PAIA Manual

Issued by: Toker Effective Date: 28 June 2026 Document Version: 1.0-draft

This Manual is published by Toker in compliance with section 51 of the Promotion of Access to Information Act 2 of 2000 ("PAIA") read with the PAIA Regulations, 2002 (Government Notice R. 187 of 15 February 2002, as amended by Government Notice R. 1244 of 22 September 2003 and Government Notice R. 1044 of 1 September 2017). It explains how to request access to records held by Toker, the fees payable, and the grounds on which access may be refused.

This Manual is not the same as the Privacy Policy (01-privacy-policy.md). The Privacy Policy governs your personal information (POPIA). This Manual governs access to records held by Toker (PAIA), which may include records that are not personal information.

1. Contact details (PAIA s.51(1)(a))

Toker has designated the following persons to receive PAIA requests and to assist requesters:

1.1 Information Officer

1.2 Deputy Information Officer

1.3 General contact

2. Guide by the Information Regulator (PAIA s.51(1)(b))

A guide to PAIA has been published by the Information Regulator of South Africa in terms of section 10 of PAIA. The guide contains information on:

• The objects of PAIA;
• The postal address, physical address, telephone and email of the Information Regulator;
• How to obtain access to a manual of a private body;
• How to lodge a complaint with the Information Regulator;
• The voluntary nature of disclosure by public and private bodies.

The guide is available:

3. Records available in terms of any other legislation (PAIA s.51(1)(d))

Toker holds records in terms of the following legislation, which may be subject to disclosure under that legislation:

4. Subjects and categories of records held (PAIA s.51(1)(e))

Toker holds records in the following categories. This list is illustrative, not exhaustive.

4.1 Corporate records

• Certificate of incorporation
• Memorandum of incorporation
• Register of directors and officers
• Register of members
• Minutes of board meetings and shareholder meetings
• Annual financial statements
• Accounting records (general ledger, trial balance, bank statements, invoices issued and received)
• Tax returns and supporting schedules
• VAT returns
• Audit reports (internal and external)
• Banking records
• Insurance policies

4.2 Personnel records

• Employment contracts
• Personnel files
• Payroll records
• Leave records
• Performance management records
• Disciplinary records
• UIF / COIDA records

4.3 Platform operational records

• User accounts and profiles (subject to POPIA; access governed by Privacy Policy §11.1)
• Shop listings (subject to the relevant shop owner's intellectual-property rights)
• Day Pass transactions
• Refund records
• Reviews
• Audit logs (7-year retention)
• Request logs (12-month retention)
• Incident response records
• Operator agreements
• Operator register (subprocessors)
• Backup records

4.4 Communications records

• Emails to and from support@go-toker.com, privacy@go-toker.com, legal@go-toker.com, security@go-toker.com, shop-support@go-toker.com, refunds@go-toker.com
• Support tickets
• Internal incident reports

4.5 Technical records

• Source code (proprietary to Toker; not subject to disclosure except as required by law)
• Architecture diagrams (proprietary; not subject to disclosure except as required by law)
• Security audit reports (subject to confidentiality protections)
• Vendor agreements

5. The request procedure (PAIA s.51(1)(e) and Chapter 3)

5.1 Who may request

Any person may request access to records of Toker. The person need not be a citizen of South Africa or a resident of South Africa.

5.2 Form of request

A request must be made on Form C (annexed to the PAIA Regulations, Government Notice R. 187 of 15 February 2002, as amended). Form C is available:

• At the end of this Manual (see §13);
• From the Information Regulator at the address in §2 above;
• From the Information Officer's email address above.

The request must:

• Be in writing (we recommend email to information.officer@go-toker.com);
• Provide sufficient details to identify the record;
• Identify the requester's identity (full name, ID or passport number, contact details);
• Specify the form of access required (copy, inspection, etc.);
• Specify the postal address or email address for the response.

5.3 Form of access

Records may be requested in the form of:

• A printed copy;
• An electronic copy (PDF or equivalent);
• Inspection at the Information Officer's office (by appointment only);
• A transcript of an audio or video record.

5.4 Time limits

5.5 Fees

Persons who are exempt from paying the request fee: A requester who is a person whose annual income, after tax, is less than R15 000 (fifteen thousand rand) per annum, on production of a sworn affidavit to that effect, is exempt from paying the request fee. The Information Officer may, in their discretion, waive any fee.

5.6 Grounds for refusal (PAIA Chapter 4)

Access to a record may be refused on any of the grounds set out in PAIA Chapter 4, including:

• Protection of privacy of a third party (s.63);
• Protection of commercial information of a third party (s.64);
• Protection of confidential information of a third party (s.65);
• Protection of safety of individuals, and protection of property (s.66);
• Protection of records privileged from production in legal proceedings (s.67);
• Protection of research information (s.69);
• Protection of commercial activities of the private body (s.68).

The Information Officer will:

• Notify the requester of the refusal and the grounds;
• Notify the requester of the right to appeal to the Information Regulator;
• Notify any third party whose interests may be affected.

5.7 Internal appeal

A requester may appeal an Information Officer's decision to the Head of Toker (legal@go-toker.com) within 30 calendar days of receiving the decision. The Head will respond within 30 calendar days.

5.8 External appeal to the Information Regulator

If the internal appeal is unsuccessful, the requester may appeal to the Information Regulator within 180 calendar days of receiving the internal appeal decision, in the form of Form D (annexed to the PAIA Regulations).

6. Voluntary disclosure (PAIA s.51(1)(f))

The following records are voluntarily disclosed by Toker and are available without a formal PAIA request:

7. Availability of this Manual (PAIA s.51(3))

This Manual is available:

• On the Platform at https://go-toker.com/paia;
• At the Information Officer's office (by appointment);
• On request to the Information Officer (free of charge);
• To the Information Regulator on request.

A copy is filed with the Information Regulator.

8. Changes to this Manual

We may update this Manual from time to time. When we make a material change:

• We will update the "Last Updated" date at the top of this document;
• We will post a notice on the Platform;
• We will file the updated Manual with the Information Regulator within 14 days of the change.

9. Contact

10. Form C — Request for Access to Record

The official PAIA Form C is published in Government Notice R. 187 of 15 February 2002 as amended. It is reproduced here for convenience. In the event of any inconsistency between this reproduction and the official form, the official form prevails. Download the official form from https://www.inforegulator.org.za/.

Form C

``` REPUBLIC OF SOUTH AFRICA PROMOTION OF ACCESS TO INFORMATION ACT 2 OF 2000 (section 53(1)) REQUEST FOR ACCESS TO RECORD OF A PRIVATE BODY

To: The Information Officer

I, the undersigned,

Full name: ___________________________________________ ID / Passport: ___________________________________________ Postal addr: ___________________________________________ Telephone: ___________________________________________ Email: ___________________________________________

Hereby request, in terms of section 53(1) of PAIA, access to the following record(s):

1. Description of record: ________________________________ Reference number (if known): __________________________ Any further particulars: ______________________________

1. Form of access (mark with X): [ ] Printed copy [ ] Electronic copy (PDF) [ ] Inspection at the Information Officer's office [ ] Transcript of audio/video record [ ] Other (specify): ________________________________

1. Manner of access (mark with X): [ ] Posted to the address above [ ] Emailed to the email above [ ] Collection in person (by appointment) [ ] Other (specify): ________________________________

1. Particulars of the right to be exercised or protected: (If providing access to the record will affect a third party, explain why the record is required to exercise or protect that right.) _____________________________________________________ _____________________________________________________

1. Notice of decision: (Mark with X whether you wish to be informed of the decision in a particular manner.) [ ] In writing (posted) [ ] In writing (emailed) [ ] Other (specify): ________________________________

1. Fees: I understand that:
2. A request fee of R50.00 is payable on submission of this request;
3. Access fees are payable before the record is released;
4. I may be exempt from the request fee if my annual income (after tax) is below R15 000.00, on production of a sworn affidavit.

Signed at ____________________ on this _______ day of _____________ 20___.

Signature: ______________________________________________

CAPACITY (mark with X): [ ] Requester personally [ ] Requester on behalf of another person (attach authority) [ ] Requester on behalf of a public body ```

*This Manual is governed by the laws of the Republic of South Africa.* *Document version 1.0-draft — pending South African legal counsel sign-off.*