PAIA Manual

PAIA MANUAL

Prepared in terms of section 51 of the Promotion of Access to Information Act, 2 of 2000 (as amended) for Nhantsi Capital Trading (Pty) Ltd, registration number 2024/615022/07.

Date of compilation: 12 November 2026. Date of revision: not yet revised (first edition). Next review due: 12 November 2027.

1. List of acronyms and abbreviations

2. Purpose of this PAIA manual

This manual is useful for the public to:

• check the categories of records held by the Company 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 Company, by providing a description of the subjects on which the Company holds records and the categories of records held on each subject;
• know the description of the records of the Company 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 Company will process personal information, the purpose of processing and the categories of data subjects and of information relating to them;
• know the recipients or categories of recipients to whom the personal information may be supplied;
• know whether the Company has planned to transfer or process personal information outside the Republic and the recipients to whom it may be supplied; and
• know whether the Company 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

3.1 Information Officer

3.2 Deputy Information Officer

3.3 Access to information general contacts

3.4 National or head office

4. Guide on how to use PAIA and how to obtain access to the guide

4.1 The Regulator has, in terms of section 10(1) of PAIA, 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.

4.2 The Guide is available in each of the official languages and in braille.

4.3 The Guide contains the description of: the objects of PAIA and POPIA; the postal and street address, phone and fax number and, if available, email address of the Information Officer of every public body and every Deputy Information Officer of every public and private 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 Officer and from the Regulator; 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 how to lodge an internal appeal, a complaint to the Regulator and an application to court; the provisions of sections 14 and 51 requiring public and private bodies to compile manuals and how to obtain access to them; the provisions of sections 15 and 52 providing for voluntary disclosure of categories of records; the notices issued in terms of sections 22 and 54 regarding fees; and the regulations made in terms of section 92.

4.4 Members of the public can inspect or make copies of the Guide from the offices of public and private bodies, including the office of the Regulator, during normal working hours.

4.5 The Guide can also be obtained upon request to the Information Officer, or from the website of the Regulator (https://inforegulator.org.za/paia-guidelines/).

4.6 A copy of the Guide is available in at least two official languages for public inspection during normal office hours at our head office (PAIA Regulations, 2021, regulation 3). There is no charge for a copy of the Guide.

4.7 Regulator contact details:

5. Categories of records of the Company which are available without a person having to request access

A printed copy may be requested from the Information Officer. Inspection at our office is free; the prescribed reproduction fee (R2.00 per A4 page) applies to paper copies.

6. Description of the records of the Company which are available in accordance with any other legislation

The Company is not an authorised financial services provider under the Financial Advisory and Intermediary Services Act, 37 of 2002, and holds no FSP licence records.

7. Description of the subjects on which the Company holds records and categories of records held on each subject

A category being listed does not mean that access will be granted. Requests are subject to section 50 of PAIA and the grounds of refusal in Chapter 4 of Part 3 of PAIA.

8. Processing of personal information

8.1 Purpose of processing personal information

• To sell and deliver educational products and services, and administer orders, payments, refunds and complaints;
• To provide free educational resources, and administer the CFI referral offer;
• To schedule free introductory calls, confirm mentorship terms in writing and provide paid mentorship;
• To run buyers’ and live WhatsApp groups and provide product updates and support;
• To send marketing where permitted by POPIA section 69 and the CPA;
• To provide and secure the Trading Journal;
• To manage suppliers, partners and advisers;
• To keep accounting and tax records and comply with the law; and
• To protect the Company’s rights, property and security.

8.2 Description of the categories of data subjects and of the information or categories of information relating thereto

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

8.4 Planned transborder flows of personal information

Personal information is stored or processed outside the Republic by the Company’s service providers, mainly in the United States (Netlify, HighLevel, Vercel, Google, Resend), other trusted service providers that may be located outside South Africa, the United Kingdom (Supabase, London region, for the Trading Journal) and other countries where these providers or their sub-processors operate. Transfers are made only as permitted by section 72 of POPIA, including where the recipient is bound by law, binding corporate rules or a binding agreement providing adequate protection, or where the transfer is necessary to perform a contract with the data subject.

8.5 General description of information security measures to be implemented by the responsible party to ensure the confidentiality, integrity and availability of the information

• Encryption in transit (HTTPS/TLS) and encryption at rest by hosting and database providers;
• Card payments handled entirely on Yoco’s PCI-compliant checkout; no card data stored by the Company;
• Private file storage with expiring, signed download links;
• Secret keys kept server-side; least-privilege access and strong authentication for Company accounts;
• Database access rules in the Trading Journal so that members see only their own records;
• Written operator terms with service providers (POPIA sections 20 and 21);
• Security-compromise procedure, including notification to the Regulator and affected data subjects (POPIA section 22).

9. Availability of the manual

9.1 A copy of this manual is available:

• on our website, https://nhantsicapitaltrading.com, and on https://nhantsi-trading-journal.vercel.app/paia;
• at the head office of the Company for public inspection during normal business hours;
• to any person upon request and upon the payment of a reasonable amount (the prescribed fee of R2.00 per A4 page for a paper copy); and
• to the Information Regulator upon request.

9.2 A fee for a copy of the manual, as contemplated in Annexure B of the PAIA Regulations, shall be payable per each A4-size photocopy made.

10. Updating of the manual

The head of the Company will on a regular basis update this manual.

Issued by: Nqaba Nhantsi, Chief Executive Officer and Information Officer. Signature: ____________________ Date: 12 November 2026

Annexure A – How to request access, fees, refusal and remedies

A1. Form 2. A request must be made on a form that corresponds substantially with Form 2 of Annexure A to the PAIA Regulations, 2021 (available at https://inforegulator.org.za/paia-forms/), and sent to the Information Officer at nqaba@nhantsicapitaltrading.com or the physical address above. The requester must give enough detail to identify the record, state the form of access and language preferred, provide proof of identity (and authority, if acting for someone else) and state which right the requester wishes to exercise or protect and why the record is needed for it (section 53 of PAIA). The Information Officer will help anyone who needs assistance, including completing the form for a requester who cannot read or write or has a disability.

A2. Own personal information. A person who only wants their own personal information may simply email the Information Officer. This is a POPIA section 23 request and is free.

A3. Timeline. The Company will decide within 30 days and notify the requester on Form 3. The period may be extended once by up to 30 days in the circumstances in section 57. No decision within the period is a deemed refusal (section 58).

A4. Prescribed fees for private bodies (Annexure B, PAIA Regulations, 2021):

A5. Grounds for refusal. The Company may or must refuse access only on the grounds in sections 63 to 69 of PAIA, including protection of third parties’ privacy, commercial or confidential information, safety of individuals and property, legally privileged records, the Company’s own commercial information and research information, subject to the public-interest override in section 70.

A6. Remedies. The Company has no internal appeal. A requester or third party who is dissatisfied may lodge a complaint with the Information Regulator on Form 5 within 180 days of the decision (section 77A), or apply to court (section 78).