<!-- Source: Lumotia Master Brief — §6 Legal & Compliance -->

## 6. Legal & Compliance

### Code signing (non-negotiable for distribution)
- **macOS:** Apple Developer Programme (£79/year) + notarisation mandatory. Unsigned apps trigger "damaged app" dialogue that most users cannot bypass.
- **Windows:** Extended Validation certificate (£240–£480/year) for immediate SmartScreen bypass. Unsigned executables trigger warnings that destroy conversion.
- **Linux:** Users more tolerant of unsigned software. Flathub + AppImage as primary formats.
- **Budget impact:** ~£320–£560/year minimum for macOS + Windows signing. Non-optional cost.

### GDPR position (local-only tier)
- **Jake is NOT a data processor.** Lumotia runs entirely on-device. No data is transmitted, stored, or visible to the developer. Same legal position as distributing a word processor.
- **Special category data:** Marketing targets neurodivergent users, but the app does not collect, store, or infer diagnosis information. Per ICO guidance, a "possible inference" is not special category data — only "reasonable certainty" triggers Article 9. Lumotia is on safe ground here.
- **Voice data:** Processed locally by Whisper. Never leaves the device. No third-party processor involved.

### GDPR position (cloud tier — when added)
- Jake becomes a data processor when voice data hits an external API.
- Requires: explicit consent before any audio is sent, data processing addendum, clarity on which AI provider and their retention policies.
- Do not add cloud features until revenue justifies compliance overhead.

### European Accessibility Act (EAA)
- Enforceable from 28 June 2025. Applies to consumer-facing digital products sold in the EU, including apps.
- Technical benchmark: EN 301 549 V3.2.1, incorporating WCAG 2.1 Level AA.
- Applies to non-EU companies selling to EU customers (similar extraterritorial reach to GDPR).
- Microenterprises (fewer than 10 employees, under €2M turnover) are currently exempt — Lumotia qualifies initially.
- **The UK has not adopted the EAA.** UK relies on the Equality Act 2010 ("reasonable adjustments") with no specific technical standards enforced.
- **Competitive opportunity:** Neither Tiimo nor Structured publishes a VPAT or formal accessibility conformance report. Publishing one first opens doors to government procurement, educational institutions, and enterprise contracts.
- Build to WCAG 2.2 AA from day one — this aligns with Lumotia's design philosophy and creates a genuine compliance moat.

### Required before paid launch
- [ ] Privacy policy (no data leaves device, no telemetry, no identifying analytics)
- [ ] Terms of service (licence terms, limitation of liability, AI accuracy disclaimer)
- [ ] Cookie policy (if landing page/website uses any tracking)

### Required before cloud tier launch
- [ ] Data processing addendum
- [ ] Explicit consent mechanism in-app
- [ ] DPIA (Data Protection Impact Assessment) — recommended given voice data + neurodivergent audience
- [ ] Review AI provider's data retention and training policies

### Business structure
- Personal project for now. No company entity required during beta.
- Roll into CORBEL Ltd if/when revenue becomes meaningful.
- Consult tax advisor at ~£500+/month revenue to determine optimal structure.
