{"object":"determination","schema_version":"1","vendor":"Surfer SEO","state":"determined","sentence":"Contracts with Surfer sp. z o.o. (Poland), governed by Polish law.","qualifier":"Vannus has not established whether a US parent controls this entity, so US reach is not established either way.","contracting_entity":"Surfer sp. z o.o.","jurisdiction":"Poland","governing_law":"Polish law; court of competent jurisdiction at the Administrator's registered address (Poland)","conditions":[],"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://surferseo.com/legal/regulations/","document_title":"Positive Surfer - Legal | Regulations","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"]}