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PAIA Manual

Last revised: 30 October 2026

This Manual is prepared in accordance with Section 51 of the Promotion of Access to Information Act 2 of 2000 (“PAIA”) and the Protection of Personal Information Act, 2013 (“POPIA”).

Date of Compilation
20 April 2023
Date of Revision
30 October 2026
Company
STS Holdings (Pty) Ltd
Jurisdiction
Republic of South Africa

1. Interpretation and definitions

  1. 1.1.
    “DIO” means Deputy Information Officer;
  2. 1.2.
    “IO” means Information Officer;
  3. 1.3.
    “PAIA” means Promotion of Access to Information Act No. 2 of 2000 (as Amended);
  4. 1.4.
    “POPIA” means Protection of Personal Information Act No. 4 of 2013;
  5. 1.5.
    “Regulator” means the Information Regulator of South Africa; and
  6. 1.6.
    “Republic” means the Republic of South Africa.

2. Purpose of PAIA manual

  1. 2.1.

    This PAIA Manual and POPIA Compliance Manual (“Manual”) is prepared in accordance with:

    • the Promotion of Access to Information Act 2 of 2000 (“PAIA”);
    • the Protection of Personal Information Act 4 of 2013 (“POPIA”);
    • applicable South African privacy and information legislation.

    This Manual applies to:

    • STS Holdings;
    • associated websites;
    • associated advertisements;
    • associated software applications;
    • associated social media platforms;
    • all information processing activities conducted by STS Holdings.
  2. 2.2.

    The purpose of this Manual is to:

    • promote transparency;
    • inform Users and data subjects of their rights;
    • explain how Personal Information is processed;
    • explain how requests for access to records may be made;
    • describe the safeguards implemented to protect Personal Information.
  3. 2.3.

    This manual is useful for the public to:

    • check the categories of records held by a body which are available without a person having to submit a formal PAIA request;
    • have a sufficient understanding of how to make a request for access to a record of the body, by providing a description of the subjects on which the body holds records and the categories of records held on each subject;
    • know the description of the records of the body which are available in accordance with any other legislation;
    • access all the relevant contact details of the Information Officer and Deputy Information Officer who will assist the public with the records they intend to access;
    • know the description of the guide on how to use PAIA, as updated by the Regulator and how to obtain access to it;
    • know if the body will process personal information, the purpose of processing of personal information and the description of the categories of data subjects and of the information or categories of information relating thereto;
    • know the description of the categories of data subjects and of the information or categories of information relating thereto;
    • know the recipients or categories of recipients to whom the personal information may be supplied;
    • know if the body has planned to transfer or process personal information outside the Republic of South Africa and the recipients or categories of recipients to whom the personal information may be supplied; and
    • know whether the body has appropriate security measures to ensure the confidentiality, integrity and availability of the personal information which is to be processed.

3. Key contact details for access to information of Software Technology Solutions

3.1. Company Information

Company Name
STS Holdings (Pty) Ltd
Registered Jurisdiction
Republic of South Africa
Head Office
Johannesburg, South Africa

3.2. Information Officer

Name
Mr. Niran Munsami
Tel
+27 79 498 0243
Email
niran@stsafrica.com

3.3. Deputy Information Officer

Name
Mr. Trishant Deva
Email
trishant@stsafrica.com

3.4. Head Office

Postal Address
16 Dale Way, Kelvin, Sandton, 2196
Physical Address
16 Dale Way, Kelvin, Sandton, 2196
Telephone
0861 787 777
Email
info@sts.holdings
Website
https://www.sts.holdings

4. About STS

STS Holdings is a technology group which operates various software products and services. You may visit the STS Holdings website, https://www.sts.holdings for more information about STS Holdings, its various businesses, products and services. You may interact with STS Holdings and its businesses, and STS Holdings and its businesses may interact with you via:

  • associated company and product websites;
  • associated company and product advertisements;
  • associated communications across email, whatsapp, telephone, application notifications and social media;
  • associated software applications and products.

STS Holdings may collect and process information about you during your interaction with the company, its businesses and various business activities to:

  • conduct security checks;
  • provide you with company, product and service information;
  • market and sell its products and services;
  • provide you with secure user accounts;
  • personalise communications and services where applicable;
  • maintain acceptable performance of its duties for any applicable services and solutions.

5. Rights of data subjects

Data subjects have rights under POPIA including the right to:

  • be notified that Personal Information is being collected;
  • request access to Personal Information;
  • request correction of Personal Information;
  • request deletion of Personal Information;
  • object to processing;
  • withdraw consent where applicable;
  • submit complaints to the Information Regulator.

6. Guide on how to use PAIA and how to obtain access

  1. 6.1.
    The Regulator has, in terms of section 10(1) of PAIA, as amended, updated and made available the revised Guide on how to use PAIA (“Guide”), in an easily comprehensible form and manner, as may reasonably be required by a person who wishes to exercise any right contemplated in PAIA and POPIA.
  2. 6.2.
    The Guide is available in each of the official languages and in braille.
  3. 6.3.

    The aforesaid Guide contains the description of:

    1. 6.3.1.
      the objects of PAIA and POPIA;
    2. 6.3.2.

      the postal and street address, phone and fax number and, if available, electronic mail address of:

      1. 6.3.2.1.
        the Information Officer of every public body, and
      2. 6.3.2.2.
        every Deputy Information Officer of every public and private body designated in terms of section 17(1) of PAIA and section 56 of POPIA;
    3. 6.3.3.

      the manner and form of a request for:

      1. 6.3.3.1.
        access to a record of a public body contemplated in section 11; and
      2. 6.3.3.2.
        access to a record of a private body contemplated in section 50;
    4. 6.3.4.
      the assistance available from the IO of a public body in terms of PAIA and POPIA;
    5. 6.3.5.
      the assistance available from the Regulator in terms of PAIA and POPIA;
    6. 6.3.6.

      all remedies in law available regarding an act or failure to act in respect of a right or duty conferred or imposed by PAIA and POPIA, including the manner of lodging:

      1. 6.3.6.1.
        an internal appeal;
      2. 6.3.6.2.
        a complaint to the Regulator; and
      3. 6.3.6.3.
        an application with a court against a decision by the information officer of a public body, a decision on internal appeal or a decision by the Regulator or a decision of the head of a private body;
    7. 6.3.7.
      the provisions of section 14 and 51 requiring a public body and private body, respectively, to compile a manual, and how to obtain access to a manual;
    8. 6.3.8.
      the provisions of sections 15 and 52 providing for the voluntary disclosure of categories of records by a public body and private body, respectively;
    9. 6.3.9.
      the notices issued in terms of section 22 and section 54 regarding fees to be paid in relation to requests for access; and
    10. 6.3.10.
      the regulations made in terms of section 92.
  4. 6.4.
    Members of the public can inspect or make copies of the Guide from the offices of the public and private bodies, including the office of the Regulator, during normal working hours.
  5. 6.5.

    The Guide can also be obtained:

    1. 6.5.1.
      upon request to the Information Officer;
    2. 6.5.2.
      from the website of the Regulator (https://www.justice.gov.za/inforeg/)
  6. 6.6.

    A copy of the Guide is also in the two official languages, for public inspection during normal office hours:

    1. 6.6.1.
      English
    2. 6.6.2.
      Afrikaans

7. Types of personal information collected

The Company may collect and process:

  • names and surnames;
  • usernames;
  • email addresses;
  • contact numbers;
  • physical address;
  • identification or passport numbers;
  • banking information;
  • geolocation information;
  • device information;
  • photographs and media;

8. Categories of records of STS Holdings which are available without a person having to request access

  1. 8.1.

    Categories of records and type of information available on software applications where you have a registered user account:

    • User Account including First Name, Last Name, Telephone Number, ID Number, Passport Number, Email Address, Physical Address and Banking information where applicable;
    • Notification Preferences including settings for email and/or sms notifications.

7. Purpose of processing personal information

Personal Information may be processed for:

  • account management;
  • security management;
  • marketing and sales;
  • performance of services;
  • customer communications;
  • customer support;
  • legal compliance;
  • analytics and reporting.

The Company processes Personal Information based on:

  • user consent
  • contractual necessity;
  • legitimate business interests;
  • legal obligations;
  • fraud prevention and security requirements.

9. Recipients of personal information

Personal Information may be shared with:

  • payment gateways;
  • banking institutions;
  • cloud hosting providers;
  • sales and marketing providers;
  • analytics providers;
  • communication service providers;
  • legal and regulatory authorities;
  • authorised Service Providers to STS Holdings.

The Company shall take reasonable steps to ensure such third parties implement appropriate security safeguards.

10. Cross-border transfers

Personal Information may be transferred outside South Africa where necessary for:

  • cloud hosting;
  • platform operations;
  • payment processing;
  • communications;
  • data storage;
  • sales and marketing services;
  • analytics and reporting;
  • support services.

The Company shall take reasonable steps to ensure appropriate safeguards are implemented.

11. Security safeguards

The Company implements reasonable technical and organisational safeguards including:

  • data encryption;
  • authentication controls;
  • access restrictions;
  • audit logging;
  • user account monitoring;
  • data security;
  • transaction monitoring;
  • fraud detection mechanisms;
  • firewall protections;
  • secure hosting environments.

Despite reasonable safeguards, no system can be guaranteed completely secure.

12. Retention of records

Records and Personal Information shall be retained:

  • for as long as necessary to fulfil operational purposes;
  • as required by Applicable Law;
  • for dispute resolution;
  • for fraud prevention and auditing purposes.

Records which shall be retained for a minimum of five (5) years:

  • financial records
  • audit logs
  • support records

Certain records may be retained longer where legally required.

13. Access to records in terms of PAIA

A data subject may request access to records held by the Company in accordance with PAIA.

Requests for access to records must be submitted using the prescribed form (Form 02 – Request for Access to Record) as available on https://inforegulator.org.za/paia/.

Requests must:

  • be submitted in writing;
  • provide sufficient detail to identify the requested records;
  • include proof of identity where necessary.

The Company may refuse access where permitted under Applicable Law.

14. Records held by the Company

The Company may hold records including:

  • user account records;
  • support records;
  • communication records;
  • operational records;
  • sales records;
  • marketing records;
  • audit logs;
  • compliance records;
  • contractual records;
  • financial/accounting records.
  • employee records;
  • service provider records;
  • security logs;
  • cloud infrastructure logs;
  • application monitoring logs;
  • analytics and reporting records;
  • communication metadata.

15. Request procedure

Requests for access to records or Personal Information may be submitted to:

Information Officer
Mr. Niran Munsami
Email
niran@stsafrica.com

The Company may:

  • request identity verification;
  • request additional information;
  • charge prescribed fees where permitted by Applicable Law.

Requests for access to records or Personal Information must be submitted using the prescribed forms where applicable as available on https://inforegulator.org.za/paia/.

16. Grounds for refusal of access

Access to records may be refused where:

  • disclosure would violate privacy rights of another person;
  • disclosure would compromise security;
  • records are legally privileged;
  • disclosure would prejudice commercial information;
  • disclosure would interfere with investigations;
  • refusal is permitted under PAIA or Applicable Law.

17. Data breach response

The Company shall take reasonable steps to:

  • investigate security incidents;
  • mitigate risks;
  • contain data breaches;
  • notify affected parties where required by Applicable Law.

The Company shall notify the Information Regulator and affected data subjects where required under Applicable Law.

18. Cookies and tracking technologies

The Platform may use:

  • cookies;
  • analytics tools;
  • session management technologies;
  • device identifiers.

These technologies are used for:

  • authentication;
  • functionality;
  • push notifications
  • analytics;
  • security;
  • user experience optimisation.

Additional information is available in the Data Privacy Policy.

19. Complaints

Users may submit privacy-related complaints to:

Company
STS Holdings (Pty) Ltd
Email
info@sts.holdings

Users may also lodge complaints with:

Information Regulator South Africa

20. Availability of this Manual

This Manual shall be made available:

  • on the Elite Series website;
  • within the Elite Series mobile application where applicable;
  • upon reasonable request.

21. Changes to this Manual

The Company reserves the right to amend this Manual from time to time.

Updated versions shall become effective upon publication.

Continued use of the Platform constitutes acceptance of the updated Manual.

21. Guide on how to use PAIA

A guide on how to use PAIA and how to obtain access to records in terms of PAIA is available from the Information Regulator.

Information Regulator

PAIA
https://inforegulator.org.za/paia/
Email
enquiries@inforegulator.org.za
Toll Free
0800 017 160
Address
Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191

22. Governing law

This Manual is governed by the laws of the Republic of South Africa.

© 2026 STS Holdings (Pty) Ltd. All Rights Reserved.

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