GDPR Compliance Risk

Adobe Lightroom is a US-based service subject to the CLOUD Act. EU organizations using this service risk non-compliance with GDPR data transfer requirements.

GDPR-Compliant Alternative to Adobe Lightroom

🇺🇸Adobe Inc. · US-based · Subject to CLOUD Act

Adobe Lightroom is a comprehensive photo editing and management software developed by Adobe Inc., based in the United States. It is designed to assist photographers and creative professionals in organizing, editing, and sharing their images. Lightroom offers a range of tools for adjusting exposure, color, and composition, as well as advanced features like non-destructive editing and batch processing. Key features include a powerful cataloging system, cloud-based storage, and seamless integration with other Adobe Creative Cloud applications. Lightroom is particularly suited for professional photographers, hobbyists, and creative professionals who require robust photo editing capabilities and efficient workflow management. Users should be aware that data stored in Adobe Lightroom is subject to US data laws, including the CLOUD Act and FISA 702. The pricing model for Adobe Lightroom typically involves a subscription-based plan, which provides access to the latest updates and features as part of Adobe's Creative Cloud offerings.

Why You Need a GDPR-Compliant Alternative to Adobe Lightroom

Since the landmark Schrems II ruling in 2020, transferring personal data to US-based services like Adobe Lightroom has become a significant legal risk for EU organizations. The US CLOUD Act gives American authorities the power to access data held by US companies, regardless of where that data is physically stored — even if it's in an EU data center.

While the EU-US Data Privacy Framework (DPF) adopted in 2023 provides a new legal basis for transfers, privacy experts and legal scholars have raised concerns about its long-term viability. The framework could face the same fate as its predecessors (Safe Harbor and Privacy Shield), both of which were struck down by the Court of Justice of the EU.

For organizations that want to eliminate compliance risk entirely, switching to a European-based design & creative tools is the most straightforward solution. Below are the best GDPR-compliant alternatives to Adobe Lightroom, all headquartered in Europe with data stored in EU data centers.

CLOUD Act Exposure

US authorities can access your data stored by Adobe Lightroom, even if servers are located in Europe.

GDPR Fine Risk

Non-compliant data transfers can result in fines up to 4% of annual global revenue under GDPR Article 83.

EU Alternative Available

2 GDPR-compliant European alternatives available with full EU data residency.

2 GDPR-Compliant Alternatives to Adobe Lightroom

European services with full GDPR compliance and EU data residency

Affinity Suite

🌍

by Affinity Suite

UK-based professional creative suite including Photo, Designer, and Publisher as one-time purchase alternatives to Adobe.

GDPR CompliantEU-Based

paidMigration:●●●2-4 hours

Why switch?

One-time purchase: Affinity Suite costs around $54.99, no subscriptions.
Cross-platform support: Works on Windows, macOS, and iPadOS.
GDPR compliant: Data protection aligned with EU regulations.

Consider

No cloud storage: Requires manual file management, unlike Lightroom's cloud.
Steeper learning curve: Different interface may slow down new users.

View Details Compare Switch Guide

Visit Affinity Suite

Photopea

🇨🇿

by Photopea

Photopea is a web-based graphic editor that supports various file formats, including PSD, XCF, and Sketch. It offers tools for photo editing, vector graphics, and text manipulation. Users can work directly in the browser without the need for software installation, making it accessible across devices.

GDPR CompliantEU-Based

freemiumMigration:●●●2-4 hours

Why switch?

Photopea is free with a functional tier for casual users.
Browser-based; no installation required, works on any OS.
Supports PSD files, allowing easy editing of Adobe projects.

Consider

Learning curve due to different interface and tools compared to Lightroom.
Limited photo organization features compared to Lightroom's cataloging.

View Details Compare Switch Guide

Visit Photopea

Quick GDPR Compliance Comparison

Service	HQ Location	GDPR Native	EU Data Centers	CLOUD Act Free	Pricing
🇺🇸Adobe Lightroom	United States	No	Partial	No	-
🌍Affinity Suite	GB	Yes	Yes	Yes	paid
🇨🇿Photopea	CZ	Yes	Yes	Yes	freemium

Frequently Asked Questions

Is Adobe Lightroom GDPR compliant?

Adobe Lightroom is a US-based service operated by Adobe Inc.. While it may have some GDPR compliance measures, as a US company it is subject to the CLOUD Act, which allows US authorities to access data stored by US companies regardless of where the data is physically located. This creates a fundamental conflict with GDPR requirements for data protection.

What are the GDPR risks of using Adobe Lightroom?

The main GDPR risks include: (1) Data transfers to the US may lack adequate protection since the Schrems II ruling invalidated Privacy Shield, (2) US authorities can demand access under the CLOUD Act, (3) Your organization may face GDPR fines up to 4% of annual revenue for non-compliant data transfers, and (4) User consent may not be sufficient to legitimize transfers given the systematic access by US authorities.

What are the best GDPR-compliant alternatives to Adobe Lightroom?

The top GDPR-compliant alternatives to Adobe Lightroom include Affinity Suite, Photopea. These European services store your data in EU data centers and are fully subject to GDPR protections.

How do I migrate from Adobe Lightroom to a GDPR-compliant alternative?

Most migrations involve three steps: (1) Export your data from Adobe Lightroom using their data export tools, (2) Create an account with your chosen EU alternative, and (3) Import your data into the new service. We provide detailed migration guides for each alternative to make the switch as smooth as possible.

Can EU companies legally use Adobe Lightroom?

Since the Schrems II ruling (2020), EU organizations face significant legal risk when using US cloud services like Adobe Lightroom. While the EU-US Data Privacy Framework (2023) provides a new legal basis, its long-term stability is uncertain. Many EU data protection authorities recommend using EU-based alternatives to avoid compliance risks entirely.

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Migration Resources

Last updated: January 31, 2026