Create PRIVACY.md for Language

components/ILIAS/Language/PRIVACY.md

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+# Language Privacy
+
+> **Disclaimer: This documentation does not guarantee completeness or accuracy. Please report any missing or incorrect information by submitting a [Pull Request](docs/development/contributing.md#pull-request-to-the-repositories) or, if you prefer, via the [ILIAS bug tracker](https://mantis.ilias.de). When using the bug tracker, please select the corresponding component in the **Category** field.**
+
+## General Information
+
+The Language component manages all user interface translations in ILIAS. It handles the
+installation, maintenance, import, export, and customization of language files. The component
+stores translation strings in the database and provides them to all other ILIAS components.
+
+The Language component itself stores very little personal data. The primary privacy-relevant
+aspects are:
+
+- When a language file is exported, the **full name and email address** of the exporting user
+  are embedded in the file header.
+- When a new language entry is created through the page translation interface, the **login name**
+  of the creating user is stored as a remark in the database.
+- An optional language usage logging feature (disabled by default, enabled via DEVMODE or
+  `LANGUAGE_LOG` configuration) records which language variables are used, but this data contains
+  no user identifiers.
+
+## Integrated Components
+
+- The Language component employs the following components, please consult the respective
+  PRIVACY.md files:
+    - [AccessControl](https://github.com/ILIAS-eLearning/ILIAS/blob/trunk/components/ILIAS/AccessControl/PRIVACY.md) – permission checks for language
+      maintenance, translation, and administration are managed through RBAC.
+    - User – the component reads the user's preferred language. When
+      exporting language files, the current user's full name and email address are retrieved
+      from the User component. When creating new language entries, the user's login is stored
+      as a remark.
+    - ILIASObject – language objects (`lng`) and the language folder (`lngf`) extend the base
+      ILIAS object class and are stored in `object_data`.
+
+## Data being stored
+
+- **Login name of the creating user (as remark)**: When a new language entry is created through
+  the page translation interface, the **login name** of the creating user is stored in the
+  `remarks` column of the `lng_data` table via `ilObjLanguage::replaceLangEntry()`. This serves
+  as an attribution of who contributed the translation.
+- **Timestamp of local changes**: When a translation value is modified through the maintenance
+  interface, a **timestamp** is stored in the `local_change` column of the `lng_data` table.
+  This records when the modification was made, but does not store which user made the change.
+
+## Data being presented
+
+- **Each user** interacts with translated text strings provided by the Language component, but
+  this does not constitute personal data presentation.
+- **Persons with the "read" and "write" permissions** on the language folder can access the
+  language maintenance interface, where they can view and edit translation values, import and
+  export language files, and manage language settings. No personal data of other users is
+  displayed in this interface.
+- **Persons with the "write" permission** on the language folder can view the language overview
+  table, which includes the number of users per installed language. This is an aggregate count
+  and does not reveal individual user identities.
+
+## Data being deleted
+
+- **When a language is uninstalled** by a person with the "write" permission on the language
+  folder: all translation data for that language is deleted from `lng_data` and `lng_modules`.
+  Any remarks (including login names stored as attribution) in `lng_data` for that language are
+  deleted. Additionally, all users who had selected the uninstalled language as their preferred
+  language are reset to the system default language (via `resetUserLanguage()` in the `usr_pref`
+  table).
+- **When local changes are cleared** by a person with the "write" permission: translation data
+  is flushed and re-inserted from the original language files, removing all local modifications
+  including timestamps and remarks.
+- **When a user account is deleted**: the Language component does not independently delete any
+  data. However, any login names that were previously stored as remarks in `lng_data` remain as
+  residual data, since these are plain text strings not linked by user ID.
+
+## Data being exported
+
+- **Language file export**: Persons with the "read" and "write" permissions on the language
+  folder can export language files. The exported file header contains the **full name** and
+  **email address** of the person performing the export (stored in the `created_by` parameter).
+  The body of the exported file contains only translation strings (module, identifier, value)
+  and does not include personal data.
+- There is no XML-based or GDPR-specific personal data export within the Language component.