LuxNationality Privacy Policy

1. Who we are

LuxNationality is published by Navritto Solutions Private Limited (“Navritto”, “we”, “us”), a company registered in Haryana, India, which is the data controller for the purposes of this policy. LuxNationality is an independent study aid and is not affiliated with, endorsed by, or connected to the INL (Institut National des Langues) or the Luxembourg government.

2. What LuxNationality collects

LuxNationality has no user accounts and no sign-in, and Navritto runs no server that stores your data. We do not use advertising, analytics, crash reporting, tracking or location, and we collect no identifiers about you. Your learning progress, settings, review history and recordings stay in the app's own storage on your device.

The one piece of personal data that leaves your device is the voice recording you make in a speaking exercise, which is sent to a language service to be turned into text (see “Speaking practice and your voice” below). In addition, the outside services the app connects to necessarily see your device's IP address when it contacts them, as any internet request does.

3. What the app can access

4. Speaking practice and your voice

When you answer a topic question out loud, your device records your answer to a local file so you can play it back, and — to show you a transcript of what you said — the recording is sent to Sproochmaschinn (sproochmaschinn.lu), a Luxembourg language service, which turns the speech into text. Speaker identification is turned off, so the recording is not used to recognise who you are, and Sproochmaschinn's operator states that the audio and text it processes are not stored. Navritto does not receive your recording or your transcript. The app shows this, next to every record button and in onboarding, before you record.

When you describe a picture, your answer is checked on your device and is not sent anywhere. A copy of your recordings is kept only on your phone — the most recent ones — so you can listen back; older ones are deleted automatically, and they are never uploaded except for the topic-question transcription described above. If you prefer not to have a recording transcribed, simply do not use the topic-question speaking exercise.

5. The services the app connects to

LuxNationality works with two outside services, plus your app store. We share with them only what each one needs to do its job, and never your name, account or any identifier (there is none).

6. What is stored on your device

7. Subscriptions

LuxNationality is free to start, with an optional Premium subscription that unlocks all the lessons and practice. The subscription is sold and billed by the app store you installed from, under its own terms and privacy policy; the store handles payment and any renewal or cancellation. Navritto never sees or stores your payment details, and we run no server to process or validate it — the app store on your device is the source of truth, and you can restore a purchase from the app.

8. Legal basis (EEA / Luxembourg / UK)

For users in the EEA, Luxembourg and the UK: we process the voice recording you choose to submit in order to provide the transcription feature you are using, which is necessary to deliver that part of the service at your request (Article 6(1)(b) GDPR); the in-app notice tells you before you record, and you can choose not to use it. Downloading lessons, audio and pictures, and showing the “you're offline” banner, rely on our legitimate interest in delivering the app's content and a working experience (Article 6(1)(f)). A subscription is processed to perform the contract for the service you buy (Article 6(1)(b)).

9. International transfers

Sproochmaschinn operates in Luxembourg, within the EU. Google is a global provider and may process the file-download data on servers outside your country, including in the United States; Google states that it relies on the European Commission's Standard Contractual Clauses and related safeguards for such transfers. The app store may likewise process subscription data internationally under its own safeguards.

10. Retention and deletion

Navritto stores no personal data on any server, so there is nothing for us to retain or delete on your behalf. Sproochmaschinn's operator states that the audio and text it processes are not stored. Everything LuxNationality keeps lives on your device and is under your control.

• Delete your recordings from within the app, or let the app remove older ones automatically.
• Reset your progress from within the app.
• Turn the reminder on or off in the app, or revoke microphone or notification permission in your device's settings.
• Uninstalling LuxNationality removes the app and everything it stored on the device.

11. Your rights

Depending on where you live — including under the GDPR (EEA/UK) and India's Digital Personal Data Protection Act, 2023 — you may have the right to access, correct, delete or restrict the processing of your personal data, to object to it, and to withdraw consent. Because Navritto holds no personal data about you on any server, there is little for us to retrieve or erase; for any question, write to info@navritto.com.

You also have the right to complain to your data-protection authority — for example the Commission nationale pour la protection des données (CNPD) in Luxembourg, your supervisory authority in the EEA (Article 77 GDPR), the Information Commissioner's Office in the UK, or the Data Protection Board of India.

12. Children's privacy

LuxNationality is a general-audience study app for adults preparing for the Sproochentest and is not directed at children under 13. We do not knowingly collect personal data from anyone, including children.

13. Security

Your data on the device is protected by the same platform security that protects the rest of your device's storage, including device encryption. The connections the app makes — to transcribe a recording, download content, or handle a subscription — use encrypted (HTTPS) connections.

14. Changes to this policy

If this policy changes, the updated version will be published at this same URL with a revised “last updated” date. Material changes will be described clearly.

15. Contact

Questions about this policy or the app can be sent to info@navritto.com. We aim to respond to privacy enquiries within 30 days.

The publisher is Navritto Solutions Private Limited, a private company limited by shares registered in Haryana, India under the Companies Act, 2013. Our Corporate Identity Number is shown at the foot of this page and can be verified on the Ministry of Corporate Affairs portal.