{"object":"determination","schema_version":"1","vendor":"Darktrace","state":"determined","sentence":"Contracts with Darktrace Holdings Limited (United Kingdom), under terms this record cannot reach — under US corporate control, so US law may have legal reach over it and the data it controls.","qualifier":"Controlled by Thoma Bravo (United States), per a release issued by Darktrace [2026-09-12]. GLEIF records the entity's own reporting exception for its parent (NON_CONSOLIDATING, read [2026-09-12]).","contracting_entity":"Darktrace Holdings Limited","jurisdiction":"United Kingdom","governing_law":null,"conditions":["Its terms are ones this record cannot reach."],"us_control":{"status":"sourced_us_parent","finding":"Yes — a US parent or US contracting entity is on the public record","parent":{"name":"Thoma Bravo","country":"United States","source_url":"https://www.darktrace.com/news/darktrace-announces-formal-completion-of-its-acquisition-by-thoma-bravo","read":"2026-09-12","citation":"controlled by Thoma Bravo (United States), per a release issued by Darktrace [2026-09-12]"},"legal_reach":"A sourced US parent controls the vendor, so US law may have legal reach over it and the data it controls.","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.darktrace.com/news/darktrace-announces-formal-completion-of-its-acquisition-by-thoma-bravo","document_title":"Darktrace announces formal completion of its acquisition by Thoma Bravo","date_read":"2026-07-29","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":["governing_law"]}