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Matrix: Matter Omnigraphs
Context + trust infrastructure for deal-shaped lawyers
Real-time single-source-of-truth Matter Omnigraphs, ready to plug-and-play into Harvey, Legora, Claude or any other existing legal LLMs law firms already use. Category-defining deterministic state machine for every deal with built-in provenance, auditability and agent-ready permissioning for lawyers running cross-border transactions.
Purpose-built for $100m - $10bn+ dealsModel-agnostic context infrastructure layer
June 2026
1. The State Problem

You can't make lawyers run billion-pound deals within a chatbot.

Every legal AI on the market asks a probabilistic model to hold the state of a live matter — every term, threshold, election and side-letter concession in flux across months, with consequences cascading into years down the line. A context window is the wrong tool for holding state. State needs a substrate to live in; a context window isn't one. The three problems below are symptoms of asking a reasoning layer to behave like an authoritative matter record.

#1: Workflow Friction

Dig for the right document, attach it, prompt engineer, pray the context window holds, wait for a conversational answer, repackage that answer into something actually usable. That is not a sustainable workflow — it is a workaround in the absence of anything better.

Load, unload, repeat: the friction cycle means high licence counts, low daily use
#2: Lose-lose-lose

Posing deterministic questions to probabilistic models is senseless: you pay for tokens and wait for half-hours to play "Where's Waldo?". Even at 99.9% accuracy, if you don't know where the 0.1% is, all 100% must be checked. That is a fundamental limitation of vector indexing, especially when applied to large volumes of unstructured data.

Burn tokens, buy hallucination risk & unauditability in return
#3: Insufficient domain depth

By the time a probabilistic model finishes burning tokens on what should've been deterministic all along, it's run out of context window to do the real work that requires nuanced judgment. This is why practitioners know that currently available products cannot deliver redlines or insights to the level of a junior associate.

"Vertical" AI for lawyers has proven to be less vertical than advertised
Buy vs build... or a new third way: the "build-on"?

The jury is filing back into court and the verdict has been reached: Kirkland & Ellis is investing $500m into building custom tooling in-house. Freshfields is building directly with Anthropic. Although there are only a handful of firms globally that have the revenue to justify this spend, these market signals point strongly in the same direction: that currently available solutions are simply not deep enough into the vertical to create genuinely usable outputs for practice area specialists who do this work day in, day out. As the elite powerhouse firms with generous innovation budgets are racing to build from scratch and the mid-market firms feel forced to buy generic tooling dressed as "vertical" off-the-shelf, we've been quietly building a third way that serves both buyer personas.

2. The Category-Defining Solution

Introducing plug-and-play Matter Omnigraphs

and why it's a big deal for big deals.

Matrix gives the legal AI stack a live, permissioned matter-state layer. Firms keep the AI interfaces lawyers already use — Harvey, Legora, OpenAI, Claude and internal agents — while Matrix becomes the authoritative graph those tools call before they reason, draft, compare, escalate or act.

The Omnigraph resolves known facts deterministically, with source, permission, version and decision lineage attached. Only the remainder routes to the probabilistic model layer, bounded by current matter context instead of loose documents. MCP makes the connector lightweight; the product depth lives in deterministic state, permissioned retrieval and reusable matter context.

Knowledge graph + operational graph + permissions + provenance = model-agnostic trust substrate
QR code: scan to view live animation
View live on mobile

Scan to see the Omnigraph animation in your browser — best on desktop.

3. Product Arc: v1 to v3

Our v1 MCP server is just the wedge. Our v2 Deal Engine & v3 market benchmarking capabilities are the company.

We enter where firms already have approved AI interfaces. The same Matter Omnigraph architecture then compounds into workflow execution, and ultimately into firm memory no model or point solution can recreate.

Architectural throughlines
Single source of truth

Answers, workflows and firm memory all call on the same immutable record.

Built-in auditability

Source trails are attached from ingestion, not reconstructed later.

Strictly permissioned

Matter data stays sealed, region-hosted and scoped per user.

Agent harnessing

Retrieval becomes workflow execution, then institutional memory.

Cross-matter intelligence

The same schema unlocks client and practice-area insight.

Matter-graph architecture v1: MCP SERVER • WEDGE
Existing AI gets the matter graph: live state, permissions, provenance and graph-grounded answers.
v2: DEAL ENGINE • WORKFLOW UI
The same graph runs workflows: drafting, trackers, eSigning, agents and practice-specific deal engines.
v3: FIRM BRAIN • CROSS-PRACTICE AREA QUERYABLE INTRANET
Structured knowledge becomes searchable across matters, clients and practice areas.
4. The Competitive Landscape

Harvey and Legora unlocked the distribution for Matrix to ride on. We are the infrastructure layer they have to call into.

The legal AI budget has already been unlocked by horizontal reasoning platforms. That is not a threat to Matrix; it is the insertion point. As firms standardise on approved AI interfaces, agents need a deterministic context infrastructure layer underneath them: live matter state, permissions, provenance and auditability before they draft, compare, escalate or act.

Sprawling tools are symptoms
point tools • one task, one workaround
Contract review Chatbot Add-on Drafting Word plug-in Wrapper Legal research Summariser Due diligence Negotiation assistant Legal analytics eSignature DMS Document automation
collapse intoget absorbed
Matter Omnigraphs
Matrix isthe substrate

Every workaround on the left exists because no one owns matter state. Matrix is not another layer on the stack; it is the ground the stack stands on: auditable, permissioned, workflow-embedded, and purpose-built for transactional practice.

call intoquery, not replace
The platforms become our tenants
funded, horizontal reasoning layers
HarveyHorizontal LLM

Broad productivity and reasoning, sold practice-wide. Powerful distribution, but no record of what has actually been agreed in the matter.

LegoraTabular • Agentic

Agentic workflows surface complex relationships; they still need a liability-grade deterministic layer for agents to query.

Frontier modelsAnthropic • OpenAI

Reasoning keeps improving. Domain state does not appear by magic. Build the substrate yourself, or call Matrix.

MCP gives Matrix a lightweight insertion point. Distribution first, substrate ownership second, workflow expansion third.

5. Defensibility: the Moat

No amount of fine-tuning models can make up for lack of structured, deterministic, real-time deal context.

The wedge is intentionally thin: plug into Harvey, Legora, Claude, OpenAI and firm-built agents as the matter-state and provenance layer. The moat compounds as each deployment creates reusable transaction memory, workflow precedent and benchmark intelligence. MCP is the connector; the durable asset is the graph, audit trail, ontology and cross-matter memory.

Pillar #1

System of record adjacency

Matrix sits next to DMS, billing, email and deal-room systems, so it captures live matter state rather than static prompts or copied documents.

Pillar #2

Audit-grade provenance

Every answer can carry source, permission, version and decision lineage. That makes the layer useful for risk, privilege and client accountability.

Matrix

Trusted context layer

One firm-controlled layer normalises the messy context that models need: who can see what, what changed, which precedent matters, and where the deal actually stands.

Knowledge graph

entities, documents, clauses, people and obligations linked to each matter.

Operational graph

tasks, approvals, status, deadlines and handoffs captured as work happens.

Trust graph

permissions, provenance, audit trails and client-specific guardrails enforced before retrieval.

Compounding flywheel
Matters land>Memory improves>Benchmarks compound
Pillar #3

Workflow precedent

Each transaction teaches playbooks, approval paths and exception patterns. The product gets better at how the firm actually executes.

Pillar #4

Model-agnostic distribution

MCP makes Matrix callable from the tools firms already adopt. When models churn, the context, ontology and trust layer stay.

Proof object: distribution-first trust infrastructure. The connector gets us called; each deployment leaves behind transaction memory, permission logic and benchmarkable matter intelligence.

Knowledge graph + operational graph + permissions + provenance
Compounding flywheel: matters land, memory improves, benchmarks compound Each matter graph becomes reusable precedent, approval logic and benchmark intelligence that no one reasoning layer — Harvey, Legora, Claude, OpenAI or an in-house agent — can recreate alone . Switching costs compound 1,000 matters become 1,000 omnigraphs feeding the firm's precedent library. Migrating off isn't exporting files — it's walking away from years of institutional knowledge that now lives inside the substrate and nowhere else . Audit-grade provenance Every answer can carry source, permission, version and decision lineage. That makes the layer useful for privilege, client accountability and risk review. Matrix has nothing to reconstruct append-only and permissioned , the Matter Omnigraph is the audit trail: every fact permanent and sourced from the moment it is confirmed. Model-agnostic distribution via approved AI tools MCP makes Matrix callable from the tools firms already adopt. When models churn, the context, ontology and trust layer stay. The front door can change; the matter record remains . That is how Matrix lands thin, then expands upward into UI, workflow and bounded agents. System-of-record adjacency Matrix sits next to DMS, billing, email and deal-room systems, so it captures live matter state rather than static prompts, copied documents or stale exports. It becomes the firm-controlled layer normalising what models need to know: who can see what, what changed, which precedent matters and where the deal stands . Trust graph Permissions, provenance, audit trails and client-specific guardrails are enforced before retrieval , not repaired after model output. Workflow precedent Each transaction teaches playbooks, approval paths and exception patterns. The product learns how the firm actually executes complex deals . Inner ring DAY-ONE CORE   •  t = 0 Outer ring COMPOUNDING MOAT   •  t → ∞
6. Defensibility: Will They, Won't They?

No, they won't: why we're the only one with the full hand.

Ontology
Architecture
Cross-firm intelligence
Incentive
Why they won't
Powerhouse firms,
building in-house
Only a handful (the highest-grossing firms globally): Kirkland • Freshfields
Deeply domain-expert lawyers
Budget + talent to build
Data never leaves firm's walls
Off-mission; billers off deals
=It's off-mission.
Powerhouse firms can build internal systems, but they cannot create a cross-market context layer. Data stays inside the firm's walls, and fee earners get dragged off live matters to define infrastructure instead of doing deals. Matrix gives every other firm a foundation to build on.
LLM wrappers,
fine-tuned for lawyers
Harvey • Legora
Legal-general, not transactional-deep
Retrofit data lakes into schema?
Unstructured + siloed volume
Off-thesis to rebuild from first principles
=It's off-thesis.
Their forward story is agents and reasoning, not rebuilding deterministic foundations underneath every live matter. "We already have Harvey" is reason to deploy Matrix, yesterday: the reasoning layer needs an authoritative matter-state layer to call.
Frontier modelsAnthropic / Claude for Legal • OpenAI
"Legal" as monolith is the vertical
Retrofit data lakes into schema?
Unstructured + siloed volume
Diametrically antithetical
=It's orthogonal.
Frontier models make reasoning cheaper and more capable. They do not create live matter state, permission lineage or practice-area ontology by magic. Build the substrate yourself, or call Matrix.
MatrixGraph-native • transactional-specialist
=We will — and we're all in.
The only player whose entire business is the trust layer itself — and the parallel bet alongside whatever a firm has already bought.
~$5bn TAM • ALL FIRMS • ALL TRANSACTIONAL PAs 3 revenue streams (see next slide): • Core ~$3.4bn — ≈1% of the $336bn fee pool • Multi-party fan-out • Market Intelligence ~$1.3bn SAM • YOUR FIRMS 3 streams • core ~$0.9bn (≈1% of the $90bn fee pool) ~$800m SOM • 3-PA BEACHHEAD 3 streams • core ~$0.56bn (≈1% of the $56bn fee pool) ~$3–7bn INTELLIGENCE LAYER • A 2ND MARKET 5–10% MULTI-PARTY FAN-OUT • LPs + COUNSEL LAUNCH — YEAR 1 ADJACENT EXPANSION • ROADMAP FUND FORMATION LPAs • side letters • MFN FINANCE Leveraged + fund finance CORPORATE M&A Private + public deals REAL ESTATE Acquisition + finance CAPITAL MARKETS ECM • DCM • securitisation PROJECT FINANCE Infra • energy RESTRUCTURING Multi-creditor
7. TAM • SAM • SOM + Roadmap

We're not in the AI race. We're the toll on the road
charging almost nothing, on everything.

≈1% of the firm's fee per mandate, across three revenue streams — a ~$5bn TAM. £3.2m today → £54m by Y3, ~9% of the $800m beachhead.
Y1 lights a thin first layer; the headroom is the adjacent practices ($1.3bn SAM) and the full firm universe ($5bn TAM).
Legal services $1.05tn × transactional ~31% ≈ $336bn (Grand View / Mordor / GM Insights 2025–26); legal analytics ~$3.15–7.7bn (Mordor / ResearchNester). Take rate derived from price card; expansion shown as upside, held at zero in base case.
CORE • law firms

Value-based (per-matter) pricing, not per-seat. Blended ~1% take-rate on every mandate onboarded onto Matrix.

£47.7m Y3
FAN-OUT • counterparties

Cross-sell to the counterparty universe within each multilateral practice area.
High fan-out potential: fund formation (many LPs), project finance (sponsor + lender syndicate + ECAs + gov + contractors), restructuring (multi-creditor), syndicated/LevFin.
Medium: capital markets, real-estate JVs.
Low: bilateral M&A and real estate.

£4.1m Y3
MARKET INTELLIGENCE LAYER • principal & intermediary universe

Market intelligence & benchmarking as a standalone offering • blended ~£50k per subscription. LPs, GPs, banks & corporates already spending on PitchBook, Preqin and Bloomberg terminals.

£2.0m Y3
8. Business model & financial projection

Every practice area unlocks three revenue streams.

Pricing — value-based, capped at willingness-to-pay (WTP) ceiling
Per matter, not per seat
Small£5k
Medium£10k
Large£20k
XL£25k
Mature ACV cap • per firm
Boutique£250k/yr
Mid-market£700k/yr
Elite£2m/yr
≈1% of the firm’s fee — the WTP ceiling
Plus a one-off setup fee to cover ingestion and onboarding costs — excluded from ARR above
ARR trajectory (conservative base) • £m
£3.2m Y1 £18.9m Y2 £53.8m Y3
Core
Multi-party fan-out
MI layer
Growth = depth × breadth
25% 60% 85% 12 28 55 DEPTH • PENETRATION BREADTH • FIRMS Y1 Y2 Y3
Bubble = ARR (£3.2m → £54m). Both levers compound — growth is back-loaded.
9. Why Now?

As the substrate, every current market force becomes a tailwind for us.

Build the substrate, and it doesn't just collapse the point-solution sprawl — it throws off value the sprawl never could. The same Omnigraph that wins the core deal spins off four more, each pulled into existence by a market force already in motion.

Force #1: Agentic in legal is < 18 months out

Harvey shipped agents March 2026; Legora is leaning heavily on their "aOS". Agents need a deterministic layer to query — or they're just ticking liability time-bombs.

"Vertical within a vertical"-level harnesses to constrain agentic workflows

Firms get agent-ready infrastructure as a byproduct of the core product — and every agent vendor becomes a tenant of the graph, not a rival to it. MCP makes that context layer callable from the AI front doors firms already bought.

Force #2: The market has never been more willing to pay, but also never more fatigued from endless LLM-on-LLM patch solutions

Legal-AI spend is compounding ~28% a year — but it's scattered across ten overlapping point tools that don't hold. Buyers are done paying for patches; they want one thing that works, and rightly so.

Omnigraphs are accidentally the all-in-one solution

GitHub for lawyers, matter tracker, AI-assisted predictive drafting, agentic onward actions, market-wide Thomson Reuters fine-grained for each practice area, firm-wide negotiation analytics, or precedent library... we happen to be all of the above. We bank the budget firms were fragmenting across patches — the good reasoning tools still plug in; narrow patches and point-solutions won't survive the consolidation.

Force #3: The regulators are watching — like a hawk

The SRA already holds 200,000 E&W solicitors to a duty of competence, and "the model hallucinated and we don't know how" is no defence to a negligence claim or referral. The EU AI Act adds pressure (fines to €15M / 3%) — though its high-risk obligations, proposed for 2 Aug 2026, may slip to Dec 2027 and aren't settled.

Auditability as a by-product of the architecture right from ingestion, not reconstructed post-hoc by some skill or plugin

Append-only and immutable, the Omnigraph is the audit trail: every fact permanent and sourced the moment it's ingested and confirmed. The sooner a firm adopts, the longer the period covered by the auditable trail. Nothing to rebuild, no plugin burning tokens poring over reams of conversation history to certify itself five years later.

Force #4: Clients have been forcing firms off the billable hour for years

Under the billable hour, working faster just means billing lessefficiency is a pay cut. Announcing its $500m in-house platform, Kirkland's chair framed it as a shift off the billable hour toward value-based pricing — the top-grossing firm making our case.

40-60% margin escape

Matrix is projected to compress time-per-matter 40-60%; firms bank it as margin instead of writing it off. Labour arbitrage becomes software economics.

10. Founding Team

3 qualified lawyers and an ontology-obsessed engineer between 2 repeat co-founders: Matrix was always going to exist, it just needed the right team.

Two BAME, female, socially mobile lawyers. One bedroom startup founded 7 years ago that became the multi-award-winning social mobility charity, STRIVE Talent. Now building the intelligence layer that transactional lawyers have needed for decades. Between them: the transactional legal experience and the technical vision to build what nobody else has thought to build in quite this way.

Sana Shafi
Sana Shafi
CEO • Practising Funds Lawyer (4 PQE, ex-Kirkland)

Six years in practice at top fund practices in the City; formation of funds with AUM in the billions is her bread and butter. She has done, manually, everything Matrix is built to replace. Sana does not have a theory about how transactional lawyers work: she is one. She has sat in every closing, negotiated every side letter, and managed every MFN process that Matrix handles. When she says the current workflow is broken, she means she lived it — just last Thursday. She is the domain expert on call who shapes design and schema decisions, tightening the feedback loop from months to minutes.

Bertilla Chow
Bertilla Chow
Chief Product & Technical Officer • Solicitor & Barrister turned Software Engineer

Chancery-trained barrister. Silver-circle trained solicitor. 42-trained software engineer with systems/architecture depth and product/design instinct. She has acted for Deutsche Bank, Goldman Sachs and Barclays on transactions up to £350M, then as Chief of Staff at a fast-scaling professional services firm drove 40% revenue growth while digitising its entire client base. Her capability as a high-resolution translator between Sana's domain expertise and her varied skills stack means we can execute at breakneck velocity, with crystal clarity of vision, and stay leaner for longer.

11. The Ask
£1.5 million
Pre-seed • Targeting round close end of Q3 2026

~18-month runway — we raise the seed at ~M12 from a position of strength, not necessity. Cash covers the full plan; the raise is a choice, with ~6 months of cushion behind it.

Product & Engineering ~46% • £690K

Graph schema, MCP connectors and UI across the 3 launch practice areas. Lead Engineer (secured) plus additional engineering, working alongside fund finance, LevFin and M&A domain experts. Cloud, Neo4j and LLM inference. MVP → v2.0.

Operations & Runway ~26% • £390K

The infosec stack institutional firms must see before they sign — SOC2 Type I → II, ISO 27001. Professional indemnity & cyber insurance, legal, finance, and contingency.Salaries sit within the functions above — this line is pure overhead.

Go-to-Market & First Clients ~28% • £420K

GTM Lead hire plus the founder-led partner motion. Design partners converted to 12 paying anchor firms. Conference circuit and category-creation thought leadership.

A B C

Appendices

AThe next 18 months: projected milestones
BCompetitive landscape: Harvey vs Legora vs Matrix
CInformation security, compliance & data residency
Appendix A: The Road to Seed — Projected Milestones

v1 (MCP server) proves the context layer as infrastructure. v2 (Deal Engine) is the UI layer on top: end-to-end OS built for all transactional workflows.

Built with design partners and live pilots from month one — not in isolation. Product, GTM, team and infosec run in parallel to first revenue, 12 anchor customers, £3.2m ARR and SOC2 Type II. The pre-seed funds the full 18-month plan; we open the Series Seed at ~M12, from a de-risked position.

M1
M2
M3
M4
M5
M6
M7
M8
M9
M10
M11
M12
M13
M14
M15
M16
M17
M18
Pre-seed
runway
£1.5M funds the full 18-month planCommence seed round fundraising ~M12 • ~6 mo cushion
PRODUCT*
Core context-layer MVP build
Finalise architecture + MCP connectors
Ship MVP
v2.0 build & iteration
GTM
Feedback loops with design partners to co-build schema, connectors & UI
Secure 12 anchor customers across 3 practice areas at launch
Pilot deployments
Convert pilots → first paying contracts
Progression towards £3.2m Y1 ARR
TEAM
Lead Engineer (secured)
GTM Lead
Domain Experts (Fund Finance, LevFin, M&A)
INFOSEC
Vanta go-live
Cyber Essentials certified
SOC2 Type I certified
ISO 27001 certified
SOC2 Type II certified

*Parallel across all three practices targeted for launch: fund formation, finance (fund finance and LevFin), and M&A. • Design partners and pilots run from M1 — the raise funds product, commercial motion and infosec in parallel, not a build in isolation.

Appendix B: Competitive Landscape

"How do you compete with Harvey/Legora?"

We don't — they're competing with each other. We're the trusted matter-state layer their agents eventually need to call into.

Harvey1
Horizontal LLM • Founded 2022 • $11B valuation
ARR $190m
Customers
1,000+ law firms

~50 AmLaw 100 + 400+ mid-sized + ~550 smaller/regional

Plus ~500+ in-house corporate teams — separate count

Buyer Innovation team
Wedge

Firm-wide productivity layer. Sold per seat across every practice — contract review, drafting, research, due diligence.

Legora2
Horizontal + differentiating through tabular and agentic focus • Launched 2024 • $5.55B valuation
ARR $100m+2
Customers
1,000+ firms + in-house

50 markets • firm/in-house mix not publicly broken out

Named BigLaw: White & Case, Linklaters, Cleary, Goodwin

Buyer Innovation team
Wedge

Agentic workflows on top of foundation models. Per-seat. Wide coverage of legal tasks, shallow per workflow.

Matrix
Graph-native, domain-specialist, MCP-callable trust infrastructure for transactional practice areas
ARR £53.8m Y3 · base case
Customers
70 enterprise firms Y3 target

Enterprise tier • top 100 by revenue + Magic Circle

+ boutique + regional firms with transactional deal flow

Buyer Transactional partners
Wedge

Workflow-critical depth inside specific transactional practices. Per-matter, value-based pricing — tiered by deal size, ACV-capped per firm — sold into the transactional practice group, not the firm-wide AI budget. Adopted alongside Harvey/Legora, not instead.

SAM

The universe of target commercial law firms — top 100 firms by revenue globally — totals roughly ~120 firms. Harvey and Legora's 1,000+ counts inflate via mid-sized firms (Harvey: 400+) and in-house teams; their actual enterprise base sits closer to 50–100 firms each. Matrix's Y3 target of rollout across 70 client firms is a meaningful share representing the transactional-heavy segment of this finite, well-defined market — plus selective boutique + regional firms with transactional deal flow, counted on a separate line and additive to the 70.

Counting methodology not publicly disclosed. Working assumption: at BigLaw firms, office budgets are set locally, not centrally — even when enterprise licensing is centralised firm-wide. The 1,000+ headline likely registers each office as a separate customer; one firm with offices in London, New York and Singapore reads as three. The most plausible reconciliation against a finite global BigLaw universe.

1Harvey, "Helping Law Firms and Companies Collaborate at Scale," 13 Mar 2026; Harvey, "How Harvey Helps Mid-Sized Law Firms Scale Legal Work," 24 Oct 2025; CNBC, 25 Mar 2026 ($190m ARR, $11B valuation).

2Legora's $100m+ ARR is self-reported (Legora, "…propels Legora past $100M in ARR," 2 Apr 2026); independent reporting put ARR at ~$23m as of Sept 2025 — the basis of the ~240× multiple on the $5.55B Series D (TechFundingNews). Harvey figures are externally corroborated (CNBC).

Appendix C: InfoSec, compliance & data residency

Information security, compliance & data residency

Isolation enforced at the architecture layer — not just the UI — with role-based access and EU / UK / US data residency. Here is an example diagram of how InfoSec would look for fund formation, but the same principles apply across Finance and M&A.

Investor-level data isolation architecture: Investor 1/2/3 inputs flow through permissioned locks down to Fund counsel, Market intelligence and Fund ops layers.
Investor-level data isolation

Each investor's side-letter terms, negotiation history and concessions are stored in discrete, permissioned nodes. No investor can query, view, or infer another's position. Confidentiality is enforced at the architecture layer, not just the UI.

Role-based access control

Every user operates within a defined permission tier — Fund Counsel (full fund view), Fund Ops (operational data only), Investor Counterparty (own data only). Queries requiring graph traversals beyond each user's permissions will be denied. Access is logged, timestamped and auditable.

Data residency

Matrix's cloud infrastructure is deployable with EU-based data centres (AWS Frankfurt / Dublin or Azure Netherlands / Ireland) for GDPR-bound funds, UK regions for post-Brexit clients, and US-East / US-West for US clients. Region selection is configured at onboarding and documented in the Data Processing Agreement.

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