Lime transfers user data to the United States for processing, even if you live in a country with stronger privacy protections, and the data will be subject to US law once transferred.
This analysis describes what Lime's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
For EU, UK, and other international users, this means their personal data including location history may be transferred to a jurisdiction with a different privacy legal framework, and the adequacy of the transfer mechanisms protecting that data is not detailed in the notice.
Interpretive note: The document does not specify which transfer mechanism (SCCs, DPF, consent) is used for EU-to-US transfers, making it unclear whether current practices fully satisfy GDPR Chapter V requirements.
Your personal data may be moved to and processed in the United States regardless of where you live, which means it is subject to US legal process and oversight; the specific mechanisms used to protect EU user data during this transfer are not detailed in the notice.
How other platforms handle this
Your personal information may be transferred to, stored, and processed in the United States or other countries outside of your country of residence, which may have data protection laws that are different from those in your country.
Your personal information may be transferred to, stored, and processed in the United States or other countries where our service providers and partners operate. By using our Services, you acknowledge that your personal information may be transferred to countries outside your country of residence, in...
At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.
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"Your information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including personal data, to the United States and process it there.— Excerpt from Lime's Lime Privacy Policy
REGULATORY LANDSCAPE: Cross-border data transfers from EU/EEA to the US engage GDPR Chapter V, specifically the adequacy decision framework and standard contractual clauses (SCCs) as updated in 2021. The EU-US Data Privacy Framework (DPF) adopted in 2023 provides an adequacy basis for certified US companies, but Lime's participation in the DPF is not stated in the document. UK transfers to the US engage the UK GDPR and the UK-US Data Bridge. The FDPIC governs Swiss transfers. Transfers to and from other jurisdictions (Brazil, Japan, etc.) engage national equivalents. GOVERNANCE EXPOSURE: Medium-High. The policy discloses transfers but does not specify the legal mechanism used (SCCs, DPF certification, consent, or other), which is a material GDPR transparency gap. Following the Schrems II ruling (CJEU, 2020), transfer mechanisms must be accompanied by supplementary measures where US surveillance laws create risks to EU data subjects. Absence of mechanism specification may attract DPA scrutiny. JURISDICTION FLAGS: EU/EEA (GDPR Chapter V, highest exposure), UK (UK GDPR and PECR), Switzerland (nFADP), Brazil (LGPD Chapter X), and any jurisdiction with data localization requirements. California residents transferring data to US processors face no heightened risk from this provision specifically. CONTRACT AND VENDOR IMPLICATIONS: All processors and sub-processors in the US receiving EU personal data must be covered by SCCs or DPF. Transfer impact assessments may be required. B2B customers or municipal partners in the EU should confirm whether their data flows through US-based Lime infrastructure and request copies of applicable transfer mechanisms. COMPLIANCE CONSIDERATIONS: Document specific transfer mechanisms by data flow and recipient country, verify DPF certification status or SCCs are in place for EU-to-US transfers, conduct transfer impact assessments where required, and update Records of Processing Activities (RoPA) to reflect all cross-border flows.
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For EU, UK, and other international users, this means their personal data including location history may be transferred to a jurisdiction with a different privacy legal framework, and the adequacy of the transfer mechanisms protecting that data is not detailed in the notice.
Your personal data may be moved to and processed in the United States regardless of where you live, which means it is subject to US legal process and oversight; the specific mechanisms used to protect EU user data during this transfer are not detailed in the notice.
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