
  • To manage User’s account and provide Users with customer support;
  • To identify and authenticate User’s access to the Services;
  • To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services;
  • To communicate with Users and to keep them informed of our latest updates, upgrades, and products;
  • To perform research or to conduct analytics in order to improve and customize our Services to Users’ needs and interests; and
  • To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.

SHARING INFORMATION WITH THIRD PARTIES

We may share information with third parties in the ways and for the purposes described above. We may also share and disclose such information, if we believe in good faith that such disclosure is necessary or required: (i) to comply with a law, regulation, governmental or securities exchange requirement, court order, judicial proceeding or legal process, such as a subpoena or a search warrant; (ii) to address a violation of the law; (iii) to investigate fraud or criminal activity, and to protect our rights or those of our affiliates, vendors and Users, or as part of legal proceedings affecting or may affect us or our affiliates, vendors or Users; and (iv) to allow Lusha to exercise its legal rights or respond to a legal claim.

We may also share information in the following ways, and for additional purposes, as follows:

1. Business Profiles

We share Business Profiles which are related to Contacts with our Users, trusted vendors and business partners. Specifically, we may disclose to them (or permit their access to) Business Profiles retained in the Lusha Database for the purposes of ensuring that their prospective or existing Business Profiles are authentic, current and up to date.

At any time, you may decide to opt-out from enabling us to disclose or allow access to your Business Profile information stored on the Lusha Database by filing in your relevant details here.

We may also share Business Profiles stored in our database with the following recipients: (i) our subsidiaries; (ii) subcontractors and other third-party service providers (e.g. hosting services, etc.); (iii) auditors or advisers of our business processes; and (iv) any potential purchasers or investors in Lusha.

2. User’s Data

We may share Business Profiles which are related to Contacts with our Users, trusted vendors and business partners. Specifically, we may disclose to them (or permit their access to) Business Profiles retained in the Lusha Database for the purposes of ensuring that their prospective or existing Business Profiles are authentic, current and up to date.

At any time, you may decide to opt-out from enabling us to disclose or allow access to your Business Profile information stored on the Lusha Database by filing in your relevant details here.

We may also share Business Profiles stored in our database with the following recipients: (i) our subsidiaries; (ii) subcontractors and other third-party service providers (e.g. hosting services, etc.); (iii) auditors or advisers of our business processes; and (iv) any potential purchasers or investors in Lusha.

RETENTION

Personal Information will be retained by Lusha for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it was collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.

If you wish to remove Business Profiles existing in our servers or if you prefer that we will not share your Business Profiles with our Users, vendors or business partners, you may opt-out by filling in your relevant details here. In this case, we shall not continue to process your Business Profiles.

Please be notified: while we respect removal of privacy requests, since the Lusha Database relies on various data sources, including publicly available sources, we may obtain in the future other records of personal data which may be associated with you. In this case, since we have complied with your deletion request, we will not have records regarding your personal data and such additional information may be reintroduced into the Lusha Database. We recommend you to periodically check your profile or the Services to ensure that your then-existed profile or account include only the Information you chose to have displayed.

HOW DO WE SAFEGUARD AND TRANSFER YOUR INFORMATION?

We take great care in implementing and maintaining the security of the Services and your information. We employ industry standard procedures and policies to ensure the safety of your information and prevent unauthorized use of any such information.

Since we operate globally, it may be necessary to transfer your Personal Information to countries outside the European Union. In such cases we will transfer your Personal Information only to such countries as approved by the European Commission as providing adequate level of data protection, rely on our self-certification under the EU-U.S. Privacy Shield Framework, and/or enter into legal agreements ensuring an adequate level of data protection.

If you feel that your privacy was treated not in accordance with our policy, or if any person attempted to abuse our Services or acted in an inappropriate manner, please contact us directly at support@lusha.co.

MINORS CONTROL

The products and services of Lusha are not targeted to or intended for children under the age of 18. If you are under 18, you may not submit information about yourself to Lusha. Lusha reserves the right to modify or remove any information on the Site or Services at its own discretion.

In the event that we become aware that a User is under the age of 18 has shared any information, we will discard such information. If you have any reason to believe that a minor has shared any information with us, please contact us at support@lusha.co.

MARKETING

We may use Users’ Personal Information, such as names and email addresses, ourselves or by using our third-party subcontractors for the purpose of providing our Users with promotional materials and newsletters concerning our Services, which we believe may interest them.

Out of respect to their right to privacy, at any time, Users may request to unsubscribe and discontinue receiving marketing offers.

A Note to EU individuals

Lusha complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries (and Iceland, Liechtenstein, and Norway) and Switzerland transferred to the United States pursuant to Privacy Shield.  Lusha has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

Lusha is subject to the investigatory and enforcement powers of the Federal Trade Commission.

Pursuant to the Privacy Shield Frameworks, EU individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States.  Upon request, we will provide you with access to the personal information that we hold about you.  You may also correct, amend, or delete the personal information we hold about you.  An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to Support@Lusha.co.  If requested to remove data, we will respond within a timeframe required under applicable laws.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than as described in the privacy policy, or before we use it for a purpose other than which it was originally collected or subsequently authorized.  To request to limit the use and disclosure of your personal information, please submit a written request to Support@Lusha.co.

 

Lusha is required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Lusha’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Lusha remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Lusha proves that it is not responsible for the event giving rise to the damage.

In compliance with the EU-US Privacy Shield Principles, Lusha commits to resolve complaints about your privacy and our collection or use of your Personal Information. European Union individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at support@lusha.co or by mail at the address below.

Lusha has further committed to refer unresolved Privacy Shield complaints to the Better Business Bureau (BBB) Privacy Shield, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit the BBB Privacy Shield at http://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information or to file a complaint. The services of the BBB Privacy Shield are provided at no cost to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.  See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction

Lusha respects your privacy rights and therefore you may contact us at any time and we shall work diligently to respect your choices and requests regarding your Personal Information. The purpose of the list stipulated below is to allow Users and Contacts to exercise their rights under applicable privacy and data protection regulations:

Your Rights

  • Right of Access: You may request to access your Personal Information and obtain a copy of Personal Information which is being processed by Lusha. In the event that you request to know what Personal Information is being processed by us, we will provide you with the following information free of charge: purposes of processing; categories of Personal Information processed; recipient(s) of Personal Information; length of time during which the Personal Information will be stored; your privacy rights; and information on data transfers. Such requests will be made by filing in your relevant details
  • Right of Rectification: You may request to change, update or complete any missing data we process about you, by contacting Support@Lusha.co with your relevant details. Please note that we may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.
  • Right of Erasure: You may at any time withdraw your consent to our processing of your Personal Information. In this case, if there is no overriding legitimate interest for continuing the processing of your Personal Information (e.g. to comply with our legal obligations, resolve disputes, enforce our agreements, etc.) and the Personal Information is no longer necessary in relation to the purpose for which it was originally collected, we will erase your data. Such withdrawal of consent will be made by contacting us at Support@Lusha.co with your relevant details.
  • Right of Restriction of Processing: You may request us to restrict processing of your Personal Information if one of the following applies: (i) the accuracy of the Personal Information is contested by you; (ii) the processing is unlawful; or (iii) if we no longer need the Personal Information. Such request will be made by contacting us at Support@Lusha.co with your relevant details.
  • Right to Data Portability: You have the right to receive the Personal Information in a structured, commonly used and machine-readable format. Such request will be made by contacting us at Support@Lusha.co with your relevant details.
  • Right to object to processing Data: You have the right to object to processing your data. Such a request will be made by sending an email with your relevant details to Support@Lusha.co

If you wish to raise a complaint on how we have handled your Personal Information, please contact us directly at Support@Lusha.co

Please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements

If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with the laws, you can complain to the applicable data protection authority here at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

 

CHANGES TO THIS POLICY

Lusha reserves the right to modify this Privacy Policy from time to time, so please review it regularly. If we make material changes to this policy, we will notify you here, by email or by means of a notice on the Site’s homepage prior to the changes becoming effective.

You are requested to regularly reviewing the Privacy Policy. You hereby declare that your continued use following any changes made to the Services or the Privacy Policy shall constitute your consent to any modified terms.

CONTACT US

If you have questions or concerns regarding this Policy, you should first contact us by email at Support@Lusha.co or:

Lusha Systems Inc

1177 Avenue of the Americas, 5th Floor

New York, NY 10036

Individuals from the EU may contact our EU representative according to Art. 27 GDPR regarding all requests related to data protection and privacy:

DP-Dock GmbH
Lusha Systems Inc
Ballindamm 39
20095 Hamburg
Germany