{"object":"determination","schema_version":"1","vendor":"Clay","state":"determined","sentence":"Contracts with Clay Labs Inc., governed by New York law.","qualifier":"Vannus has not established whether a US parent controls this entity, so US reach is not established either way.","contracting_entity":"Clay Labs Inc.","jurisdiction":null,"governing_law":"The Federal Arbitration Act, federal arbitration law, and New York law will apply to these terms and any disputes related to these terms or our services, regardless of conflict of laws rules. Read 22 September 2026.","conditions":[],"us_control":{"status":"not_established","finding":"Not disclosed — the vendor's own documents name the contracting entity but do not settle whether a US entity or parent controls it","parent":null,"legal_reach":"The record does not establish US corporate control either way, so it makes no finding on US legal reach.","caveat":null,"rule":"A provider subject to US jurisdiction can be required by valid US legal process to produce data in its possession, custody or control wherever it is located (CLOUD Act, 18 U.S.C. § 2713). A US-incorporated contracting entity is subject to US jurisdiction. A non-US contracting entity under US corporate control may be within reach through that control, depending on whether the parent controls the data and on the circumstances; where that control has not been established, the entity is not thereby beyond reach.","rule_url":"/static/manifesto.html#us-reach-rule"},"evidence":{"source_url":"https://www.clay.com/terms-of-service","document_title":"Clay: Terms of Service","date_read":"2026-09-14","last_rechecked":{"last_check":"found_again","gate":"readable","date":"2026-10-19","words":"clause re-checked 19 Oct 2026"},"quote":null,"quote_carried_by":"the AI Subprocessor Jurisdiction Report ($299), which quotes the clause each finding rests on"},"not_established":["jurisdiction","us_control"]}