3.2 KiB
3.2 KiB
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.