lemlist: DPA, subprocessors and transfers

Links last opened 30 October 2026. Record confirmed by a person on 16 September 2026. 3 recorded changes, listed below.

lemlist contracts through lempire SAS, registered in France. It is registered inside the EEA, so sending personal data to it is not a transfer out of the EEA. Data regions it offers: EU. Its trust center is published at https://trust.lemlist.com/. Its customer data processing agreement, also called a data processing addendum, is published by lemlist itself; the link is below. We open those pages every day — last on 30 October 2026 — and a person last went through this record on 16 September 2026.

Contracting legal entity: lempire SAS
Country of registration: France
Transfer mechanism for its own onward transfers: Standard contractual clauses (SCC)
Reaching lemlist is not a transfer out of the EEA: it is registered in France. This is what the record holds for where it sends personal data on, and it is not something we have checked — its sub-processor list is the place to look.
Data processing agreement: https://www.lemlist.com/legal/dpa
Subprocessor list: We read lemlist's own site on 6 October 2026 and found none there. It may exist behind a login or on request — this says what a visitor can reach, not what the company has.
Security or trust page: https://trust.lemlist.com/
Data regions: EU

What to put in your subprocessor list

A ready row. Replace the purpose with what your client actually uses lemlist for.

Subprocessor	Legal entity	Country	Purpose	Transfer	DPA
lemlist	lempire SAS	FR	CRM and marketing	SCC	https://www.lemlist.com/legal/dpa

Questions people ask about lemlist

Where is lemlist's DPA?: lemlist publishes its customer data processing agreement at https://www.lemlist.com/legal/dpa. We last opened that link on 30 October 2026.
Is lemlist's DPA the same thing as a data processing addendum?: Yes. A data processing agreement and a data processing addendum are two names for the document Article 28 of the GDPR requires between a controller and a processor; vendors use both, and some call it processor terms. What it has to contain does not change with the name. lemlist's is at https://www.lemlist.com/legal/dpa.
Which legal entity does lemlist contract through?: lempire SAS, registered in France. That is the name to put in a record of processing or a sub-processor list, not the brand.
Does sending personal data to lemlist count as a transfer out of the EEA?: No. lempire SAS is registered in France, inside the EEA, so no transfer mechanism is needed to reach it. Where it sends personal data on to is a separate question, and one for its own sub-processor list.
Where is lemlist's trust center?: lemlist publishes it at https://trust.lemlist.com/. A trust center, trust page or security page is the same thing under different names: the vendor's own account of how it protects data, and the place it keeps its certifications. It is lemlist's page, so we link to it rather than repeat what it says.

What has changed, and when

Changes we noticed on lemlist's own pages, each with the page we saw it on. The vendor does not publish this, and neither does anyone else.

29 September 2026
lemlist removed marketing content about a product redesign from their DPA, reducing the document by 3 lines.
Seen on https://www.lemlist.com/legal/dpa
24 September 2026
lemlist updated their Data Processing Addendum document. The change involved adding new introductory content about a website redesign while removing promotional webinar and trial signup messaging.
Seen on https://www.lemlist.com/legal/dpa
22 September 2026
We recorded a change to the UK transfer mechanism.
Recorded from a source other than their own pages.

Building your own sub-processor list?

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Worked out from the registry and what we have written: the country this vendor contracts from, the guides that answer the question this page raises, and the rest of the registry.

Other crm and marketing

Six of them. All crm and marketing in the registry · others that transfer the same way.

Subprocessor

Legal entity

Country

Purpose

Transfer

DPA

lemlist

lempire SAS

CRM and marketing

SCC

https://www.lemlist.com/legal/dpa

Questions people ask about lemlist

Where is lemlist's DPA?

lemlist publishes its customer data processing agreement at https://www.lemlist.com/legal/dpa. We last opened that link on 30 October 2026.

Is lemlist's DPA the same thing as a data processing addendum?

Yes. A data processing agreement and a data processing addendum are two names for the document Article 28 of the GDPR requires between a controller and a processor; vendors use both, and some call it processor terms. What it has to contain does not change with the name. lemlist's is at https://www.lemlist.com/legal/dpa.

Which legal entity does lemlist contract through?

lempire SAS, registered in France. That is the name to put in a record of processing or a sub-processor list, not the brand.

Does sending personal data to lemlist count as a transfer out of the EEA?

No. lempire SAS is registered in France, inside the EEA, so no transfer mechanism is needed to reach it. Where it sends personal data on to is a separate question, and one for its own sub-processor list.

Where is lemlist's trust center?

lemlist publishes it at https://trust.lemlist.com/. A trust center, trust page or security page is the same thing under different names: the vendor's own account of how it protects data, and the place it keeps its certifications. It is lemlist's page, so we link to it rather than repeat what it says.

What has changed, and when

Changes we noticed on lemlist's own pages, each with the page we saw it on. The vendor does not publish this, and neither does anyone else.

29 September 2026

lemlist removed marketing content about a product redesign from their DPA, reducing the document by 3 lines.

Seen on https://www.lemlist.com/legal/dpa

24 September 2026

lemlist updated their Data Processing Addendum document. The change involved adding new introductory content about a website redesign while removing promotional webinar and trial signup messaging.

Seen on https://www.lemlist.com/legal/dpa

22 September 2026

We recorded a change to the UK transfer mechanism.

Recorded from a source other than their own pages.

lemlist: DPA, subprocessors and transfers

What to put in your subprocessor list

Questions people ask about lemlist

What has changed, and when

Building your own sub-processor list?

Where to go next

Other crm and marketing

lemlist: DPA, subprocessors and transfers

What to put in your subprocessor list

Questions people ask about lemlist

What has changed, and when

Building your own sub-processor list?

Where to go next

Other crm and marketing