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TacTile›Launch TacTile›Foundations›Legal & Compliance·33 in this wave

Approve: Legal & ComplianceTo do · blocker NEEDS MATTHEW: privacy-policy §6 publishes an admission against interestBlocked · blocker Verify support@tactile-connect.com delivers end-to-endTo do · blocker MATTHEW: eight legal documents marked DRAFT — NOT IN FORCE are published and now linked from marketingTo do · blocker Draft Terms of ServiceDone Draft Privacy PolicyTo do Draft Acceptable Use PolicyDone DMCA takedown policy + register agentTo do DSAR + account-deletion processTo do App Store privacy labels + Play Data SafetyTo do DECIDE: "no third-party data sales" pledge dropped from canonical S13To do Add IP-assignment and NDA agreements to S13's pre-launch checklistTo do Add product liability + workers' comp to S13's insurance planTo do Fix cap table misstatement: S13 says "no SAFEs" while one is actively being raisedTo do Decide: restore or drop the "no third-party data sales, ever" pledgeDone Resolve the data-retention contradiction between S13 and Pro analyticsDone Execute IP assignment and NDA agreementsTo do Appoint an Article 27 EU representativeTo do Execute SCCs with all seven sub-processorsTo do Publish the legal pack — /legal index + a page per documentDone Verify entity name "TacTile Connect, Inc." across docsTo do Write support policyDone Audit business plan Section 13 for policy driftTo do Confirm marketing claims match capabilitiesTo do Confirm co-founder equity resolution note and trademark class 45 in S13To do Draft Cookie PolicyDone Draft DPA templateTo do Sign DPAs with sub-processorsTo do Draft refund policyDone Write incident-response planDone Stand up compliance mailboxesDone Publish sub-processor list pageTo do Resolve retention conflict: S13's 90-day blanket vs indefinite Pro analytics retentionTo do

Wave

Legal & Compliance

v1.0 legal + compliance docs and processes — agent-drafted, Matthew signs off. Entity: TacTile Connect, Inc.

TacTile › Launch TacTile › Foundations › Legal & Compliance

10/33 done23 open4 open blockers

Selected taskclear

Appoint an Article 27 EU representative

To doOwner · met_b15be9a1

No dependencies in this wave — nothing gates it, and nothing waits on it.

Show the prompt

You are Viv, the agent for the TacTile lane of Command.

Open the lane and work there:

```bash
cd ~/Command/tactile && claude
```

Read that lane's CLAUDE.md and lane.json before you touch anything — they
carry your identity, your scope, and the hazards specific to this lane.
Read state from the hub (https://internal.tactile.to) or ask. Never guess at it.

## The task

**Appoint an Article 27 EU representative** · to do

Where it sits: TacTile › Launch TacTile › Foundations › Legal & Compliance

## The brief on file

DEFERRED to EU launch — v1.0 is US-only (Matthew, 2026-07-28). No longer a v1.0 blocker, and the blocker flag is cleared.

STILL TRUE AND STILL REQUIRED WHEN EU LAUNCH HAPPENS: TacTile Connect, Inc. is a US entity with no EU establishment, so offering the service to people in the EU triggers GDPR Art. 27 — a designated representative established in a member state, contactable by data subjects and supervisory authorities. The narrow Art. 27(2) exemption does not apply, since it requires processing to be occasional AND low-risk, and continuous scan analytics on identifiable visitors is neither. A separate UK representative is also required post-Brexit; the EU appointment does not cover it. Both are paid services costing a few hundred a year, not hires. Both must be named with contact details in the Privacy Policy.

DO NOT DELETE THIS TASK — pick it up when EU launch is scheduled. Grouped with: executing SCCs with sub-processors (t_792035cd), and enabling the EU branch of the App Store upgrade path, which carries Apple's EU business terms.

## How to work this

- Do the work, don't just plan it. If the fix is obvious and safe, make it.
- Surface anything needing Matthew's sign-off instead of deciding it yourself.
- Short replies. Lead with the answer, then stop.
- Finish by saying what changed, what you verified, and what you'd do next.

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Lanes

Legal & Compliance

Appoint an Article 27 EU representative