Privacy Policy for DEU App

Effective Date: 17th June 2025

Last Updated: 17th June 2025

1. Introduction

Lulo (“we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how the DEU app (“the App”) collects, uses, stores, and protects your information. The App is designed to help users prepare for the German citizenship test (Einbürgerungstest and Leben in Deutschland) and functions entirely offline.

2. Information We Collect

A. Data Stored Locally on Your Device

All data is stored on your device using iOS’s UserDefaults system. The App stores the following types of information:

• Study Progress

  • Progress in Practice, Bundesland, Mock Test, and Starred Modes
  • Answer history and question completion status
  • Overall performance statistics

• User Preferences

  • Name (optional)
  • Exam date and location (optional)
  • Selected Bundesland (German state)
  • Preferred language
  • Appearance settings (light/dark/system)

• Saved Questions

  • Questions marked as favorites for later review
  • Associated question IDs and metadata

• App Cache

  • Downloaded question database for offline use
  • Cache version information for data consistency

B. Data We Do NOT Collect

• No Personally Identifiable Information (PII):

We do not collect your real name, email, phone number, or other personal data unless entered voluntarily.

• No Location Tracking:

We do not access or use GPS or location services.

• No Analytics or Advertising:

We do not use analytics tools, third-party SDKs, or ad networks.

• No Network Communication:

The app does not send or receive any data from external servers.

3. How Your Data Is Used

All data is stored locally and used solely to:

  • Track your study progress
  • Provide a personalized learning experience
  • Enable offline use
  • Improve app performance through caching

4. Data Storage and Security

  • Local Only: Data remains on your device
  • No Cloud Sync: We do not use iCloud or cloud services
  • Secured by iOS: Data is protected by your device’s encryption and access controls
  • No Third-Party Access: No data is shared with third parties

5. Data Sharing

We do not share, sell, or transmit your data. The app operates fully offline with no server communication.

6. Your Rights and Choices

• Access & Control:

  • View and modify preferences in app settings
  • Clear study progress or saved questions
  • Use “Reset App” to delete all data

• Data Deletion:

  • Delete saved data in settings
  • Uninstalling the app deletes all stored data

• No Opt-Out Required:

Since no data is collected, no opt-out is necessary.

7. Children’s Privacy

The app may be used by individuals under 13. However, we do not knowingly collect personal information. All data stays local and anonymous.

8. Data Retention

  • Data is stored only on your device
  • You can delete it anytime via app settings
  • Nothing is stored or backed up online

9. International Users

As no data leaves your device, international data transfer laws (like GDPR or CCPA) do not apply. Your data remains in your local jurisdiction.

10. Changes to This Policy

We may update this policy from time to time. Changes will be noted with a new “Last Updated” date. Continued use of the app confirms your acceptance of the updates.

11. Contact Us

If you have questions or concerns about this Privacy Policy, contact us at:

Email: saradrada@luloai.com, yesidlopez@luloai.com

Developers: Sara Ortiz Drada, Yesid López

Summary

The DEU app is privacy-focused. It works entirely offline, stores all data locally, and does not collect or transmit personal or usage data.