PERSONAL INFORMATION NOTICE - NEW CONTACTS

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This notice serves to provide you with information about the collection, processing, and sharing of certain of your personal information in relation to your professional or employment capacity (“Personal Information“) by Lusha Systems Inc. and Lusha Systems Ltd., acting as joint data controllers (“Lusha“). Please continue reading below for more information about the information we collect, how we gather it, and how it is used and shared. For more information about Lusha’s data processing activities more generally, please refer to our Privacy Notice.

Lusha’s proprietary online platform assists businesses (our “Customers“) to find business contact information  (“Business Contact Information“) regarding business professionals (“Contacts”) and companies retained in Lusha’s B2B  database (“Database“). 

Our Customers may use the Business Contact Information for sales, marketing, recruiting and fraud prevention purposes, subject to restrictive license agreements that limit the use to those specified purposes and prohibit the unauthorized use or transfer of the information.

Right to opt-out

If this is the first time you are being notified by Lusha regarding the processing of your Personal Information and you do not want your Business Contact Information to be included in our B2B Database, you have 14 days from the delivery of this notice to opt out using the instructions provided below.

If your Business Contact Information is already in Lusha’s B2B Database, you may exercise your right to opt out at any time. If you exercise this right, your Business Contact Information will be removed from our B2B Database and added to our suppression list, to ensure it is not reintroduced in the future. Additionally, our clients who have had access to your Business Contact Information will be informed of your opt-out request.

To opt-out you can: 

• use our opt-out form
• contact us at privacy@lusha.com

Categories of Personal Information Processed 

Lusha only processes Business Contact Information and related business attributes of Contacts. Depending on the sources available, the Business Contact Information we process may include:

• Full name
• First name
• Last name
• Middle Name
• Organization Name
• Job title
• Seniority
• Role
• Email address
• Phone number
• Country 
• State
• Social media URL
• Professional & Education background
• Picture associated with your professional profile
• Categorization of Contacts based on the above categories of personal data

Sources of Personal Information

Our Lusha B2B Database relies on data retrieved or derived from: 

• Our Community Program: Customers which have voluntarily chosen to become part of our Community Program may share data relating to their professional business network with us. You can learn more about Lusha’s Community Program here.
• Our affiliates and group members: we receive Business Contact Information from affiliates, i.e. subsidiaries, parent companies, joint ventures, and other corporate entities under common ownership or in the same corporate group.

• Publicly available sources: We source We source Business Contact Information from trusted data brokers and also use publicly available APIs to collect data from publicly available sources.

• Auto-Complete Feature: Our proprietary algorithm scans publicly available sources and retrieves public information to understand standard corporate email patterns (e.g firstname.lastname@company.com). 
• Business social network profiles: When a customer uses our browser extension while using LinkedIn, we read the minimum data presented on the LinkedIn profile pages that the customer is browsing for providing our service ( e.g. name, position, company, contact details if public)

Purposes and Legal Basis of Processing 

• Purposes related to the provision of our Services: Enabling our Customers and their service providers to access and use our B2B Database and the related features and creating, enriching, updating, cross-checking and validating our B2B Database.

Legal basis: Our legitimate interest in fighting against identity theft and online fraud and our legitimate interest in providing accurate and up to date Contact data, allowing our Customers to engage with other businesses and business representatives in meaningful and effective online and offline interactions.

• Purposes related to the analysis and improvement of our Services: Responding to your questions, support requests, or feedback, and conducting troubleshooting, data analysis, testing, research, statistical and survey analysis. 

Legal basis: Our legitimate interest in operating a successful business and our legitimate interest to improve our services.

• Purposes related to compliance with regulations and the fight against fraud: Detecting and preventing fraudulent and illegal activity, or any other type of activity that may jeopardize or negatively affect the integrity of our services, responding to your requests regarding your data, investigating violations and enforcing our policies, complying with applicable laws, regulations, or requirements of other governmental authorities, complying with a subpoena or similar legal process, or responding to a government authority’s request.

Legal basis: Our legitimate interest in ensuring the safety and proper functioning of our services, our legitimate interest in ensuring that our Terms of Use and other policies are complied with, our legitimate interest relating to the exercise of our rights or the defense of our legal rights and compliance with our legal obligations.

In relation to the processing activities where Lusha relies on legitimate interests, you may obtain, upon request, information on the balancing test conducted by Lusha by contacting us at privacy@lusha.com.

Recipients

Subject to restrictive license agreements, we share Business Contact Information with our Customers (which are businesses operating in various sectors including the tech, retail, consultancy and recruitment), for the purpose of providing our services and allowing access to authentic, current, and up to date business contact information.

We may also share Business Contact Information with our service providers, including (i) hosting services providers, (ii) data analytics providers, (iii) payment processors, and (iv) security services providers. A full list of service providers, including their purpose, locations, and transfer method can be found here.

We may also share Business Contact Information In connection with an asset sale, merger, bankruptcy, or other business transaction and with other third parties and public authorities where legally required, to investigate fraud or criminal activity, protect our rights or those of our affiliates, vendors and Customers, or as part of legal proceedings which affect or may affect us or our affiliates, vendors or Customers; and to allow Lusha to exercise its legal rights or respond to a legal claim.

International Transfers

We may share information with third parties in the ways and for the purposes described above, including to overseas recipients, located in countries including the United States, the United Kingdom, Australia and Israel. 

Where transfers are made to a country not providing an adequate level of protection, they are subject to appropriate safeguards. Information on such appropriate safeguards may be obtained by sending an e-mail to privacy@lusha.com

Retention Period

We retain your data for the period for which it is used to provide our Services and, thereafter in archives, for the period required to comply with our legal obligations, resolve disputes and enforce our policies.

No automated decision making producing legal effects or having similar significant effects on you

Lusha does not make decisions based solely on automated processing, including profiling, that produce legal effects concerning you or has similar significant effects on you.

Your Rights 

You have the following rights which you can exercise through our Privacy Center or by contacting us at privacy@lusha.com:

• Right of access: You may obtain confirmation as to whether or not your data is processed by Lusha. As applicable, you may receive more information on the data we hold and how your data is processed, and receive a copy of your data.
• Right of rectification: You may rectify your data if it is inaccurate or incorrect or out-of-date. You may also have incomplete data completed.
• Right of erasure: You may request the erasure of your data, e.g. if you object to the processing of your data (see below). However, we may have legal or legitimate reasons for retaining the data depending on the context. Upon complying with your request, we shall also inform the Customers that purchased your data. For more information see here.
• Restriction of processing: You may request a restriction of the processing of your data. We will mark your data to limit its future processing.
• Right to object / opt out: You may object to the processing of your data where such processing is based on legitimate interest as described above. We will stop the processing unless we have compelling legitimate grounds to continue processing the personal data.

The foregoing rights may be subject to certain limitations.

You also have the right to lodge a complaint with the appropriate supervisory authority in your country, if any. 

Who We Are and how to contact us

Lusha Systems Inc. (800 Boylston St, Suite 1410, Boston, MA 02199,  United States) is a registered data broker in the State of California, Vermont,Texas and Oregon and is owned by Lusha Systems Ltd. (132 Derech Menachem Begin, Tel Aviv 6701101, Israel) which is a registered data broker in Israel.

You can contact us via:

• the Lusha Privacy Center
• postal mail: 800 Boylston St, Suite 1410, Boston, MA 02199,  United States 
• email at privacy@lusha.com

Lusha has appointed DP-Dock GmbH as a contact point in the European Union and DP-Data Protection Services UK as a contact point in the United Kingdom. We hope that in the first instance, you can raise any questions and concerns with our Data Protection Officer by email (privacy@lusha.com), but you can also contact DP-Dock GmbH or DP-Data Protection Services UK at lushasystems@gdpr-rep.com or write to them:

In the EU:
DP-Dock GmbH
Attn: Lusha Systems, Inc.
Ballindamm 39
20095 Hamburg
Germany

In the UK:
DP-Data Protection Services UK
Attn.: Lusha Systems, Inc.
16 Great Queen Street
London WC2B 5AH
United Kingdom

Sincerely, 

Lusha Privacy Team