Thaki Platform Privacy Policy

Effective Date: January 21, 2019
Last Updated: September 13, 2026

1. Introduction

Thaki Netherlands (“Thaki,” “we,” “us,” or “our”) respects the privacy of the students, teachers, schools, educational centers, and other users who use the Thaki Platform.

The Thaki Platform is primarily an offline educational platform designed to provide access to educational applications and content on computers distributed to schools and educational centers.

The Platform includes educational applications in different categories. These applications may include free software, open-source software, and proprietary educational software that Thaki is authorized to distribute under agreements or licenses with educational content providers.

The Platform is primarily designed for Ubuntu-based computers, although information about the operating system may also be collected where the Platform is used on another supported operating system.

This Privacy Policy explains what information the Thaki Platform collects, why it is collected, how it is stored and transmitted, who may have access to it, and what rights users may have regarding that information.

Thaki Netherlands is the data controller for the processing described in this Privacy Policy.

For privacy questions, contact:

Thaki Netherlands
Email: info@thaki.org
Website: www.thaki.org

2. Who Uses the Thaki Platform

The Thaki Platform is primarily intended for:

• Students, including children
• Teachers
• Schools and educational centers

Computers may be shared by multiple students and teachers.

Students and teachers normally use the standard “Thaki” operating-system account. They do not need a personal account, username, email address, or password to use the Thaki Platform.

An administrative operating-system account, “Thaki-admin,” is maintained for authorized administration and technical management. Students and teachers are not provided with the administrator password.

3. What Users Can Do

Users of the Thaki Platform can use the Platform to:

• Open the Thaki Platform
• Browse educational categories
• View applications within a category
• Search for educational applications or topics
• Search using predefined application names, categories, and tags
• Open installed educational applications

The Platform does not require users to create an individual Thaki Platform account.

4. Information We Do Not Ask Users to Provide

The Thaki Platform does not ask students or teachers to provide personal profile information such as:

• Name
• Email address
• Telephone number
• Personal password
• Home address
• Date of birth
• Gender
• Student identification number
• Teacher identification number

Thaki does not use the Platform to create individual student or teacher profiles.

Because computers may be shared by multiple users and no individual login is required, Thaki generally does not know which particular student or teacher performed a specific Platform action.

5. Usage and Device Information We Collect

Although the Platform does not collect direct personal identifiers such as names or email addresses, it collects limited device-level and usage information for analytics and reporting purposes.

This information may include:

Application activity: which educational application was clicked or opened.

Category activity: which educational category was selected.

Search activity: recognized application names, tags, or categories selected or searched through the Platform.

Date and time: the date and time associated with a Platform activity.

Device identifier: a device/MAC identifier used to distinguish one distributed computer from another and measure usage by machine.

Educational center: an identifier or code representing the school or educational center associated with the distributed computer.

Country and city: predefined country and city information assigned to the computer image or deployment.

Screen resolution: information about the display resolution of the computer.

Platform interface language: the language selected or used within the Thaki Platform.

Operating system: information about the operating system on which the Platform is running, such as Ubuntu or Windows.

Thaki treats device-level analytics appropriately as data that may fall within the scope of applicable data protection laws.

6. Search Information

The Platform uses controlled search functionality and autocomplete based on known educational application names, categories, and tags.

Arbitrary text that does not correspond to supported applications, categories, or tags is not transmitted to the central analytics database.

For example, if a user types a person’s name or unrelated text that is not recognized as an application, tag, or category, that text is not intended to be sent as analytics data.

This design is intended to reduce the possibility of personal information being entered into Thaki’s analytics system through the search function.

7. Location Information

The Thaki Platform does not determine a user’s geographic location using:

• GPS
• Wi-Fi positioning
• IP geolocation
• Mobile location services
• Other automatic device-location technologies

Country, city, and educational-center information is configured as part of the computer’s deployment or software image.

The educational center is stored using an identifier or code.

This location information therefore describes the intended deployment location of the computer rather than tracking the physical location of an individual user.

8. Why We Collect Usage Information

Thaki collects limited usage and device information for purposes including:

• Understanding how distributed Thaki computers are being used
• Measuring the use of educational applications
• Understanding which educational categories and resources are used
• Understanding educational-content usage across countries, cities, and centers
• Measuring usage trends over time
• Improving the organization and usefulness of the Thaki Platform
• Supporting technical management of distributed computers
• Producing statistical reports about educational-resource usage
• Providing aggregated usage information to educational content providers regarding their own applications

Thaki does not use this information for advertising, targeted advertising, commercial profiling, or marketing to individual students or teachers.

9. Legal Basis for Processing

Where the General Data Protection Regulation (“GDPR”) applies, Thaki relies on its legitimate interests in operating, evaluating, maintaining, and improving the Thaki Platform and understanding the use of educational resources distributed through the Platform.

These interests include measuring the effectiveness and use of educational resources and providing aggregated usage statistics to relevant educational content providers.

Thaki seeks to limit the information collected to information necessary for these purposes.

Because the Platform is used by children as well as adults, Thaki recognizes that children’s privacy interests require particular protection and must be taken into account when evaluating any processing based on legitimate interests.

Thaki does not rely on behavioral advertising, commercial profiling, or targeted marketing as a purpose for this processing.

10. Local Storage and Offline Operation

The Thaki Platform is designed to operate primarily offline.

When a user interacts with the Platform, usage information is initially stored locally on the computer in a SQLite database.

An internet connection is not required for users to browse or open the available educational content.

If an internet connection is unavailable, analytics information remains temporarily stored on the computer.

The Platform attempts to synchronize stored analytics when an internet connection becomes available. Synchronization may occur when the Platform starts and through periodic connectivity checks while unsynchronized information remains locally stored.

After analytics records have been successfully transmitted to Thaki’s server, the corresponding local analytics records are cleared from the local SQLite database.

11. Transfer to Thaki’s Server

When an internet connection becomes available, the Platform sends the analytics information through a Thaki API to Thaki’s central database.

The central database is hosted using SiteGround infrastructure located in the European Union.

The analytics data transmitted by the Platform does not include a user’s name, email address, telephone number, account password, or other user-account information because the Platform does not require individual user accounts.

An IP address is not included as a field in the Thaki Platform analytics payload.

12. Device Identifiers

Thaki uses a device/MAC identifier to distinguish one distributed computer from another and to understand usage associated with each machine.

The identifier is used for device-level measurement and not for identifying individual students or teachers.

Because computers may be shared by many students and teachers, a device identifier does not by itself tell Thaki which individual person performed a particular activity.

Thaki does not use the device identifier to build individual student or teacher profiles or for advertising.

13. Educational Centers, Countries, and Cities

Each distributed computer may contain predefined deployment information such as:

• Country
• City
• Educational-center identifier

This information is configured as part of the deployment process and is not generated by tracking the user’s physical location.

It allows Thaki to understand educational-resource usage across deployments.

For example, Thaki may use this information to understand how often a particular educational application is used in a country or during a particular reporting period.

14. Aggregated Reporting to Educational Content Providers

Some applications distributed through the Thaki Platform are provided by educational partners or content providers.

Thaki may provide a relevant educational provider with aggregated statistics about the use of that provider’s own application.

For example, a report may state that:

“An application was opened 12,420 times in Lebanon.”

or:

“An application was opened 12,420 times during 2025.”

Educational providers are not provided with Thaki’s device-level analytics records.

Thaki does not provide educational providers with MAC/device identifiers, center-level device records, individual search records, screen-resolution records, individual timestamps, or other device-level analytics data.

Educational providers receive aggregated information related to their own educational resources.

15. Sharing of Information

Access to Thaki’s central analytics information is limited to authorized personnel who require access for legitimate operational purposes, including:

• Authorized Thaki IT staff
• Authorized Thaki management

Educational content providers may receive aggregated statistics relating to their own applications as described above.

Thaki does not sell users’ personal information.

Thaki does not provide device-level analytics data to donors, governments, advertisers, or unrelated third parties for marketing or advertising purposes.

Thaki may disclose information where disclosure is required by applicable law or a valid legal obligation.

16. Hosting and Service Providers

Thaki uses SiteGround to provide hosting infrastructure for the API and central analytics database.

The relevant hosting infrastructure used for this analytics system is located in the European Union.

Hosting providers may process information on Thaki’s behalf as necessary to provide infrastructure and hosting services, subject to applicable contractual and data-protection requirements.

17. Third-Party and Educational Applications

The Thaki Platform may include:

• Open-source applications
• Free educational applications
• Proprietary educational applications licensed for distribution by educational providers

When a user selects an application, the Thaki Platform records the applicable Platform-level usage event, such as the application click or launch.

The analytics system described in this Privacy Policy does not collect the content a student or teacher creates or enters inside an educational application.

The Platform’s analytics reporting is handled through the Thaki Platform’s local SQLite database, Thaki API, and central database. Thaki does not use Google Analytics, Firebase Analytics, Mixpanel, Matomo, or similar third-party analytics services for the Platform analytics described in this Policy.

18. Advertising, Profiling, and Automated Decisions

Thaki does not use Platform analytics data for:

• Targeted advertising
• Behavioral advertising
• Commercial marketing profiles
• Selling user data
• Tracking users across unrelated services

Thaki does not use the analytics information described in this Privacy Policy to make automated decisions about individual students or teachers that produce legal or similarly significant effects.

19. Children’s Privacy

The Thaki Platform is designed for educational environments and may be used by children of different ages, including children under 13 and under 16.

Thaki therefore seeks to minimize the information collected about Platform users.

Children are not required to provide their names, email addresses, telephone numbers, personal passwords, or individual user profiles in order to use the Platform.

The Platform uses shared computers and a shared standard operating-system account in many educational deployments.

Thaki’s analytics are intended to measure use of computers and educational resources rather than monitor individual children.

Thaki does not use children’s Platform activity for advertising, marketing profiles, or behavioral targeting.

Parents, guardians, teachers, schools, or educational centers with privacy questions concerning a child’s use of the Platform may contact Thaki at info@thaki.org.

20. Data Retention

Analytics information is temporarily stored in the local SQLite database until it is successfully synchronized with Thaki’s server.

Once transmission is successful, the corresponding local analytics information is cleared from the local database.

At present, Thaki has not established a fixed retention period for analytics information stored in the central database.

Thaki recognizes that data should not be retained for longer than necessary for the purposes for which it is processed.

This Privacy Policy will be updated when a formal central analytics retention period has been adopted.

Aggregated statistical information that can no longer reasonably be associated with an identifiable individual or device may be treated differently from device-level analytics information.

21. Data Security

Thaki takes measures intended to limit unauthorized access to Platform analytics information.

Access to the central analytics database is restricted to authorized Thaki IT personnel and authorized Thaki management according to operational need.

Analytics information is transmitted from distributed computers to Thaki’s backend through the Thaki API.

No method of electronic storage or transmission can be considered completely free of security risk. Thaki therefore seeks to maintain technical and organizational safeguards appropriate to the nature of the information processed.

22. Your Data Protection Rights

Depending on where you live and which data-protection laws apply, you may have rights concerning personal data processed by Thaki.

Under the GDPR, these rights may include, where applicable:

• The right to receive information about processing
• The right to request access to personal data
• The right to request correction of inaccurate personal data
• The right to request deletion of personal data in applicable circumstances
• The right to request restriction of processing
• The right to object to processing based on legitimate interests
• Other rights provided by applicable data-protection law

Requests can be sent to:

info@thaki.org

Because the Thaki Platform does not create individual accounts or collect names and email addresses, Thaki may not always be able to identify which device-level analytics record relates to a particular student or teacher.

Thaki may request reasonable information necessary to locate relevant records and verify a request where required. Thaki will not intentionally collect unnecessary personal information solely for the purpose of creating a user profile.

23. Right to Object

Where Thaki processes personal data on the basis of legitimate interests under the GDPR, an individual has the right to object to that processing based on circumstances relating to that individual.

Requests may be sent to:

info@thaki.org

Thaki will evaluate requests in accordance with applicable data-protection law.

24. Complaints

Individuals may contact Thaki first with any questions or concerns about the processing described in this Privacy Policy.

Email:

info@thaki.org

Where the GDPR applies, individuals may also have the right to lodge a complaint with the competent data-protection supervisory authority.

Because Thaki Netherlands is the controller, the Dutch Data Protection Authority — Autoriteit Persoonsgegevens — may be a relevant supervisory authority.

Individuals may also have the right to contact another competent supervisory authority depending on their circumstances and applicable law.

25. International Use

Thaki computers and educational resources may be distributed in countries including:

• Lebanon
• Jordan
• Syria
• Egypt
• United Arab Emirates
• Palestine

The central analytics infrastructure described in this Privacy Policy is hosted in the European Union.

Thaki seeks to apply appropriate privacy and data-protection safeguards to the Platform regardless of the country in which a distributed computer is used, while also complying with applicable local legal requirements.

26. Changes to This Privacy Policy

Thaki may update this Privacy Policy when the Platform, analytics system, legal requirements, hosting arrangements, data practices, or educational services change.

When material changes are made, the “Last Updated” date at the beginning of this Privacy Policy will be revised.

The current version should be made available through Thaki’s website or another appropriate location accessible to schools, teachers, parents, and educational centers.

27. Contact Us

For questions, privacy requests, or concerns regarding this Privacy Policy or the Thaki Platform’s handling of information, contact:

Thaki Nederland
James Wattstraat 100-8
1097DM Amsterdam
The Netherlands

Email: info@thaki.org
Website: https://thaki.org