Effective Date: 2025-02-03

1. Introduction

This manual is prepared in accordance with Section 51 of the Promotion of Access to Information Act, 2 of 2000 (PAIA). It provides an outline of the types of records held by Interstellio IO (Pty) Ltd ("Interstellio") and the procedures to request access to such records.

2. Company details

• Company Name: Interstellio IO (Pty) Ltd.
• Registration Number: 2019/606622/07
• Physical Address: 19 Indianapolis Street, Kyalami Park, Kyalami, Gauteng, 1684, South Africa
• Postal Address: Postnet Suite 72, Private Bag x11, Halfway House, Gauteng, 1685, South Africa
• Telephone Number: +27 12 883 1824
• Email: legal@interstellio.io
• Website: https://www.interstellio.com

3. Information Officer

• Name: Hieronymus Crouse
• Email: rony@interstellio.io
• Phone: +27 12 883 1824

4. Guide on how to use the PAIA ACT

The Information Regulator has, in terms of section 10(1) of the PAIA Act, provided a guide on how to use the PAIA Act (“the Guide”).

It is designed to be easily understood by a person who wishes to exercise any right provided for in the PAIA Act or in the Protection of Personal Information Act 4 of 2013 (“the POPI Act”).

The Guide is available in all of the official languages as well as in braille, and contains a description of, amongst other things:

• the objects of the PAIA Act and the POPIA Act;
• the postal and street address, phone and, if available, electronic mail address of the Information Officer of every public body,
• the manner and form of a request for access to a record of a public or private body;
• the assistance available from the Information Regulator in terms of the PAIA and POPIA Acts;
• the remedies available regarding an act or failure to act in respect of a right or duty conferred or imposed by the PAIA and POPIA Acts; and
• fees to be paid for requests for access to information.

During normal working hours, members of the public can inspect or make copies of the Guide from the offices of both private and public bodies, including the office of the Information Regulator.

PAIA Forms - Information Regulator (inforegulator.org.za)

The Guide can also be obtained as follows:

• upon request to an Information Officer or
• from the website of the Information Regulator at PAIA Guidelines - Information Regulator (inforegulator.org.za)

5. How to request access to records held by Interstellio

Requests for access to records held by the Interstellio must be made on the request form entitled “Form 2: Request for Access to Record [Regulation 7]”, which is available from our website https://www.interstellio.io/legal and head office, as well the website of the Information Regulator at PAIA Forms - Information Regulator (inforegulator.org.za).

A request fee may be payable. The schedule of fees can be accessed on page 31 of the document available at: https://www.justice.gov.za/legislation/notices/2021/20210827-gg45057gon757-PAIAregulations.pdf

You can submit a request without paying the fee, but please note that the prescribed fees must be paid before the request is processed.

Requests for access to records must be directed to the Interstellio Information Officer at the address or email address provided earlier in section 3 of this document.

The requester must furnish adequate details on the request form to facilitate the Information.

The officer will identify the record and the requester. The requester should also specify the required form of access and whether he or she wishes to be informed in any other manner, as well as provide the necessary details to facilitate such notification.

If you know which department within Interstellio holds the records you are requesting, please indicate this. If you are uncertain about which division maintains the records, kindly provide as much detail as possible about the records to facilitate our search and avoid any potential delays.

The requester must identify the right he or she seeks to exercise or protect and explain why the requested record is required to do so.

If a request is made on behalf of an individual, the requester must subsequently provide evidence, to the satisfaction of the Information Officer, of the capacity in which the requester is submitting the request.

Form 2 is the standard form for making requests. Failure to use this form or provide sufficient information may result in your request being refused or delayed.

Please note that all requests submitted to Interstellio will be evaluated and considered in accordance with the PAIA Act and the POPIA Act. The publication of this manual and the description of the categories and subject matter of information held by Interstellio do not give rise to any rights (in contract or otherwise) to access such information or records except in terms of the PAIA Act.

6. Voluntary Disclosure

Interstellio has not published a notice in terms of Section 52(2) of the PAIA Act; however, it should be noted that the information relating to Interstellio and its services is freely available on the Interstellio website. Certain other information relating to the Interstellio is also made available on our website from time to time.

Further information in the form of marketing brochures, advertising material and other public communication is made available from time to time.

7. Records Available in Terms of Any Other Legislation

Information is available in terms of the following legislation to the persons or entities specified in such legislation:

• Companies Act 71 of 2008
• Income Tax Act 58 of 1962
• Value Added Tax Act 89 of 1991
• Tax Administration Act 28 of 2011
• Labour Relations Act 66 of 1995
• Basic Conditions of Employment Act 75 of 1997
• Employment Equity Act 55 of 1998
• Skills Development Levies Act 9 of 1999
• Unemployment Insurance Act 30 of 1966
• Regulation of Interception of Communications and Provision of Communication-related Information Act 70 of 2002
• Criminal Procedure Act 56 of 1955
• Electronic Communications and Transactions Act 25 of 2002
• Occupational Health and Safety Act & Regulations: Act 85 of 1993

8. Records Held by Interstellio

Interstellio maintains records on the following categories and subject matters. However, recording a category or subject matter in this Manual does not imply that a request for access to such records would be honoured. Any access requests will be evaluated on a case-by-case basis following the provisions of the PAIA Act.

9.1. Internal Records

The following are records about Interstellio’s own affairs and those of its divisions, subsidiaries and associated companies:

• Memorandum and Articles of Association.
• Financial records.
• Operational records.
• Licences.
• Intellectual property.
• Internal correspondences.
• Product records.
• Statutory records.
• Internal policies and procedures.
• Records held by officials of Interstellio.

9.2. Personnel Records

Personnel refers to any person who works for or provides services to or on behalf of Interstellio and receives or is entitled to receive any remuneration and any other person who assists in carrying out or conducting the business of Interstellio. This includes, without limitation, directors, executive directors, non-executive directors, all permanent, temporary and part-time staff, as well as contract workers. Personnel records include the following:

• Any personal records provided to the Interstellio by their personnel.
• Any records a third party has provided Interstellio about their personnel.
• Conditions of employment and other personnel-related contractual and quasi-legal records.
• Internal evaluation records.
• Other internal records and correspondence.

9.3. Customer Records

Please be aware that Interstellio seriously protects its customers’ confidential information. Please motivate any request for customer information very carefully with regard to Sections 63 to 67 of the PAIA Act.

Customer information includes the following:

• Any records a customer has provided to the Interstellio or a third party acting for or on behalf of the Interstellio.
• Contractual information.
• Customer needs assessments.
• Personal records of customers.
• Other research conducted with respect to customers.
• Any records a third party has provided to the Company about customers.
• Confidential, privileged, contractual and quasi-legal records of customers.
• Customer evaluation records.
• Customer profiling.
• Performance research conducted on behalf of customers or about customers.
• Any records a third party has provided to the Company either directly or indirectly.
• Records generated by or within the Company pertaining to customers, including transactional records.

9.4. Marketing Records

Records are kept concerning other parties, including contractors, suppliers, joint ventures, service providers, and general market conditions. These parties may also possess records that can be said to belong to Interstellio.

The following records fall under this category:

• Market Information.
• Public Customer Information.
• Product Brochures.
• Leads records.
• Social media accounts and history.
• Performance Records.
• Product Sales Records.
• Marketing Strategies.
• Customer Database.
• Sales channel documents.

9.5. Other Parties Records

Records are kept regarding other parties, including, without limitation, contractors, suppliers, joint ventures, service providers, and general market conditions. Such parties may also possess records that can be said to belong to Interstellio.

The following records fall under this category:

• Personnel, customer or Interstellio records which are held by another party as opposed to being held by the Interstellio.
• Records held by the Company pertaining to other parties, including financial records, correspondence, contractual records, electronic mail, logs, cached information, records provided by the other party, and records third parties have provided about the contractors/suppliers or customers.

9.6. Other Records

Further records are held, including:

• Information relating to Interstellio’s own commercial activities.
• Research carried out on behalf of a client by Interstellio or commissioned from a third party for a customer.
• Research information belonging to Interstellio, whether carried out or commissioned by a third party.

10. Protection of Access to Information

10.1. Purpose of Processing

Interstellio will use your personal information only for the purposes for which it was collected and agreed upon with you. In addition, where necessary, your information may be retained for legal or research purposes.

For example:

• To gather contact information.
• To enable the execution of contracts.
• To confirm and verify your identity or to verify that you are an authorised user for security purposes.
• For the detection and prevention of fraud, crime, money laundering or other malpractice.
• To comply with legal obligations imposed on the Company .
• To conduct market or customer satisfaction research or for statistical analysis.
• For audit and record-keeping purposes.
• In connection with legal proceedings.

10.2. Description of categories of data subjects and of the information or categories of information relating thereto

Interstellio may possess records relating to suppliers, shareholders, contractors service providers, staff and clients:

Entity Type	Personal Information Processed
Customers	Names of customer and contact persons. Physical and Postal address and contact details. Financial information. Bank details. Registration Number. Founding documents. Tax related information (for example VAT numbers). Authorised signatories, beneficiaries, ultimate beneficial owners. IP addresses assigned to customers. Company account IDs, usernames, email addresses. Source and Sestination IP addresses.
Intermediary/Advisor	Names of contact persons. Name of Legal Entity. Physical and Postal address and contact details. Financial information. Registration Number. Founding documents. Tax related information. Authorised signatories, beneficiaries, ultimate beneficial owners.
Third Party Providers	Names of contact persons. Name of Legal Entity. Physical and Postal address and contact details. Financial information. Registration Number. Founding documents. Tax related information. Authorised signatories, beneficiaries, ultimate beneficial owners.
Employees/Directors	Gender. Pregnancy. Marital Status. Age. Language. Education information. Financial Information. Employment History. ID number. Physical and Postal addresses. Contact details.

10.3. The recipients or categories of recipients to whom the personal information may be supplied.

Interstellio may supply the Personal Information to service providers who render the following services:

• Capturing and organising of data.
• Storing of data.
• 3rd party Service providers that facilitate services for our customers.
• Lawyers, debt collection companies, court officials and tracing service providers.
• Credit bureaus.
• Law enforcement agencies and the South African Revenue Services or as otherwise directed by a court order.

11. Planned transborder flows of personal information

Where transborder flows of Personal Information is required, Interstellio will assure to:

• Take steps to determine whether you can transfer personal information about a data subject to a third party in a foreign country.
• Confirm that at least one of the additional requirements has been met.
• The third party is subject to a law, binding corporate rules or binding agreement that provide adequate personal information protection.
• The data subject consented to transferring personal information to a third party in a foreign country.
• The transfer is necessary to perform a contract between the data subject and Interstellio or to implement pre-contractual measures taken regarding the data subject's request.
• The transfer is essential for the completion or execution of a contract between your company and the third party, in the interests of the data subject.
• The transfer is for the benefit of the data subject, and obtaining the consent of the data subject to that transfer is not reasonably practical. If it were practical, the data subject would have provided consent.

12. Security Measures Implemented by Interstellio

Interstellio continuously establishes and maintains appropriate, reasonable technical and organisational measures to ensure that the integrity of the personal information in its possession or under its control is secure and that such information is protected against unauthorised or unlawful processing, accidental loss, destruction or damage, alteration or access by having regard to the requirements set forth in law, in industry practice and generally accepted information security practices and procedures within Interstellio.