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Hi Jamie, thanks for your comments, as we are only offering Payment HSMs as a service we do not hold or control any Data at all and therefor do not come under the control of jurisdiction. The payment HSM process is a challenge and response, where the HSM processes a command and returns a response. There is zero data held or stored and the communication is all over TLS. For my part, as with so many evolutions I firmly believe this will become the norm once people look at the solution in detail and accept that outside organisations can offer solutions that are at least as secure as inhouse offerings. I think the point you make is more around where the Payment Application sits  which is in the cloud and this could be a concern under.