Legal · Nhantsi Capital Trading

PAIA Manual

Compiled 12 November 2026 · Next review due 12 November 2027 · Nhantsi Capital Trading (Pty) Ltd, registration number 2024/615022/07

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

AbbreviationMeaning
“CEO”Chief Executive Officer
“DIO”Deputy Information Officer
“IO”Information Officer
“Minister”Minister of Justice and Correctional Services
“PAIA”Promotion of Access to Information Act, 2 of 2000 (as amended)
“POPIA”Protection of Personal Information Act, 4 of 2013
“Regulator”Information Regulator
“Republic”Republic of South Africa
“the Company”Nhantsi Capital Trading (Pty) Ltd, trading as Nhantsi Capital Trading

2. Purpose of this PAIA manual

This manual is useful for the public to:

3. Key contact details for access to information

3.1 Information Officer

NameNqaba Nhantsi
DesignationChief Executive Officer (head of the private body)
Date of appointment1 January 2024
Registration number with the Regulator2026-071919 (registered 12 November 2026)
Telephone+27 76 887 0951
Emailnqaba@nhantsicapitaltrading.com

3.2 Deputy Information Officer

NameNone appointed. Nqaba Nhantsi is the only Information Officer; send all requests to him.

3.3 Access to information general contacts

3.4 National or head office

Registered nameNhantsi Capital Trading (Pty) Ltd (registered with the Information Regulator as NHANTSI CAPITAL TRADING, private company)
Registration number2024/615022/07
Postal address277, Metropolitan Office Park, 281 Cape Rd, Greenacres, Gqeberha, 6001, South Africa
Physical address277, Metropolitan Office Park, 281 Cape Rd, Greenacres, Gqeberha, 6001, South Africa
Telephone+27 76 887 0951
FaxNone
Emailnqaba@nhantsicapitaltrading.com
Websiteshttps://nhantsicapitaltrading.com and https://nhantsi-trading-journal.vercel.app
Office hours for inspection09:00 to 16:00, Monday to Friday, excluding public holidays, by appointment

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:

Information Regulator (South Africa)
Websitehttps://inforegulator.org.za
Online complaints (eServices portal)https://eservices.inforegulator.org.za
POPIA complaints emailPOPIAComplaints@inforegulator.org.za
PAIA complaints emailPAIAComplaints@inforegulator.org.za
General enquiriesenquiries@inforegulator.org.za
Telephone010 023 5200
Physical addressWoodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191
Postal addressP.O. Box 31533, Braamfontein, Johannesburg, 2017

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

Category of recordsTypes of recordAvailable on websiteAvailable upon request
Public informationThis PAIA Manual; Privacy Policy; Cookie Notice; Website Terms of Use; Risk Disclosure; Course Terms and Refund Policy; Affiliate and Earnings DisclosureYesYes
Product informationProduct descriptions, prices and the library catalogue and price listYesYes
Marketing and educationPublic website pages, public social-media content and press materialYesYes

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

Category of recordsApplicable legislation
Company records (Memorandum of Incorporation, registers, minutes, annual returns)Companies Act, 71 of 2008
Tax recordsIncome Tax Act, 58 of 1962; Tax Administration Act, 28 of 2011 (the Company is not registered for VAT)
Consumer transaction, cooling-off, refund and direct-marketing opt-out recordsConsumer Protection Act, 68 of 2008
Electronic transaction records and online-supplier disclosuresElectronic Communications and Transactions Act, 25 of 2002
Personal-information processing records, data-subject requests and security-compromise recordsProtection of Personal Information Act, 4 of 2013
PAIA requests and this manualPromotion of Access to Information Act, 2 of 2000
Copyright and trade-mark recordsCopyright Act, 98 of 1978; Trade Marks Act, 194 of 1993
Employment records (if and when the Company employs staff)Basic Conditions of Employment Act, 75 of 1997; Labour Relations Act, 66 of 1995; Employment Equity Act, 55 of 1998; Unemployment Insurance Act, 63 of 2001; Skills Development Levies Act, 9 of 1999; Compensation for Occupational Injuries and Diseases Act, 130 of 1993; Occupational Health and Safety Act, 85 of 1993
Records relating to the Company’s own trading accountFinancial Intelligence Centre Act, 38 of 2001 and tax law, to the extent applicable

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

Subjects on which the Company holds recordsCategories of records
Company and statutoryIncorporation documents, Memorandum of Incorporation, directors’ and shareholders’ records, resolutions, CIPC filings, Information Officer registration
Finance and taxAccounting records, invoices, bank statements, financial statements, tax returns, Yoco payment reports
Customers and ordersNames, email addresses, products bought, order and payment references, delivery and download records, refund and complaint records
Leads and free resourcesFree-book, trader-test, indicator and live-group sign-ups, including CFI account numbers and phone numbers where provided; marketing consents and opt-outs
MentorshipFree introductory call bookings, contact details, the client’s description of topics, call notes, written mentorship terms and payment records
CommunityRecords of buyers’ and live WhatsApp group membership and group administration
Referral partnershipsIntroducing-broker agreement with CFI and rebate statements and referred-client reports from CFI’s partner portal
Trading JournalMember accounts, journal content and system logs, as described in the Trading Journal Privacy Policy
Intellectual property and productsManuscripts, book and library files, indicator code, course materials, trade-mark and copyright records
Own tradingStatements and records of the Company’s own trading accounts
Suppliers and advisersContracts, invoices and correspondence with service providers and professional advisers
Legal and compliancePolicies, legal opinions, regulatory correspondence, disputes
Information technologySystem configuration, access-control and security records
Employment (if any)Contracts, payroll and statutory records

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

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

Categories of data subjectsPersonal information that may be processed
CustomersName, email address, phone number (where given), purchase and payment records (not full card details), correspondence
Leads and free-resource usersName, email address, phone number, CFI account number, trader-test answers and result, consents and opt-outs
Mentorship clientsName, email, phone number, booking details, messages, call notes, written terms and payment records
WhatsApp group membersWhatsApp name, phone number, profile photo and messages
Trading Journal membersAs described in the Trading Journal Privacy Policy
Website visitorsIP address, browser and device information, pages requested
Directors and shareholdersIdentity and contact details, company and tax records
Suppliers, partners and advisersNames, contact details, contracts, banking and payment records
Employees and contractors (if any)Identity, contact, tax, payroll and employment records

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

Category of personal informationRecipients or categories of recipients
Payment informationYoco Technologies (Pty) Ltd (payment provider)
Customer, lead and booking recordsNetlify, Inc. (hosting and data storage); HighLevel, Inc. (CRM; marketing tags only where the person opted in); trusted email delivery and secure cloud file-storage providers, which may be located outside South Africa
Referral confirmations (CFI account number)CFI Financial (Pty) Ltd (FSCA-authorised financial services provider, FSP No. 53711), and the CFI group company that holds the referred client’s account, only as needed to confirm referrals
WhatsApp group dataWhatsApp (Meta Platforms)
Trading Journal dataSupabase, Inc.; Vercel Inc.; Resend; Yoco, as described in the Journal Privacy Policy
Website technical dataNetlify, Inc.; Google LLC (Google Fonts)
Financial and tax recordsAccountants, auditors and the South African Revenue Service
Any category, where requiredAttorneys, regulators, courts and law-enforcement agencies, as the law requires

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

9. Availability of the manual

9.1 A copy of this manual is available:

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):

ItemDescriptionAmount
1Request fee (not payable by a personal requester)R140.00
2Photocopy of A4-size pageR2.00 per page or part thereof
3Printed copy of A4-size pageR2.00 per page or part thereof
4Copy in computer-readable form on flash drive (provided by requester) / on compact disc (provided by requester / provided to requester)R40.00 / R40.00 / R60.00
5–6Transcription and copies of visual imagesService provider’s quotation
7Transcription of an audio record, per A4 pageR24.00
8Copy of an audio record on flash drive (provided by requester) / on compact disc (provided by requester / provided to requester)R40.00 / R40.00 / R60.00
9Search and preparation, per hour or part of an hour, excluding the first hourR145.00, to a maximum of R435.00
10Deposit, if search exceeds six hoursOne third of the amount payable for items 2 to 8
11Postage, email or other electronic transferActual expense, if any

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).