Notion
Verified“US company through and through, with a European sales coat.”
- Listing
- Private
- Users
- 100M+
- Revenue
- $500M+ ARR
- Employees
- ~800
19 = midpoint of Control 15 & Data 22
Sovereignty Quadrant
Control ↑ who owns & governs the company · Data → where your data lives. Every dot is a company — click to open it.
Every number below traces to 14 sourced facts across 11 independent sources, last verified 2026-06-12. 3 open questions hold confidence at 82% — they lower confidence, never the score.
Control ↑
Who legally and economically controls the company
Legal & Jurisdiction
18
Incorporated in Delaware and run from San Francisco; the named data controller is the US parent. A Dublin EMEA sub exists but is operational, not the controlling entity, and transfers rely on SCCs + the EU-US Data Privacy Framework — classic incorporated-and-run-outside-the-EU.
Why 18? 4 sourced facts · click to expand
Notion Labs, Inc. is incorporated in Delaware, per its SEC Form D filing (CIK 1781814).
SEC EDGAR — Notion Labs Form D index · as of 2020-04-13
Notion's Privacy Policy names Notion Labs, Inc. at 685 Market St, San Francisco as the controller.
Notion Privacy Policy · as of 2026-06-12
Notion relies on Standard Contractual Clauses (and the EU-US Data Privacy Framework) to transfer EU personal data outside the EU.
Notion Help — GDPR at Notion · as of 2026-06-12
Notion's EMEA legal/operations base is Dublin, Ireland, but it functions as a regional HQ, not the data controller.
IDA Ireland press release · as of 2021
Control & Ownership
12
Privately held and controlled outside the EU: a US-based founder-CEO holds the largest stake, with US VCs and Singapore's GIC as major backers and no EU voting or economic majority.
Why 12? 3 sourced facts · click to expand
Co-founder and CEO Ivan Zhao is the largest individual shareholder, estimated around 30%, and is US-based.
RevenueMemo — Who owns Notion · as of 2026
Lead investors are US firms Coatue, Sequoia Capital and Index Ventures; Singapore's GIC joined in 2026.
Notion blog — Sequoia/Index share purchase · as of 2024
Notion is privately held (no public listing); a 2026 tender valued it near $11B.
The Information · as of 2025-12-15
Data →
Where your data lives and who can reach it
Data & Infrastructure
22
All data runs on AWS, a US hyperscaler. EU data residency exists (Frankfurt, Ireland backup) but is Enterprise-only and at-rest-only, and account/billing/analytics/Calendar/Mail stay in the US — EU-region-on-US-cloud territory with default US storage.
Why 22? 4 sourced facts · click to expand
Notion is hosted by AWS and offers EU data residency in AWS Frankfurt (eu-central-1) with Ireland as backup.
Notion Help — Data residency · as of 2026-06-12
EU data residency is limited to Enterprise plan customers and applies only to data at rest.
Notion Help — Data residency · as of 2026-06-12
Even with EU residency, user accounts, workspace billing, usage/analytics, and Notion Calendar and Mail are stored outside the EU region (US).
Notion Help — Data residency · as of 2026-06-12
Subprocessor and LLM processing may occur outside the chosen region; running on US-owned AWS carries CLOUD Act exposure.
Notion Help — Data residency · as of 2026-06-12
Operations & People
23
HQ, CEO and primary leadership are US-based and reporting is in USD, but Notion has a real and growing European footprint: a 100+ person Dublin EMEA HQ, an EMEA GM, and new London, Paris and Munich hubs.
Why 23? 3 sourced facts · click to expand
Notion is headquartered in San Francisco with US-based founder-CEO Ivan Zhao.
Notion — About · as of 2026-06-12
Notion's Dublin EMEA HQ has grown past 100 people, with new offices opening in London, Paris and Munich.
businesscloud.co.uk · as of 2025-09-02
Notion employs roughly 800 people globally and serves 100M+ users with $500M+ in annualized revenue.
super.so — Notion stats · as of 2026
Aligned to the EU Commission’s official Cloud Sovereignty Framework (SEAL, Jun 2026) →
What we don’t know
3 open questions — they lower confidence, never the score
- ?
What is the exact cap-table split between US, European and other investors, and does any EU holder have meaningful voting rights?
Could nudge the ownership score, though a US founder-CEO majority plus US-VC and GIC backing makes EU control very unlikely.
- ?
How many EU Enterprise customers have actually enabled EU (Frankfurt) data residency versus defaulting to US storage?
Affects how much real EU data localization exists in practice; the default and the consumer/free/Plus tiers remain US-hosted regardless.
- ?
Does Notion maintain a formal Article 27 EU representative, and is the Dublin entity the GDPR establishment for EU users?
Bears on EU legal enforceability; the public privacy policy names only the US entity as controller.
EU Cloud Sovereignty Framework lens
The EU Cloud Sovereignty Framework (SEAL) is designed to assess cloud service providers; applying it to a SaaS app like Notion is an analogous mapping for comparison, not a certification.
Strategic
US-controlled, VC-backed productivity SaaS with no EU strategic anchor; European presence is a growth market, not a control center.
Legal & jurisdictional
Delaware-incorporated, US controller; EU data transfers rely on SCCs and the EU-US Data Privacy Framework, leaving exposure to US legal process.
Data & AI
Optional EU (Frankfurt) data-at-rest residency for Enterprise, but accounts/billing/analytics and LLM/subprocessor processing can still leave the region.
Operational
Genuine Dublin EMEA HQ (100+ staff) plus new London/Paris/Munich hubs, but global operations and decisions sit in San Francisco.
Supply chain
Core dependency on US hyperscaler AWS and US-based subprocessors/LLM providers; no EU-sovereign infrastructure option.
Technological
Proprietary US-built platform running entirely on AWS; no EU-owned or open-sovereign tech stack.
Security & compliance
Holds SOC 2 Type II, ISO 27001 and ISO 27701, and offers GDPR DPAs — strong assurance, but US-jurisdiction-bound.
Environmental sustainability
No Notion-specific EU sustainability disclosures found; inherits AWS regional energy profiles.
EU alternatives
German open-source collaboration/docs suite, self-hostable on EU infrastructure; the strongest sovereignty answer to Notion-style workspaces.
Privacy-first, local-first Notion-like app with EU roots and end-to-end encryption; smaller ecosystem and still maturing for enterprise.
Closest feature peer to Notion but also US-incorporated and cloud-hosted — listed for comparison, not as a sovereignty upgrade.
How the method works
Methodology v2 (provisional): the score is the midpoint of two axes — Control (who owns and governs the company) and Data (where your data lives and who can reach it). Each axis is scored only on verified evidence; unknowns reduce confidence, never the score. Every input below is sourced; the weights and judgments are open to challenge.
Spotted an error? Every claim is sourced — challenge it and we correct the record.
- 2026-06-12 — Initial golden profile, authored from primary sources (human + AI review).
Report Incorrect Data
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Verified 2026-06-12 · Human + AI joint review (sources independently checked) · Methodology