45 lines
3.2 KiB
Markdown
45 lines
3.2 KiB
Markdown
<!-- Source: Kon Master Brief — §6 Legal & Compliance -->
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## 6. Legal & Compliance
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### Code signing (non-negotiable for distribution)
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- **macOS:** Apple Developer Programme (£79/year) + notarisation mandatory. Unsigned apps trigger "damaged app" dialogue that most users cannot bypass.
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- **Windows:** Extended Validation certificate (£240–£480/year) for immediate SmartScreen bypass. Unsigned executables trigger warnings that destroy conversion.
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- **Linux:** Users more tolerant of unsigned software. Flathub + AppImage as primary formats.
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- **Budget impact:** ~£320–£560/year minimum for macOS + Windows signing. Non-optional cost.
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### GDPR position (local-only tier)
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- **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.
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- **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.
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- **Voice data:** Processed locally by Whisper. Never leaves the device. No third-party processor involved.
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### GDPR position (cloud tier — when added)
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- Jake becomes a data processor when voice data hits an external API.
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- Requires: explicit consent before any audio is sent, data processing addendum, clarity on which AI provider and their retention policies.
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- Do not add cloud features until revenue justifies compliance overhead.
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### European Accessibility Act (EAA)
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- Enforceable from 28 June 2025. Applies to consumer-facing digital products sold in the EU, including apps.
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- Technical benchmark: EN 301 549 V3.2.1, incorporating WCAG 2.1 Level AA.
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- Applies to non-EU companies selling to EU customers (similar extraterritorial reach to GDPR).
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- Microenterprises (fewer than 10 employees, under €2M turnover) are currently exempt — Kon qualifies initially.
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- **The UK has not adopted the EAA.** UK relies on the Equality Act 2010 ("reasonable adjustments") with no specific technical standards enforced.
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- **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.
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- Build to WCAG 2.2 AA from day one — this aligns with Kon's design philosophy and creates a genuine compliance moat.
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### Required before paid launch
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- [ ] Privacy policy (no data leaves device, no telemetry, no identifying analytics)
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- [ ] Terms of service (licence terms, limitation of liability, AI accuracy disclaimer)
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- [ ] Cookie policy (if landing page/website uses any tracking)
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### Required before cloud tier launch
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- [ ] Data processing addendum
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- [ ] Explicit consent mechanism in-app
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- [ ] DPIA (Data Protection Impact Assessment) — recommended given voice data + neurodivergent audience
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- [ ] Review AI provider's data retention and training policies
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### Business structure
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- Personal project for now. No company entity required during beta.
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- Roll into CORBEL Ltd if/when revenue becomes meaningful.
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- Consult tax advisor at ~£500+/month revenue to determine optimal structure.
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