PAIA MANUAL

Prepared in terms of Section 51 of the Promotion of Access to Information Act 2 of 2000 (as amended)

1. LIST OF ACRONYMS AND ABBREVIATIONS

• PAIA: Promotion of Access to Information Act 2 of 2000
• POPIA: Protection of Personal Information Act 4 of 2013
• Regulator: The Information Regulator (South Africa)
• The Company: Polyphrōn t/a Polynoesis (Pty) Ltd

2. PURPOSE OF PAIA MANUAL

This PAIA Manual is useful for the public to:

• Check the categories of records held by a body that are available without requiring a person to submit a formal PAIA request.
• Understand how to submit a request for access to a body record.
• Know the description of the records of the body which are available in accordance with other legislation.

3. KEY CONTACT DETAILS

Name of Body:

Polyphrōn t/a Polynoesis (Pty) Ltd

Registration Number:

2025/971927/07

Head of Body / Information Officer:

Chris House

Physical Address:

Cape Town, Western Cape, South Africa, 7441

Email:

privacy@polyphronai.com

4. GUIDE ON HOW TO USE PAIA

The Regulator has updated and made available the existing Guide on how to use PAIA. It is available in all official languages and in Braille. The Guide can be obtained upon request from the Information Regulator:

Website: https://inforegulator.org.za

Email: enquiries@inforegulator.org.za

5. CATEGORIES OF RECORDS AVAILABLE WITHOUT REQUEST

The following records are automatically available on the Company website or upon request without the need to submit a formal Form 2 request:

• Newsletters and Marketing Materials
• Company Privacy Protocol (SALT)
• Product Brochures and Pricing

6. RECORDS AVAILABLE IN ACCORDANCE WITH OTHER LEGISLATION

Where applicable to our operations, records are kept in accordance with the following legislation:

• Companies Act 71 of 2008
• Income Tax Act 58 of 1962
• Value Added Tax Act 89 of 1991
• Basic Conditions of Employment Act 75 of 1997
• Protection of Personal Information Act 4 of 2013
• Electronic Communications and Transactions Act 25 of 2002

7. DESCRIPTION OF THE SUBJECTS AND CATEGORIES OF RECORDS

Subject: Human Resources

Employment contracts, payroll records, leave records, and internal policies.

Subject: Financials

Annual financial statements, banking records, asset registers, invoices, and tax returns.

Subject: Clients/Customers

Entity data (as defined in SALT Protocol), transaction records, billing coordinates, correspondence.

8. PROCESSING OF PERSONAL INFORMATION (POPIA)

Purpose of Processing

As outlined in the SALT Privacy Protocol, the Company processes information for:

• Contractual necessity (Service delivery)
• Legal obligations (Tax, KYC)
• Legitimate interests (System optimisation, security)

Categories of Data Subjects

Merchants ("Entities"), Employees, Service Providers.

Planned Transborder Flows

The Company may transfer information to foreign countries for hosting and processing purposes, subject to adequate data protection agreements (e.g., GDPR adequacy or Standard Contractual Clauses).

General Description of Information Security Measures

The Company employs the "Fort Knox Protocol," utilising encryption, access controls, and regular monitoring to ensure the confidentiality, integrity, and availability of information.

9. HOW TO REQUEST ACCESS TO A RECORD

To request access to a record, please:

1. Complete Form 2 (Request for Access to Record).
2. Submit the form to the Information Officer at privacy@polyphronai.com.
3. Pay the prescribed request fee (if applicable).

The Company will respond within 30 days. Access may be refused on the grounds outlined in Chapter 4 of PAIA (e.g., the mandatory protection of a third party's commercial information).

10. FEES

Request Fee:

R140.00 (standard fee for private bodies).

Access Fee:

Calculated based on time spent searching/preparing and the format of the record (e.g., photocopying costs).

11. CONTACT

Last updated: 2026-01-02