PAIA Handleiding

1. Introduction

This manual is published in terms of Section 51 of the Promotion of Access to Information Act 2 of 2000 ("PAIA"), as amended by the Protection of Personal Information Act 4 of 2013 ("POPIA"). PAIA gives effect to the constitutional right of access to any information held by a private body that is required for the exercise or protection of any rights.

This manual provides information on how members of the public may submit requests for access to records held by RoxWealth (Pty) Ltd, trading as Gemoedsrus ("the Company").

2. Details of the Private Body

3. Information Officer and Deputy Information Officer

The following persons have been designated as responsible for dealing with PAIA requests:

4. Guide on How to Use PAIA (Section 10 Guide)

The South African Human Rights Commission ("SAHRC") has compiled a guide in terms of Section 10 of PAIA to assist persons wishing to exercise their right to access information. This guide is available from the SAHRC:

• SAHRC: www.sahrc.org.za
• PAIA Hotline: 011 877 3600
• Address: Braampark Forum 3, 33 Hoofd Street, Braamfontein, Johannesburg

5. Records Available Without a PAIA Request

The following categories of records are freely available on our website or upon request, without the need to submit a formal PAIA request:

• Privacy Policy (available at /privaatheidsbeleid)
• Terms and Conditions (available at /bepalings-en-voorwaardes)
• Complaints Procedure (available at /klagteprosedure)
• This PAIA Manual
• General information about our services and product providers
• FSP licence details and FSCA registration information

6. Records Held by the Company

The Company holds records in the following categories. Note that access to records is subject to the grounds for refusal set out in PAIA.

6.1 Company Records

• Memorandum of Incorporation and company registration documents
• Minutes of directors' and shareholders' meetings
• Share register and related records
• Financial statements and annual returns

6.2 Financial Records

• Accounting records and supporting documentation
• Tax returns and assessments
• Banking records and statements
• Invoices, receipts, and payment records
• Insurance policies (company-held)

6.3 Client Records

• Client personal information and contact details
• Financial needs analyses and advice records (as required by FAIS)
• Policy documentation and quotations
• Correspondence with clients and product providers
• FICA documentation (identification and verification records)
• Complaints and dispute records

6.4 Employment and HR Records

• Employment contracts and personnel files
• Payroll and benefits records
• Performance evaluations and training records
• Disciplinary records

6.5 Operational and Technology Records

• IT system logs and security records
• Website analytics and usage data
• AI assistant (Frik) interaction logs
• Third-party service provider agreements

6.6 Regulatory and Compliance Records

• FSP licence and compliance documentation
• FAIS compliance reports
• FICA compliance records
• Regulatory correspondence (FSCA, Information Regulator)

7. Processing of Personal Information (POPIA — Section 51(1)(c))

In accordance with Section 51(1)(c) of PAIA, as inserted by POPIA, the following information is provided regarding the Company's processing of personal information:

7.1 Purpose of Processing

Personal information is processed for the purposes described in our Privacy Policy, including providing financial intermediary services, regulatory compliance, and business administration.

7.2 Categories of Data Subjects

• Clients and prospective clients
• Employees and contractors
• Service providers and suppliers
• Website visitors

7.3 Recipients of Personal Information

• Insurance product providers (PPS, Liberty Life, Sanlam, Hollard)
• Technology service providers (including development teams)
• Regulatory authorities (FSCA, SARS, Information Regulator)
• Professional advisors (auditors, lawyers)

7.4 Cross-Border Transfers

Certain technical data may be transferred to service providers in India for website development and maintenance. Appropriate safeguards are in place as described in our Privacy Policy.

7.5 Security Measures

The Company implements appropriate technical and organisational measures to protect personal information, including encryption, access controls, and regular security assessments.

8. How to Submit a PAIA Request

Requests for access to records must be submitted on the prescribed form (Form C for private bodies), obtainable from the website of the Information Regulator at https://inforegulator.org.za.

The completed form must be submitted to our Information Officer by email or post (see contact details in Section 3 above) and must include:

• The requester's full name, contact details, and identity number
• Sufficient detail to identify the record(s) requested
• The form of access required (e.g., inspection, copy, electronic copy)
• The right that the requester is seeking to exercise or protect, and an explanation of why the record is required for this purpose
• If the request is made on behalf of another person, proof of authorisation

9. Prescribed Fees

The following fees may be applicable to PAIA requests, as prescribed by the Minister in terms of Section 54 of PAIA:

9.1 Request Fee

A non-refundable request fee of R50.00 is payable by a requester who is not a personal requester (i.e., a person requesting access to their own personal information is exempt from this fee).

9.2 Access Fee

An access fee may be charged for the search, preparation, and reproduction of records. The Information Officer will notify the requester of the applicable fee before processing the request. Access fees are determined in accordance with the prescribed tariff.

9.3 Deposit

Where the search and preparation of a record requires more than 6 hours, a deposit of one-third of the estimated access fee may be required.

10. Decision on Request

The Information Officer will process a PAIA request within 30 days of receipt. This period may be extended by a further 30 days if:

• The request is for a large number of records
• The search requires a search through a large volume of records
• Consultation with a third party or another private body is necessary

The requester will be notified in writing of the decision to grant or refuse the request, including reasons for any refusal.

11. Grounds for Refusal

The Company may refuse a request for access to records on any of the following grounds as set out in Chapter 4 of PAIA:

• Protection of third-party personal information (Section 63)
• Protection of commercial information of a third party (Section 64)
• Protection of confidential information of a third party (Section 65)
• Safety of individuals and property (Section 66)
• Legally privileged records (Section 67)
• Commercial information of the private body (Section 68)
• Research information of a third party or the private body (Section 69)
• Mandatory protection of records in the interest of the Republic (Section 70)

Note: These grounds are subject to the public interest override in Section 70 of PAIA, which may require disclosure even where a ground for refusal exists.

12. Remedies Available if Request is Refused

If a request for access to records is refused, the requester may:

• Lodge an internal appeal (where applicable)
• Apply to the Information Regulator for appropriate relief
• Apply to a court for appropriate relief within 180 days of notification of the decision

Complaints may be directed to the Information Regulator:

• Email: PAIAComplaints@inforegulator.org.za
• Website: https://inforegulator.org.za

13. Availability of This Manual

This manual is available for inspection at the Company's registered office during normal business hours, and is published on the Company's website at /paia-handleiding. A copy is also available from the Information Regulator's website.

14. Updates to This Manual

This manual will be reviewed and updated as and when necessary to reflect changes in legislation, business operations, or contact details. The "Last Updated" date above reflects the most recent revision.