## 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.** Kon 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. Kon 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 — Kon 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 Kon'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.