Privacy Policy — Witram LëtzDrill
This policy explains what personal data the Witram LëtzDrill app ("the app") collects, why, where it is stored, how long we keep it, and what rights you have. We have tried to keep it short and plain.
1. Who we are
The controller of your personal data is Witram Tech S.à r.l.-S, a simplified limited liability company under Luxembourg law (in formation).
- Registered address: [REGISTERED ADDRESS, LUXEMBOURG]
- RCS Luxembourg: [RCS NUMBER]
- VAT: [VAT NUMBER]
- Privacy contact: privacy@witram.lu
- General support: support@witram.lu
- Data protection officer: [DPO CONTACT — or state that no DPO is appointed]
2. Scope
This policy covers the Witram LëtzDrill app for iPhone and iPad (iOS 17 or later) and the servers that support it. The app helps you learn Luxembourgish and prepare for the Sproochentest. It is independent and is not affiliated with or endorsed by the INLL, MENJE, the Zenter fir d'Lëtzebuerger Sprooch (ZLS), France Éducation international or the Goethe-Institut.
3. Age requirement
The app is only for people aged 18 or over. During onboarding you confirm that you are 18+, and we record the time of that confirmation. We do not knowingly create accounts for minors. If we learn that an account belongs to someone under 18, we will delete it.
4. What data we collect
4.1 Account data
- A user ID (uid) created by Google Firebase Authentication
- Your email address
- The sign-in method you chose: Sign in with Apple, Google sign-in, or email and password (passwords are handled by Firebase Authentication; we never see them in plain text). If you use "Hide My Email" with Apple, we receive only the relay address.
4.2 Profile data
- Learning goal, optional exam date, self-assessed level
- App interface language and daily study minutes
- Timestamp of your age attestation
- Consent records (which consent, its version and the time you gave or withdrew it)
4.3 Learning progress
- Spaced-repetition state for each item you study (for example due date and difficulty)
- Session summaries (what you studied, when, how it went)
- Mock exam results
4.4 AI feature data (only if you turn AI features on)
- Typed answers and voice recordings you submit for grading or feedback
- The AI-generated grades, feedback and transcripts
- Usage counters (how many AI requests you made), used for fair-use limits
See section 7 and our separate AI Disclosure for details.
4.5 Purchase data
- App Store transaction IDs, the product bought, and the period your access is valid ("entitlement window")
- An
appAccountToken: a random-looking identifier (UUID) derived from your user ID, so Apple's purchase records can be matched to your account
Apple processes all payments. We never see or store your card or bank details.
4.6 Technical diagnostics
We receive crash and performance diagnostics only through Apple MetricKit, and only if you have allowed Apple to share diagnostics with app developers in your iOS settings. These reports are aggregated by Apple and are not linked to your account.
4.6a Problem reports you send
If you tap Report a problem on an exercise, word or lesson, we store: which item it was, the reason you picked (for example "my answer should be accepted"), an optional short comment of up to 300 characters, the content and app version, and the time. The report is not linked to your account: it contains no user ID, email or device identifier. To prevent abuse, a daily counter (your user ID, how many reports you sent that day and for which items) is kept for about two days and then deleted automatically. Please don't enter personal data in the comment. Reports are read only by Witram staff and contributors who review course content. Every report is deleted automatically 12 months after you send it, whether or not it has been dealt with. If a comment contains personal data anyway, we delete that report as soon as we notice. Because a report isn't linked to you, we usually can't find it for you; if you can tell us the item, the day and the wording of your comment, we will look for it and delete it.
4.6b Contributors (Recording Studio)
If you contribute recordings or review course texts for Witram (by invitation only, under a separate contributor agreement), we also store your agreement (version, date and a fingerprint of the text you signed), your recordings and their review status, and the corrections, reports and decisions you make, each with your user ID. If you delete your account, your user ID in these records is replaced by "erased" and your notes are removed; corrections to the course text stay. What happens to your published recordings is set out in the contributor agreement.
4.7 What we do NOT do
- No analytics SDKs, advertising, ad IDs or cross-app tracking
- No third-party crash reporting SDKs
- No selling or renting of your data
- No voiceprinting or biometric identification
5. Why we use your data and our legal basis
| Purpose | Data | Legal basis (GDPR) |
|---|---|---|
| Create and run your account, sync progress across devices | Account, profile, progress | Contract (Art. 6(1)(b)) |
| Provide the lessons, spaced repetition and mock exams | Profile, progress | Contract (Art. 6(1)(b)) |
| Optional AI grading and feedback | AI feature data | Consent (Art. 6(1)(a)) |
| Keep your recordings for 30 days for review (opt-in) | Voice recordings | Consent (Art. 6(1)(a)) |
| Unlock and verify purchases | Purchase data | Contract (Art. 6(1)(b)) |
| Keep accounting records | Minimal purchase records | Legal obligation (Art. 6(1)(c)) |
| Age check and consent records | Attestation and consent timestamps | Legal obligation / legitimate interest in demonstrating compliance (Art. 6(1)(c), (f)) |
| Protect the service from abuse (App Check, fair-use limits) | Device attestation, usage counters | Legitimate interest (Art. 6(1)(f)) |
| Fix mistakes in the course content you report | Problem reports (not linked to your account), daily report counter | Legitimate interest in accurate course content (Art. 6(1)(f)) |
| Recording Studio and content review (contributors only) | Contributor agreement, recordings, reviews and reports | Contract (contributor agreement, Art. 6(1)(b)) |
| Fix bugs and improve stability | MetricKit diagnostics | Legitimate interest (Art. 6(1)(f)) |
Your voice is personal data. We do not process it to identify you (no biometric processing under Art. 9 GDPR).
6. Where your data is stored and who processes it
We use Google Firebase, provided by Google Ireland Limited and, for some services, Google LLC, acting as our processor under the Google Cloud Data Processing Addendum:
- Cloud Firestore —
eur3multi-region (European Union) - Cloud Storage — EU location
- Cloud Functions —
europe-west1(Belgium) - Firebase Authentication
- Firebase App Check with Apple App Attest (checks that requests come from a genuine copy of the app)
If AI features are on, your submission is sent from our server to Google Gemini on Google Cloud (Gemini Enterprise Agent Platform), processed in the EU (EU multi-region). See section 7.
Apple processes your payments and App Store account as an independent controller under its own privacy policy. If you use Sign in with Apple or Google sign-in, Apple or Google also process the sign-in under their own policies.
International transfers. Our primary storage is in the EU. Some Google services may involve access from or transfer to the United States. Such transfers rely on the EU-US Data Privacy Framework (Google LLC is certified), with the EU Standard Contractual Clauses as a fallback.
7. AI features
AI features are optional and off until you give explicit consent in the app, which names Google Gemini as the provider. The app works fully without them.
- What is sent: your voice recording or typed text, plus the exercise prompt. We do not send your name or email.
- Model training: under the Google Cloud terms, Google does not use this data to train or fine-tune its models.
- Where: processed in the European Union (Google Cloud EU multi-region). We have turned off Google's response caching and don't use web search grounding.
- Voice recordings: deleted right after grading by default. If you turn on "Keep my recordings", they are kept for 30 days so you can listen back, then deleted automatically.
- Grades and transcripts: kept with your learning progress until you delete your account.
- Withdrawing consent: turn AI features off in Settings at any time. This stops new processing; it does not affect processing already done.
8. How long we keep data
| Data | Retention |
|---|---|
| Account, profile, progress, AI grades and transcripts | Until you delete your account |
| Voice recordings (default) | Deleted after grading |
| Voice recordings ("Keep my recordings" on) | 30 days, then auto-deleted |
| AI usage counters | Purged after 90 days |
| Problem reports | Not linked to your account; 12 months after sending, then auto-deleted |
| Daily problem-report counter | About 2 days, then auto-deleted |
| Minimal purchase records needed for accounting | Up to 10 years, as required by Luxembourg accounting law, in minimised form |
| MetricKit diagnostics | [RETENTION PERIOD] |
9. Deleting your account
Go to Settings → Delete account. This erases your Firestore data, any stored audio in Cloud Storage, your AI usage logs and your Firebase Authentication user. Deletion is permanent. Deleting the account does not cancel an App Store subscription — cancel that in your Apple ID settings. Backups held by Google are overwritten in line with Google's standard cycles [CONFIRM BACKUP PERIOD].
10. Your rights
Under the GDPR (Articles 15–22) you have the right to:
- Access your data (Art. 15)
- Rectify inaccurate data (Art. 16)
- Erase your data (Art. 17) — use in-app deletion or contact us
- Restrict processing (Art. 18)
- Data portability (Art. 20) — use the in-app export (JSON file)
- Object to processing based on legitimate interest (Art. 21)
- Not be subject to decisions based solely on automated processing with legal or similarly significant effects (Art. 22). AI grades in the app are learning feedback only and have no legal effect.
- Withdraw consent at any time, without affecting earlier processing
To exercise your rights, email privacy@witram.lu. We reply within one month.
You may also complain to the Commission nationale pour la protection des données (CNPD), 15, Boulevard du Jazz, L-4370 Belvaux, Luxembourg — cnpd.public.lu.
11. Security
Data is encrypted in transit (TLS) and at rest by Google. Access is restricted by Firebase security rules so that each user can read only their own data. App Check helps block requests not coming from the genuine app. No system is perfectly secure; if a breach affects you, we will notify you and the CNPD as required by law.
12. Changes to this policy
If we change this policy materially, we will tell you in the app and, where needed, ask for your consent again. The current version is always at https://letzdrill.witram.lu/legal/privacy.
13. Contact
privacy@witram.lu · Witram Tech S.à r.l.-S, [REGISTERED ADDRESS]