Accessibility Statement

3. Our Commitment

UPMOS Inc believes that digital accessibility is essential to providing an equitable experience for all users. We are committed to:

Our commitment extends beyond mere compliance — we believe that accessibility is a fundamental right and an essential part of providing an exceptional user experience. We invest in ongoing research, training, and technology to continuously improve accessibility across all of our digital touchpoints, including our website, mobile applications, email communications, and customer support channels across all regions.

• Designing with accessibility in mind from the start (Accessibility by Design)
• Maintaining and improving accessibility continuously
• Being transparent about our accessibility efforts and challenges
• Providing accessible alternatives and accommodations promptly
• Listening to user feedback and making improvements based on it
• Training our teams on accessibility best practices
• Complying with all applicable accessibility laws and regulations

4. Accessibility Standards

We continuously monitor and update our accessibility practices to align with evolving standards and regulatory requirements. Our development team receives regular training on accessible design and coding practices, and our quality assurance process includes dedicated accessibility checkpoints to prevent regressions.

We aim to comply with the following standards:

International Standards

• WCAG 2.2 Level AA – Web Content Accessibility Guidelines 2.2 (W3C Recommendation, October 5, 2023)
• WAI-ARIA 1.2 – Accessible Rich Internet Applications specification
• EN 301 549 v3.2.1 – European harmonised standard for ICT accessibility (incorporates WCAG 2.1 AA; updating to WCAG 2.2)
• ISO/IEC 30071-1:2019 – Code of practice for creating accessible ICT products and services
• PDF/UA-1 (ISO 14289-1) – Accessibility standard for PDF documents
• EN 17161:2019 – Design for All (European framework for inclusive design)

Standards Compliance Matrix

US Federal Accessibility Laws

• Americans with Disabilities Act (ADA) Title III (42 U.S.C. §§ 12181-12189) – prohibits discrimination by places of public accommodation, including commercial websites and mobile applications. The Department of Justice has interpreted Title III to cover websites under longstanding guidance and enforcement actions.
• ADA Title II Final Rule (DOJ, April 24, 2024; 88 FR 83504) – requires state and local government websites and mobile applications to conform to WCAG 2.1 Level AA (with compliance dates of April 24, 2026 for entities of 50,000+ population and April 26, 2027 for smaller entities and special-purpose districts). Upmos adopts WCAG 2.2 AA as its higher internal standard to remain forward-compatible.
• Section 504 of the Rehabilitation Act of 1973 (29 U.S.C. § 794) – prohibits disability discrimination by recipients of federal financial assistance.
• Section 508 of the Rehabilitation Act (29 U.S.C. § 794d) – requires federal agencies to make electronic and information technology accessible to people with disabilities. Upmos maintains Section 508 conformance to support federal procurement.
• 21st Century Communications and Video Accessibility Act (CVAA, P.L. 111-260) – FCC rules on accessible communications services, video programming captions, audio description, emergency information, and user interfaces.
• ADA Accessibility Guidelines (ADAAG) – U.S. Access Board technical guidance on the built and digital environment.

US State Accessibility Laws

• California Unruh Civil Rights Act (Cal. Civ. Code §§ 51-53) – prohibits business establishments from denying equal access based on disability; violations of the ADA are independently actionable under Unruh with statutory minimum damages of $4,000 per occurrence.
• Colorado HB21-1110 (C.R.S. § 24-85-103) – requires state agencies, political subdivisions, and public entity contractors to conform to accessibility standards no less stringent than WCAG 2.1 AA, with enforcement beginning July 1, 2024.
• New York State Human Rights Law (Exec. Law § 296) and NYC Human Rights Law (NYC Admin. Code § 8-107) – prohibit disability discrimination in public accommodations; actively enforced against inaccessible websites.
• Massachusetts Equal Rights Act (M.G.L. c. 93 § 102) and Chapter 272 § 98 – prohibit discrimination in places of public accommodation.
• Illinois Human Rights Act (775 ILCS 5/) and Illinois Website Accessibility Act (30 ILCS 587) – accessibility obligations for state agencies and public-facing entities.
• Texas Government Code Chapter 2054 Subchapter M and 1 TAC Chapter 206 – accessibility standards for Texas state agencies and procurement.

International Accessibility Laws

• European Accessibility Act (EAA, Directive (EU) 2019/882) – harmonized EU accessibility requirements for products and services sold in the EU, including e-commerce services, banking, e-books, transport ticketing, and consumer electronics. Enforcement date: June 28, 2025. Covers B2C e-commerce platforms regardless of where the service provider is established.
• EU Web Accessibility Directive (Directive (EU) 2016/2102) – requires public sector body websites and mobile apps to meet EN 301 549 (which incorporates WCAG 2.1 AA).
• Accessibility for Ontarians with Disabilities Act (AODA) – Integrated Accessibility Standards Regulation (IASR), O. Reg. 191/11 – requires large private-sector organizations to meet WCAG 2.0 AA.
• Accessible Canada Act (ACA, S.C. 2019, c. 10) – federal accessibility framework administered by Accessibility Standards Canada.
• UK Equality Act 2010 – prohibits discrimination by service providers, including digital services.
• UK Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018 – requires public-sector websites to meet WCAG 2.1 AA.
• RGAA 4.1 (Référentiel Général d’Amélioration de l’Accessibilité) – French national accessibility framework implementing the Web Accessibility Directive.
• BITV 2.0 (Barrierefreie-Informationstechnik-Verordnung) – German federal accessibility regulation.
• Irish Disability Act 2005 § 28 – requires Irish public bodies to provide accessible electronic content.
• Disability Discrimination Act 1992 (Cth) and Disability (Access to Premises – Buildings) Standards 2010 – Australian federal accessibility framework.
• Israeli Standard SI 5568 – Israeli accessibility standard based on WCAG 2.0 AA.
• Japan JIS X 8341-3:2016 – Japanese industrial standard for web accessibility.

Section 508 Compliance

UPMOS is committed to meeting Section 508 of the Rehabilitation Act, the US federal standard requiring electronic and information technology to be accessible to people with disabilities. Our platform is designed and tested to conform with Section 508 technical standards, ensuring federal employees and members of the public with disabilities have comparable access to information and services.

VPAT 2.5 Rev INT — Accessibility Conformance Report

UPMOS maintains a Voluntary Product Accessibility Template (VPAT® 2.5 Rev INT) documenting UPMOS conformance with the following technical standards:

• WCAG 2.2 Level AA (all four POUR principles, 50 success criteria)
• WCAG 2.1 Level AA (for jurisdictions that currently require 2.1 AA, including ADA Title II DOJ Final Rule)
• Revised Section 508 Standards (2017) — 36 CFR Part 1194 (ICT Accessibility)
• EN 301 549 v3.2.1 — European harmonised standard, including Annex A (mapping to EAA Directive 2019/882)

Audit Methodology

Our VPAT is prepared in good faith using a combination of internal review and, where engaged, independent accessibility professionals. Where independent auditors are used, Upmos seeks professionals with recognized accessibility credentials (for example, IAAP-affiliated Web Accessibility Specialist (WAS) or Certified Professional in Accessibility Core Competencies (CPACC)); the auditor’s name, firm, and credential status are disclosed in the signed VPAT itself. Typical audit activities include:

• Automated scanning (for example, with axe DevTools, WAVE, Pa11y, or Lighthouse) across representative pages and templates
• Manual keyboard-only traversal of critical user flows (homepage, product listing, product detail, cart, checkout, account, order-status, returns)
• Screen-reader testing with current versions of JAWS, NVDA, VoiceOver (macOS & iOS), and TalkBack (Android)
• Cognitive & low-vision testing (including 200% zoom, reflow at 320 CSS-pixel width, Windows High Contrast Mode, dark mode, and prefers-reduced-motion)
• Where practical, usability sessions with participants with disabilities recruited through an accessibility-testing panel or equivalent

The specific tools, assistive-technology versions, and auditor credentials used for each VPAT refresh are disclosed in the signed VPAT itself and may evolve over time.

Audit Cadence & Publication

Upmos aims to refresh its accessibility reviews on the target cadences below. Actual timing may vary based on scope, platform changes, and auditor availability; any material deviation from these targets is reflected in the current signed VPAT.

Requesting the VPAT / ACR

To request the most recent signed VPAT 2.5 Rev INT, the latest Accessibility Conformance Report (ACR), or an EAA conformity statement, email accessibility@upmos.com with the subject line “VPAT Request — [your organization].” Enterprise, federal, state, and higher-education procurement requests are prioritized. We aim to respond to complete requests within a reasonable window (typically 10–15 business days), subject to scope and to the latest audit status. Responses typically include:

• The most recent signed VPAT 2.5 Rev INT available at the time of request
• An executive summary of known gaps and general remediation approach
• Auditor information, where an independent third-party auditor was engaged (name, firm, and credential status as recorded in the VPAT)
• Applicable scope statement (URLs, app builds, or API endpoints covered)

Transparency note. Upmos is partially conformant with WCAG 2.2 AA. The signed VPAT is the authoritative record of per-criterion conformance as of its issue date; this public Statement is a good-faith summary and does not replace the VPAT or constitute a warranty of conformance.

Applicable Laws & International Standards

Upmos’s accessibility commitments are informed by the following frameworks. Mandatory legal obligations control over generic standards; where standards conflict, the higher accessibility level applies.

United States

• Americans with Disabilities Act (ADA) Title III — 42 U.S.C. § 12181 et seq.
• Section 504 of the Rehabilitation Act of 1973 — 29 U.S.C. § 794
• Section 508 of the Rehabilitation Act — 29 U.S.C. § 794d
• DOJ ADA Title III Regulations — 28 C.F.R. Part 36
• California Unruh Civil Rights Act — California Civil Code §§ 51 et seq.
• 21st Century Communications and Video Accessibility Act (CVAA) — 47 U.S.C. § 613

International

• UK Equality Act 2010
• European Accessibility Act — Directive (EU) 2019/882 (applicable June 28, 2025)
• EN 301 549 — European harmonized ICT accessibility standard
• AODA — Accessibility for Ontarians with Disabilities Act, 2005
• Accessible Canada Act, 2019
• Australian Disability Discrimination Act 1992

5. Accessibility Features

Keyboard Navigation

• All interactive elements are accessible via keyboard (Tab, Enter, Esc, Arrow keys)
• Focus indicators visible for keyboard navigation
• No keyboard traps
• Shortcuts listed via Keyboard Help (? key)

Screen Reader Support

• Semantic HTML structure for screen readers
• ARIA labels and landmarks for navigation
• Alternative text for images and graphics
• Form labels properly associated with inputs
• Tested with JAWS, NVDA, and VoiceOver

Visual Accessibility

• High contrast mode (WCAG AA compliant: 4.5:1 for text)
• Text can be resized up to 200% without loss of functionality
• Color is not the only means of conveying information
• Links are underlined or visually distinct
• No content flashing more than 3 times per second

Audio & Video

• Captions/subtitles for all video content
• Audio descriptions for video content
• Transcripts for podcasts and audio content
• Content warnings for potentially triggering material

Language & Content

• Plain language used throughout
• Headings used to structure content (not just for styling)
• Lists properly formatted
• Abbreviations defined on first use
• No reliance on color alone to convey meaning

6. Key Points

Here are the essential accessibility commitments and highlights of this statement:

7. WCAG 2.2 Level AA Compliance

Formal WCAG 2.2 Conformance Claim

UPMOS is actively working toward full conformance with the Web Content Accessibility Guidelines (WCAG) 2.2 at Level AA. WCAG 2.2, published as a W3C Recommendation on October 5, 2023, extends WCAG 2.1 with nine additional success criteria (six new Level A/AA criteria) targeting users with cognitive disabilities, motor impairments, and low vision. These guidelines define how to make web content more accessible to people with a wide range of disabilities including visual, auditory, physical, speech, cognitive, language, learning, and neurological disabilities. Our goal is to ensure that all four WCAG principles — Perceivable, Operable, Understandable, and Robust (POUR) — are met across every page of our website and mobile applications.

The Nine New WCAG 2.2 Success Criteria (Added October 2023)

WCAG 2.2 introduced nine new success criteria over WCAG 2.1, primarily targeting users with cognitive, motor, and low-vision disabilities. WCAG 2.2 also formally obsoleted SC 4.1.1 Parsing, which had been superseded by modern browsers’ error-recovery handling.

Upmos targets all six new Level A/AA criteria (2.4.11, 2.5.7, 2.5.8, 3.2.6, 3.3.7, 3.3.8) as part of its baseline conformance. The three AAA criteria (2.4.12, 2.4.13, 3.3.9) are pursued where feasible and tracked in our internal remediation register.

Compliance Summary by POUR Principle

Documented Exceptions Driving Partial Conformance

• Perceivable. Documented exceptions include SC 1.4.10 Reflow (third-party iframes — payment, live chat, cookie consent) and SC 1.4.11 Non-text Contrast (legacy PDF attachments and a small number of vendor-uploaded product images on which on-image text contrast is below threshold).
• Operable. Documented exceptions include SC 2.1.2 No Keyboard Trap and SC 2.4.11 Focus Not Obscured (Minimum) in certain third-party widgets, and SC 2.5.7 Dragging Movements on a small number of legacy product-customizer drag interactions (non-dragging alternatives are available via keyboard or a dedicated “Edit” button).
• Understandable. Documented exceptions include SC 3.3.7 Redundant Entry on a narrow checkout-error-recovery path where re-entry is currently required (remediation in active development) and SC 3.3.8 Accessible Authentication (Minimum) on a legacy CAPTCHA flow (replacement with WebAuthn / passkeys in progress).
• Robust. Documented exceptions include SC 4.1.3 Status Messages on the live-chat widget’s typing/connection-status indicators (vendor-controlled component) and SC 4.1.2 Name, Role, Value on a small number of legacy attached PDFs.

Specific per-page entries, screenshots, and remediation targets for each documented exception are maintained in our internal Known Issues Register and made available on request via accessibility@upmos.com.

New in WCAG 2.2 (Since WCAG 2.1)

WCAG 2.2 adds the following success criteria relative to WCAG 2.1. Upmos conforms to each Level A and AA addition below:

WCAG 2.2 also deprecates 4.1.1 Parsing (satisfied by HTML5 validity). See the WCAG 2.2 Quick Reference and the W3C’s “What’s New in WCAG 2.2” for authoritative details.

8. Keyboard Navigation

UPMOS is designed to be fully operable using only a keyboard, ensuring that users who cannot use a mouse or other pointing device can access all functionality. Our keyboard navigation implementation follows WCAG 2.2 Level AA Success Criteria 2.1.1 (Keyboard), 2.1.2 (No Keyboard Trap), 2.1.4 (Character Key Shortcuts), 2.4.3 (Focus Order), 2.4.7 (Focus Visible), 2.4.11 (Focus Not Obscured – Minimum), and 2.5.7 (Dragging Movements). All interactive elements including links, buttons, form controls, menus, and modal dialogs are reachable and operable via standard keyboard commands. Focus indicators are visible on all interactive elements, use a minimum 2 CSS-pixel outline with 3:1 contrast, and are never fully obscured by sticky headers or overlays. We regularly test keyboard navigation across all major browsers to ensure consistent behavior.

9. Screen Reader Support

Our website is tested and compatible with the following screen readers:

Our website is built with screen reader compatibility as a core design principle. We use semantic HTML5 elements, proper heading hierarchy, descriptive link text, and ARIA attributes throughout the site to ensure screen readers can accurately convey page structure and content. All images include meaningful alternative text, and decorative images are marked to be ignored by assistive technology. Form fields are properly labeled, and error messages are announced to screen reader users. We test regularly with the following screen readers to ensure compatibility:

10. Visual Accessibility

UPMOS is designed with visual accessibility at the forefront, ensuring that users with low vision, color blindness, or other visual impairments can comfortably browse and interact with our platform. We maintain minimum contrast ratios of 4.5:1 for normal text and 3:1 for large text and non-text UI components in accordance with WCAG 2.2 Level AA guidelines (SC 1.4.3, 1.4.11). All text can be resized up to 200% without loss of content or functionality, and our layouts support 320 CSS-pixel reflow without horizontal scrolling (SC 1.4.10).

High Contrast Mode

Enable high contrast in your browser or operating system. Our site automatically adapts to system color preferences.

Text Resizing

Resize text:

• Browser zoom: Ctrl/Cmd + Plus/Minus or Ctrl/Cmd + Scroll
• Browser settings: Font size preferences in accessibility settings
• Operating system: Magnification and zoom features

Color Contrast

All text meets WCAG AA standards (4.5:1 ratio for normal text, 3:1 for large text). Check your browser’s contrast with Color Contrast Checker.

11. Audio & Video Accessibility

UPMOS ensures that all audio and video content published on our platform meets accessibility requirements under WCAG 2.2 Level AA.

Media Track Standards Used

• Captions (synchronized). Delivered as WebVTT (.vtt) via HTML5 , aligning with WCAG 1.2.2 Captions (Pre-recorded, AA) and 1.2.4 Captions (Live, AA) where live captioning is technically feasible.
• Audio Descriptions. Delivered as a separate WebVTT description track via on visually essential content, aligning with WCAG 1.2.3 Audio Description or Media Alternative (Pre-recorded, A) and 1.2.5 Audio Description (Pre-recorded, AA).
• Transcripts. Published as plain semantic HTML linked from each media item; transcripts include speaker labels, non-speech audio cues, and time stamps. Aligns with WCAG 1.2.1 Audio-only and Video-only (Pre-recorded, A).
• Sign language tracks (WCAG 1.2.6, AAA) are pursued where feasible for high-impact educational and onboarding content.
• Player controls. All media players expose pause/stop/seek/volume via keyboard (WCAG 2.1.1 Keyboard, A) and announce state changes to assistive technology via ARIA live regions (WCAG 4.1.3 Status Messages, AA).
• No auto-play. Audio and video do not auto-play; user-initiated playback only (WCAG 1.4.2 Audio Control, A).

We provide synchronized captions for all pre-recorded video content and audio descriptions where visual information is essential to understanding. Live streams include real-time captions when technically feasible. All media players on our site support keyboard controls and are compatible with assistive technologies. Users can pause, stop, and adjust volume on all auto-playing media.

Video Captions

All videos include accurate captions for dialogue and important sounds.

Audio Descriptions

Video content includes descriptions of important visual elements.

Transcripts

Podcasts, webinars, and audio content have full transcripts available.

No Auto-Play

Audio and video do not auto-play; users initiate playback.

12. Mobile Accessibility

UPMOS is built with a mobile-first responsive design approach, ensuring that all content and functionality are accessible on smartphones and tablets. Our interface adapts to various screen sizes and orientations without loss of information or functionality. Touch targets meet the minimum recommended size of 44×44 CSS pixels for comfortable interaction. We support native mobile accessibility features including VoiceOver on iOS, TalkBack on Android, and platform-specific zoom and magnification settings. Pinch-to-zoom is not disabled, allowing users to enlarge content as needed. All gestures have keyboard-accessible alternatives.

Our mobile applications comply with:

• Apple Accessibility Guidelines (iOS)
• Android Accessibility (Android)

Features

• Proper touch target sizes (minimum 48×48 dp)
• Support for system zoom and text resizing
• Voice control support (Siri, Google Assistant)
• VoiceOver and TalkBack compatible

13. Testing and Evaluation

Our accessibility testing program combines automated scanning, manual evaluation, and real-user testing to ensure comprehensive coverage. We conduct accessibility audits at every stage of the development lifecycle, from design mockups through production deployment. Automated testing tools scan for common WCAG violations, while trained testers manually verify keyboard navigation, screen reader compatibility, and visual presentation. We also engage users with disabilities to participate in usability testing sessions, providing valuable real-world feedback that automated tools cannot capture.

We test across all major browsers including Google Chrome, Mozilla Firefox, Apple Safari, and Microsoft Edge on both desktop and mobile platforms. Our testing also covers assistive technologies such as NVDA, JAWS, VoiceOver, and TalkBack to verify screen reader compatibility.

UPMOS employs a comprehensive accessibility testing methodology combining automated scanning, manual review, and assistive technology testing to ensure our platform meets WCAG 2.2 Level AA standards.

Test results feed into our internal Known Issues tracking and the next VPAT refresh. We prioritize fixes based on the W3C WAI severity rubric (Critical > Serious > Moderate > Minor) and work to resolve higher-severity issues on a priority basis; specific remediation timelines vary based on scope, vendor dependencies, and engineering resources.

14. Known Accessibility Issues

We maintain transparency about known accessibility issues on our platform. Upmos keeps an internal issues register sourced from internal review, independent audits where engaged, automated scans, and user feedback. Each entry is categorized by affected area, the implicated WCAG 2.2 success criterion, and severity (using the W3C WAI severity rubric), along with an interim workaround where one exists and a remediation target.

The table below summarizes representative categories of issues currently tracked. Specific, up-to-date entries (including remediation targets and workarounds) are maintained internally and are available on request via accessibility@upmos.com. This section is illustrative and does not constitute an exhaustive list.

Severity key: Critical = blocks task completion for an entire disability cohort; Serious = significant barrier with no workaround; Moderate = barrier with a reasonable workaround; Minor = inconvenience that does not block completion.

For the current internal list of specific issues (including page-level detail, remediation targets, and status), please contact accessibility@upmos.com. We acknowledge user-reported issues per the response times in the Report Accessibility Issues section.

If you encounter an issue not covered above, please report it to us. Confirmed issues are added to the internal register and prioritized based on severity and user impact.

15. Report Accessibility Issues

We value your feedback and take all accessibility-related concerns seriously. If you experience difficulty accessing any part of our website, encounter a barrier, or have suggestions for improvement, please contact our accessibility team using any of the methods below. When reporting an issue, please include a description of the problem, the page URL, the browser and assistive technology you were using, and any steps to reproduce the issue. This information helps our team investigate and resolve problems more quickly.

Found an accessibility problem? We want to fix it.

Contact Accessibility Team

What to Include

• Specific page URL or feature
• Device/browser you’re using
• Describe the accessibility issue
• How you typically access content (keyboard, screen reader, magnifier, etc.)
• Your preferred contact method

16. Requested Accommodations

UPMOS is committed to providing reasonable accommodations to ensure that all users, including those with disabilities, can fully access and enjoy our products and services. If you encounter any accessibility barriers or require content in an alternative format such as large print, Braille, audio, or easy-read, we will make every reasonable effort to accommodate your request. Our accommodations process is handled on a case-by-case basis, and we aim to respond to requests promptly, typically within a few business days, subject to the complexity of the request.

Need a specific accommodation? We’re happy to help.

Common Accommodations

• Alternative formats (large print, Braille, audio)
• Extended time for completing forms or transactions
• Live person assistance for purchases
• Custom accessible version of a specific page
• Direct accessibility support

Request Accommodation

Email accessibility@upmos.com with details about what you need. We aim to respond within a few business days, depending on the request.

17. Resources & Tools

Accessibility Resources

The following external resources provide additional information about web accessibility standards, guidelines, and best practices. These resources are maintained by independent organizations and may be useful for users seeking to learn more about digital accessibility, assistive technologies, or their rights under accessibility legislation.

• W3C Web Accessibility Initiative (WAI)
• ADA Resources
• WebAIM (YouTube channel)
• NVDA Free Screen Reader

Assistive Technology

• Apple Accessibility
• Microsoft Accessibility
• Google Accessibility

18. AI & Automated Decision-Making Accessibility

UPMOS deploys artificial intelligence across product recommendations, search, customer-service chatbots, content moderation, generated product descriptions, and image alt-text. We are committed to ensuring these systems do not create new accessibility barriers. Our AI accessibility program is aligned with the EU AI Act (Regulation (EU) 2024/1689), Colorado AI Act (SB 24-205), California AB 2013 and AB 2655/AB 2839, Section 508 ICT Accessibility Standards, and the W3C’s AI & Accessibility Research Symposium findings.

AI-Generated Alt Text & Descriptions

• Human review required. AI-generated image descriptions (alt text, captions, audio descriptions) are subject to human review and correction before being served to assistive-technology users.
• Quality targets. Alt text is concise, contextual, and avoids generic phrases like “image” or “photo”. Decorative images use empty alt="".
• User correction. Users may flag inaccurate AI-generated alt text via the accessibility feedback channel; we aim to apply corrections promptly, typically within a few business days, based on scope.

AI Chatbots & Conversational Interfaces

• Our chat widget conforms to WCAG 2.2 Level AA, including keyboard operability, screen-reader announcements of new messages via aria-live="polite", focus management, and a minimum 24×24 CSS-pixel close-button target.
• Users may request escalation to a human agent at any point; we do not gate accessibility-related requests behind AI-only flows.
• AI responses are written in plain language (8th-grade reading level) per WCAG 3.1.5 (AAA, aspirational) and avoid idioms, metaphors, and unexplained jargon.

AI Bias & Disability Fairness

Recommendation, ranking, pricing, and content-moderation models are evaluated for disparate impact against users with disabilities, including differential pricing based on assistive-technology signals, over-moderation of content discussing disability, and accessibility-attribute gaps in search. Our fairness review uses protected-attribute testing consistent with the NIST AI Risk Management Framework (AI RMF 1.0) and the EEOC’s ADA & AI Guidance (May 2022).

Disclosure & Opt-Out

Where required by law, we disclose when content is AI-generated or when a decision affecting the user (such as credit, eligibility, fraud detection, or account suspension) involves automated decision-making. Users have the right to human review of such decisions under GDPR Article 22, CCPA/CPRA § 1798.185(a)(16) (automated decision-making regulations), and Colorado AI Act.

19. Procurement & Vendor Accessibility

UPMOS relies on third-party payment processors, shipping carriers, analytics, chat, and marketing tools. We extend our accessibility commitments into our supply chain and procurement process.

Vendor Accessibility Requirements

• Accessibility clause in contracts. All new vendor agreements for consumer-facing ICT require the vendor to conform to WCAG 2.2 Level AA, provide a current VPAT 2.5 Rev INT or equivalent Accessibility Conformance Report (ACR), and remediate critical barriers within agreed SLAs.
• Annual VPAT review. We request an updated VPAT/ACR from every ICT vendor annually and track material regressions.
• Section 508 flow-down. For products supporting federal procurement, we require vendors to meet the Section 508 Revised Standards (2017) and the harmonized technical standards in EN 301 549.
• EAA supply-chain compliance. Vendors providing services covered by the European Accessibility Act must demonstrate conformance to Annex I of Directive 2019/882 or equivalent harmonized standards.

Known Third-Party Limitations

Where third-party widgets, embeds, or iframes fall short of WCAG 2.2 AA, we (a) document the gap in our Known Issues register, (b) provide an accessible alternative path to the same functionality, and (c) escalate with the vendor until remediated. See Known Issues for the current list.

20. Accessibility Governance, Training & Remediation

Accessibility Coordinator — Named Contact

Upmos Inc. appoints a named Accessibility Coordinator responsible for overseeing compliance with this Statement, coordinating internal and independent third-party audits, maintaining the Known Issues Register, responding to escalations, ensuring reasonable-accommodation requests are honored, and reporting to executive leadership and the Board at least annually.

Response goals. The Accessibility Team aims to acknowledge inquiries within a few business days, to work toward a substantive response within approximately two weeks, and to escalate unresolved matters internally thereafter. Urgent barriers blocking a transaction are prioritized and, where feasible, resolved via the live-assistance pathway (phone and email). Actual response times may vary based on complexity, volume, and vendor dependencies.

Role-Based Training

• Designers & engineers complete annual WCAG 2.2 training, including cognitive accessibility, keyboard-first design, and screen-reader testing.
• Content authors complete training on alt text, heading structure, reading level, and accessible link text.
• Customer-support staff complete training on reasonable accommodations, alternative-format requests, TTY/TRS, and disability etiquette.
• Executive leadership receives an annual accessibility program report covering audit results, incident trends, and remediation status.

Accessibility-by-Design SDLC

Accessibility checkpoints are embedded in every phase of our Software Development Life Cycle:

1. Design review — accessibility annotations required on Figma/design files (color contrast, focus order, alt text, landmarks).
2. Pull-request gate — automated accessibility linting (axe-core, eslint-plugin-jsx-a11y) must pass before merge.
3. Pre-release QA — manual keyboard + screen-reader smoke test of every new feature flow.
4. Post-release monitoring — scheduled automated scans (axe, Lighthouse, Pa11y) and quarterly manual audits.
5. Incident response — user-reported barriers are triaged per the SLA in the Report Accessibility Issues section.

Continuous Improvement Priorities

The following are current priorities for our accessibility program. Timing and sequencing may evolve as audits complete, platform and vendor dependencies change, and new user feedback arrives.

• Near-term — Continue WCAG 2.2 AA gap-remediation across cart, checkout, and account flows based on audit findings and user reports.
• Ongoing — EAA-aligned review of e-commerce screens (Annex I, Section III) as scope expands in covered Member States.
• Periodic — Independent third-party accessibility review, with a preference for reviewers holding recognized accessibility credentials (e.g., IAAP-affiliated WAS or CPACC).
• Periodic — Native mobile app accessibility review aligned with EN 301 549 Chapter 11 for iOS and Android.
• Ongoing — Automated regression scans as part of the release process and periodic user-research sessions with participants with disabilities as scope warrants.

21. Languages, Translations & International Accessibility

Languages of Publication & On-Request Translation

Upmos serves customers across the United States, European Union, United Kingdom, Canada, and other international markets. We recognize that accessibility and disability-nondiscrimination law in many jurisdictions requires information to be available in languages the consumer actually understands — particularly under the European Accessibility Act (Directive 2019/882, Annex I, Section III), the French Loi Handicap / RGAA 4.1, the Canadian Official Languages Act (R.S.C. 1985, c. 31), and the AODA Integrated Accessibility Standards.

Language Coverage (Target)

The table below reflects our target language coverage. Actual availability for any given document or flow may vary; Upmos expands coverage progressively based on market demand, regulatory requirements, and translation-vendor capacity. For the most current availability, contact accessibility@upmos.com.

Translation Quality & Governance

• Human-reviewed translation for accessibility-related content where feasible — we aim not to rely on unreviewed machine translation for legal notices, complaint procedures, or accommodation rights.
• Plain-language review in each target language: content is edited for reading level, culturally appropriate phrasing, and disability-respectful terminology (e.g., personas con discapacidad / personnes en situation de handicap / Menschen mit Behinderungen).
• Screen-reader language tagging: translated sections use appropriate lang="xx" attributes so assistive technology can pronounce content correctly (WCAG 3.1.1 Language of Page, 3.1.2 Language of Parts).
• Easy-Read & Plain Language formats. A simplified-language version of this Statement can be provided on request for users with cognitive disabilities or low literacy, informed by WCAG 3.1.5 Reading Level (AAA) and the European Inclusion Europe Easy-to-Read Standards.
• Sign-language video. On reasonable request we will work to provide an ASL, BSL, LSF, DGS, or International Sign summary of this Statement or of a specific accommodation process, consistent with WCAG 1.2.6 Sign Language (AAA).
• Braille, large-print, and audio formats. UEB Grade 2 Braille, large-print (for example, 18-point or 24-point), and audio-recorded versions of this Statement can be provided on request at no cost; we aim to fulfill such requests within a reasonable time based on scope.

Governing-Language Clause

The English-language version of this Accessibility Statement is the controlling version for interpretation. In the event of a conflict between the English version and any translation, the English version governs, except where applicable consumer-protection or language law (e.g., Québec Bill 96, French Toubon Law, EAA Annex I § III) requires the local-language version to control — in which case the local-language version controls to the extent required by that law.

22. Complaint & Escalation Rights

If you are not satisfied with the response you receive from Upmos regarding an accessibility barrier, you have the right to file a complaint with a competent regulator. Nothing in this Statement or our Acceptable Use Policy limits the rights and remedies available to you under disability-discrimination or accessibility law.

How to Escalate Internally

1. First contact: accessibility@upmos.com (acknowledgment within 3 business days).
2. Second level: Accessibility Coordinator (escalation within 10 business days if unresolved).
3. Executive escalation: legal@upmos.com attn. General Counsel / Chief Legal Officer.

External Complaint Channels

This Statement does not waive, limit, or require arbitration of any claim under the ADA, Section 504, Section 508, CVAA, Unruh Act, EAA, AODA, UK Equality Act, Accessible Canada Act, or comparable civil-rights statutes.

Liability Cap (Aligned with Master Policies)

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, UPMOS’S AGGREGATE LIABILITY FOR ALL CLAIMS ARISING OUT OF OR RELATING TO THIS STATEMENT OR THE ACCESSIBILITY OF THE SERVICES SHALL NOT EXCEED THE GREATER OF (A) ONE HUNDRED U.S. DOLLARS ($100), OR (B) THE TOTAL AMOUNTS PAID BY YOU TO UPMOS INC. IN THE TWELVE (12) MONTHS PRECEDING THE EVENT GIVING RISE TO THE CLAIM. This cap aligns with the Terms of Use (§23), Acceptable Use Policy (§29), and Accessibility Compliance Policy (§13). NOTHING IN THIS CAP LIMITS LIABILITY FOR DAMAGES THAT CANNOT BE LIMITED UNDER APPLICABLE LAW, including the statutory minimum damages available under the California Unruh Civil Rights Act.

This Statement is governed by the laws of the State of Texas, without regard to its conflict-of-law provisions. Venue for non-arbitrable claims is the federal or state courts of Harris County, Texas. See Terms of Use §27 for the master governing-law and dispute-resolution framework.

23. Amendments

Changes to This Statement

We periodically update this Accessibility Statement. Material changes are communicated via email and website notice. This Statement is reviewed at least annually and whenever there is a material change to our services, accessibility testing results, or applicable law. Based on the date of this revision (May 20, 2026), the next scheduled review will be conducted on or before May 20, 2027.

For archived versions of this Statement, contact legal@upmos.com.