Privacy Policy
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This notice explains how New2Germany handles personal information when you use its account, Germany preparation tools, document wallet, optional Nia AI features and subscriptions. It also explains your choices and how to exercise your rights.
1. Who is responsible
Uchenna E. Onyeisi, trading as New2Germany, is responsible for processing your personal data.
Address: Hallesches Ufer 42, 10963 Berlin, Germany.
For privacy, app or billing enquiries, contact support.new2germany@gmail.com.
2. Information we process
- Account information: your email, account identifier, authentication and email-verification records, account creation date, and profile details you provide, such as display name, language, time zone and profile photo. Supabase handles password authentication; the app does not include your password in account exports.
- Germany preparation information: nationality, city, arrival date, residence category, permit expiry date, selected journeys and the preparation steps you mark complete.
- Documents and deadlines: files you select or photograph, document titles, categories, file type and size, validation status, optional expiry dates, missing-document lists, linked deadlines and completion status. A profile photo is stored privately with a separate purpose and is excluded from My Documents.
- AI requests: questions or selected document-page images you expressly submit, the chosen action and language, relevant guidance and step statuses, and the generated response. The precise sharing is described below.
- Subscription information: your account identifier, product and transaction information, subscription status and expiry, restoration information, and whether a verified transaction is a test purchase. Apple or Google handles payment details; New2Germany does not collect your full payment-card number.
- Operational information: requests, network addresses and technical records processed by hosting providers; subscription event identifiers; and account-linked AI quota records containing request identifiers, timestamps and success status, not the question or answer.
- Support and privacy choices: information you send when requesting help and any recorded consent or withdrawal history.
Providing an email and authentication information is necessary for an account. Profile fields support the features that use them. You choose whether to add documents, use optional AI or enable reminders; withholding information may make the related feature unavailable.
3. Purposes and legal bases
For ordinary personal data, we rely on the following GDPR legal bases, as applicable:
- Providing the service you request — Article 6(1)(b): account access, saving your records, matching journeys to your profile, document storage, reminders, and verifying or restoring subscriptions.
- Your consent — Article 6(1)(a): optional sharing with Groq for AI processing. Document actions require confirmation for each selected page and action. You can decline without sending the page.
- Legitimate interests — Article 6(1)(f): proportionate security, fraud prevention, technical troubleshooting and service protection. These interests are balanced against your rights.
- Legal obligations — Article 6(1)(c): records and disclosures required by applicable accounting, tax, consumer or other laws.
4. Optional AI and your documents
Nia chat: choosing the AI action sends your question and applicable source guidance, review information and journey-step statuses through our backend to Groq. It does not automatically send your name, email, profile photo, wallet files or other conversations. Personal information you type into a question will be included.
Explain, Translate and Draft reply: after your confirmation, Groq receives the selected document image and the requested action and language. For a PDF, the app renders a page locally and sends only your selected page image to Groq. The full PDF remains in the document wallet; it is not sent to Groq by this action. The image itself may contain names, addresses, reference numbers or other personal details.
The app does not automatically send files to AI when you upload them. It does not send generated replies, make applications or change deadlines on your behalf. AI output and extracted text are displayed for your review.
New2Germany does not save a conversation or analysis-result history in its database. Results are held in the current screen and cleared when you leave it or background the app. Account-linked usage records are retained separately for quota enforcement. A request already sent to Groq cannot be recalled by closing the screen or withdrawing consent.
Groq states that ordinary inference content is not retained by default, but reliability or abuse investigations can retain inputs and outputs for up to 30 days, or longer where legally required. Usage metadata is retained separately. We do not promise zero retention by the AI provider. See Groq's data handling.
Permission for document processing is requested each time. The app also lets you withdraw legacy recorded choices in Profile → Privacy & Security. A previous stored decision does not authorize future automatic document processing.
5. Sensitive information and information about others
Identity and immigration documents can be highly sensitive. Health records, religious information and other specially protected information require additional legal safeguards. Do not submit unnecessary sensitive details or another person's documents without authority. Redact information that is not needed for the action you request.
6. Providers and recipients
- Supabase: account authentication, database, private file storage and backend functions. This includes the records and files needed for the app. Provider privacy information.
- Groq: the optional AI requests described above. Wallet files not selected for an AI action are not included in those requests. Provider privacy information.
- RevenueCat: subscription processing and verification. The app identifies you using your full account UUID, which is pseudonymous rather than anonymous. RevenueCat processes transaction and technical information; the app does not intentionally send it your documents or immigration profile. Provider privacy information.
- Apple and, where offered, Google Play: app distribution, store purchases, renewals, cancellations and refunds under their own account and privacy terms. Android billing is not yet offered in this release.
- Support, hosting and legally required recipients: authorized providers that help operate the service, and authorities where disclosure is legally required. Support email is handled through Gmail (Google); information you send to our support address is processed there. The public legal and support pages are hosted on Vercel at new2-germany.vercel.app. Visiting those pages sends a web request to Vercel. Contact us for information about hosting records associated with your visit.
We do not use document content for advertising. The current app has no advertising SDK or cross-app advertising-tracking feature. Opening an official government link or another external page takes you to a service with its own privacy practices.
7. Where data is processed
The New2Germany Supabase database is hosted in Frankfurt, Germany (AWS region eu-central-1), verified on 23 September 2026. Providers may process information outside Germany or the EEA. Groq states that retained customer content is stored in the United States. Choosing an EU database region does not by itself mean all authentication, support, billing or AI processing stays in the EU.
8. Storage, retention and deletion
Saved profile, journey, document and deadline records remain while your account uses the service, until you delete the relevant record or your account. The current app does not automatically expire an inactive account. Replaced profile photos and some deleted-document metadata may remain until account deletion.
Profile → Privacy & Security → Delete my account starts removal of private files and account records. The app removes files before deleting the account and its linked records. If cleanup is interrupted, the screen offers a retry; removal is not guaranteed to finish immediately. Subscription and AI-quota rows in our database are linked to account deletion.
Deleting an account does not itself cancel a store subscription or automatically erase RevenueCat's customer record. Store transaction records, provider logs and backups may have separate retention requirements. Files you have exported, shared or saved elsewhere are outside the app's deletion process.
9. Your device and security
On native devices, authentication sessions use operating-system secure storage. The web version uses browser local storage for its session. File selection and camera access are used when you request them. Notification permission enables local device reminders; the current reminder flow does not register a remote push token. Reminder text can appear on your lock screen depending on device settings.
Private storage and account-based access controls limit access to files. Short-lived download links and local preview/cache copies are used to display or share documents. This is not end-to-end encryption: the backend must process files for the actions you request. No system can guarantee absolute security.
The accompanying static legal pages contain no analytics scripts or third-party fonts. Vercel hosts these pages and may process technical request information to deliver and protect the website.
10. Your rights and choices
Subject to applicable conditions, you can request access, correction, erasure, restriction or portability of your data; object to processing based on legitimate interests; and withdraw consent without affecting earlier lawful processing. Contact the privacy address above. We may ask for proportionate information to verify your identity. Requests are normally answered within one month, with extensions only where allowed and explained.
The in-app account export provides profile and activity records, document metadata and consent history. It excludes uploaded file contents, credentials, some billing/operational records and information on other devices. Download files separately or contact us for a broader access request. Privacy controls, export and deletion do not require Plus.
You may complain to a data-protection authority, including in the EU country where you live or work or where an alleged infringement occurred. See the EDPB authority directory. You do not have to contact us first.
11. Automated suggestions and children
Profile matching and AI generate informational suggestions. New2Germany does not decide immigration status, eligibility, benefits or other matters with legal effect. Preparation progress reflects your own recorded steps.
New2Germany is intended for adults aged 18 and over. You must be at least 18 to create an account. The signup form asks you to confirm this; it does not collect your date of birth or verify your identity documents for age assurance. If you believe someone under 18 has created an account, contact support.new2germany@gmail.com so we can investigate and take appropriate action.
12. Changes to this notice
We will update the date shown above when this notice changes and communicate material changes through an appropriate channel. New purposes that require consent will be presented before that processing begins. A privacy-policy update is not, by itself, consent to optional AI processing.