{"object":"determination","schema_version":"1","vendor":"Proton Lumo","state":"determined","sentence":"Contracts with Proton AG (Switzerland), under a governing law that depends on where the customer is based and whether it is a business or a consumer.","qualifier":"Vannus has not established whether a US parent controls this entity, so US reach is not established either way. GLEIF records the entity's own reporting exception for its parent (NON_CONSOLIDATING, read [2026-09-12]).","contracting_entity":"Proton AG","jurisdiction":"Switzerland","governing_law":"Substantive laws of Switzerland for business users and non-US consumers; for US consumers, disputes go to arbitration under the Federal Arbitration Act with the law of the consumer's state of residence applying to state-law questions","conditions":["The agreement is under a governing law that depends on where the customer is based and whether it is a business or a consumer."],"us_control":{"status":"not_established","finding":"Not established — the vendor's own terms name no US contracting entity, and no source establishes its parent either way","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://proton.me/lumo/terms","document_title":"Lumo Terms of Service | Proton","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":["us_control"]}