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Lumotia/docs/brief/legal-compliance.md
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feat(docs): add brief and brand reference docs to phase-2 branch
Co-Authored-By: Claude Opus 4.6 (1M context) <noreply@anthropic.com>
2026-04-21 16:03:49 +01:00

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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.