Legal
Privacy notice
Last updated 5 August 2026
Draft. Not yet in force
This notice has not been reviewed by Tanzanian counsel and the bracketed details below are unfilled. It does not bind ATLAS or any school yet. Remove this notice only once counsel has approved the wording and the Personal Data Protection Commission steps in the internal privacy checklist are signed off.
ATLAS holds information about children. We have written this notice to be read, not to be survived, and it describes what the software actually does rather than what would be convenient to claim.
1. Who is responsible for what
Your school decides what records to keep about its students, guardians and staff, and why. In the language of Tanzania's Personal Data Protection Act 2022, the school is the data controller.
ATLAS stores and processes those records on the school's instructions in order to provide the service. The data processor. We do not sell personal data, we do not use it to train AI models, and we do not use children's data for marketing.
For our own website, the enquiry form and our business contacts, we are the controller.
2. What we hold, on behalf of your school
| Category | Examples |
|---|---|
| Student identity | Name, admission number, date of birth, class and stream, enrolment status |
| Guardians | Name, relationship, phone number, portal access |
| Attendance | Daily and per-period presence and absence |
| Academic | Assessment marks, grades, report cards, NECTA combinations |
| Fees and accounting | Invoices, payments, receipts, balances, ledger entries |
| Staff and payroll | Employment records, salaries, PAYE and deductions |
| Communications | SMS and announcements sent, and their delivery status |
| Health | Limited clinic visit records, where the school uses that module |
| Technical | Sign-in records, audit logs of who changed what, device push tokens |
3. Children's data
Most of what ATLAS holds concerns children, which is why access is restricted by role rather than by trust. A teacher sees their own classes. A bursar sees fees. A parent sees only their own children. Every one of these boundaries is enforced by the database itself, not only by the screens.
Clinic messages sent to guardians are deliberately kept general, and clinical detail is never sent to the AI assistant.
4. The AI assistant
When someone at your school asks the assistant a question, the question and the results of the specific lookups needed to answer it are sent to our model provider, Moonshot AI, whose service is outside Tanzania.
By design, the assistant:
- reaches data only through a fixed catalogue of tools, each permission-checked against the asking user's role;
- receives no clinical detail and no individual salary and the payroll tool returns aggregates only;
- cannot change anything on its own. Every write is proposed and waits for a person to confirm it.
Transferring personal data outside Tanzania may require approval or a permit from the Personal Data Protection Commission. That work is not complete. Until it is, the assistant must not be enabled against real student data. It is restricted to pilot and synthetic data. Your onboarding will tell you plainly which applies to your school.
5. Who else processes data
We use the following sub-processors. The country or region of each service, and the contract with it, are being confirmed and will be listed here before any school goes live: [confirm region and contract per row].
| Service | Purpose | Data |
|---|---|---|
| Supabase | Database, authentication and file storage | All school records |
| Beem Africa | Sending SMS to guardians and staff | Recipient phone number and message text |
| Moonshot AI | The AI assistant's language model | The question asked and the tool results returned to answer it |
| Sentry | Error reporting, so faults are found and fixed | Technical diagnostics; 5xx responses are scrubbed |
| Redis | Background job queueing | Job references, not record content |
| Expo | Mobile app delivery and push notifications | Device push tokens |
| Resend | Transactional and sales email | Email address and message content |
We will tell schools before adding a sub-processor that handles student data.
6. How long we keep it
While your school subscribes, we keep records for as long as the school needs them, because a student's results and fee history are meant to outlast their time at the school.
We do not delete a school's data for non-payment. On leaving, we provide a full export and delete on written request from an authorised person, except where law requires us to retain something.
Specific retention periods for assistant conversation history, audit logs and message records are being finalised with counsel: [retention schedule per category].
7. Rights of students, guardians and staff
Under the Personal Data Protection Act 2022 you may ask to see the data held about you, to have it corrected, to object to certain processing, and to complain to the Personal Data Protection Commission.
Because your school is the controller, please contact your school first. They hold the records and can correct them directly. If you cannot resolve it with the school, contact us at [privacy contact email] and we will help the school respond.
8. Security
Access is separated by school and by role, and enforced in the database as well as the application. Financial records cannot be edited, because a correction is a reversal, so the audit trail cannot be quietly rewritten. Every change of consequence is logged against the person who made it. Passwords are set by each user and never shared with us.
If a breach occurs that is likely to affect people, we will notify the school and the Commission as required, following our internal incident-response procedure.
9. This website
The public website sets no advertising or analytics cookies. If you submit the demo enquiry form we store what you enter, meaning your school, your name and your phone number, in order to contact you about ATLAS, and for no other purpose. We do not sell it or share it with anyone outside our sub-processors above.
10. Registration and contact
Our registration with the Personal Data Protection Commission and our data-protection contact are being completed: [PDPC registration reference] · [DPO or privacy contact name and email].
[registered entity name] · [registered address]