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PAIA Manual

PAIA Manual

Last updated: March 2026

This manual is published in accordance with 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 grants the public the right to access information held by private and public bodies, subject to certain limitations aimed at the reasonable protection of privacy, commercial confidentiality, and the effective governance of such bodies. This manual is intended to assist any person wishing to exercise their right of access to information held by RealTeasy (Pty) Ltd, trading as PetGuru.

1. Details of the Private Body

  • Registered Name: RealTeasy (Pty) Ltd
  • Trading As: PetGuru
  • Website: petguru.co.za
  • Country of Registration: Republic of South Africa

2. Information Officer

The Information Officer, appointed in terms of Section 55 of POPIA, is responsible for facilitating requests for access to information and ensuring PAIA and POPIA compliance.

3. Guide on How to Use PAIA

The Information Regulator of South Africa has compiled a guide in terms of Section 10 of PAIA to assist individuals wishing to exercise their right of access to information. This guide is available from:

4. Records Available in Terms of Other Legislation

RealTeasy (Pty) Ltd may hold records in terms of the following legislation. This list is not exhaustive and is provided for reference purposes only:

4.1 Company & Tax Legislation

  • Companies Act 71 of 2008
  • Close Corporations Act 69 of 1984
  • Income Tax Act 58 of 1962
  • Value-Added Tax Act 89 of 1991
  • Tax Administration Act 28 of 2011

4.2 Employment Legislation

  • 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 Act 97 of 1998
  • 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

4.3 Consumer & Electronic Commerce Legislation

  • Consumer Protection Act 68 of 2008
  • Electronic Communications and Transactions Act 25 of 2002
  • National Credit Act 34 of 2005

4.4 Data Protection Legislation

  • Protection of Personal Information Act 4 of 2013 (POPIA)
  • Promotion of Access to Information Act 2 of 2000 (PAIA)
  • Regulation of Interception of Communications and Provision of Communication-Related Information Act 70 of 2002 (RICA)

4.5 Animal & Industry-Specific Legislation

  • Animals Protection Act 71 of 1962
  • Performing Animals Protection Act 24 of 1935
  • National Environmental Management: Biodiversity Act 10 of 2004 (NEMBA)
  • Foodstuffs, Cosmetics and Disinfectants Act 54 of 1972
  • Fertilizers, Farm Feeds, Agricultural Remedies and Stock Remedies Act 36 of 1947

4.6 Financial Legislation

  • Financial Intelligence Centre Act 38 of 2001 (FICA)
  • Prevention of Organised Crime Act 121 of 1998
  • Broad-Based Black Economic Empowerment Act 53 of 2003

5. Categories of Records Held

The following categories describe the types of records held by RealTeasy (Pty) Ltd in relation to its operations as PetGuru. The availability of a particular record for access is subject to the grounds of refusal set out in PAIA (Sections 62 to 70).

5.1 Company Records

  • Certificate of incorporation and registration documents
  • Memorandum of Incorporation (MOI)
  • Minutes of directors' and shareholders' meetings
  • Share register and shareholder agreements
  • Annual financial statements and audit reports

5.2 Financial Records

  • Accounting records, invoices, and receipts
  • Banking records and statements
  • Tax returns and supporting documentation
  • VAT records
  • Asset registers
  • Marketplace transaction records and commission statements

5.3 Human Resources Records

  • Employment contracts and offer letters
  • Payroll records and salary information
  • Leave records
  • Performance reviews and disciplinary records
  • PAYE, UIF, and SDL records
  • Workplace policies and procedures

5.4 Client & User Records

  • User account registration details
  • User profile information and preferences
  • Pet profiles and associated records
  • Marketplace purchase and order history
  • Listing and advertisement records
  • Correspondence and support tickets
  • Verification and onboarding documents (identity and registration documents, and selfies submitted for identity verification)
  • Identity-verification records (hashed ID number, derived date of birth / gender / citizenship, biometric-consent records, and automated verification check results)
  • Reviews and testimonials

5.5 Merchant & Seller Records

  • Merchant registration and verification documents
  • Product and service listing records
  • Transaction and payout records
  • Commission and settlement statements
  • Merchant compliance and performance records

5.6 Operational & Technical Records

  • Website and platform technical infrastructure records
  • Security logs and access control records
  • Data processing and backup records
  • Intellectual property records (trademarks, domain registrations)
  • Software licences and vendor agreements
  • Cookie and analytics data

5.7 Legal & Compliance Records

  • Contracts with suppliers, service providers, and partners
  • Insurance policies and claims
  • Dispute and complaint records
  • Regulatory correspondence
  • Data breach incident records

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

In accordance with Section 51(1)(c) of PAIA (as inserted by Section 112 of POPIA), the following information is provided regarding how RealTeasy (Pty) Ltd processes personal information:

6.1 Purpose of Processing

Personal information is processed for the following purposes:

  • Providing and operating the PetGuru platform and its features
  • User account management, authentication, and verification
  • Facilitating marketplace transactions between buyers and sellers
  • Processing payments and distributing funds to merchants
  • Communicating with users about their accounts, orders, and platform activity
  • Marketing and promotional communications (with consent)
  • Personalising content, recommendations, and search results
  • Fraud prevention, platform security, and safety monitoring
  • Legal compliance and regulatory reporting
  • Business analytics and platform improvement
  • Providing AI-powered features as described in our AI Disclaimer

6.2 Categories of Data Subjects

  • Registered users (pet owners, browsers, and general public)
  • Breeders and shelters
  • Service providers (veterinarians, groomers, trainers, pet sitters, dog walkers)
  • Merchants and product sellers
  • Visitors to the website (non-registered)
  • Employees and contractors of RealTeasy (Pty) Ltd
  • Suppliers and business partners

6.3 Categories of Personal Information Processed

  • Identifying information (names, email, phone, addresses, ID numbers)
  • Pet-related information (names, breeds, species, health records, photographs)
  • Financial information (transaction records, banking details for merchants)
  • Technical and usage data (IP addresses, browser data, cookies, activity logs)
  • Communications (messages, support requests, feedback)
  • Verification documents (identity documents, breeder accreditation certificates)

6.4 Recipients of Personal Information

Personal information may be shared with:

  • Other users on the platform as necessary for transactions and listings
  • Payment gateway providers for transaction processing
  • Cloud hosting and infrastructure providers
  • Email and communication service providers
  • Analytics and monitoring service providers
  • AI service providers (as described in our AI Disclaimer)
  • Law enforcement or regulatory authorities when required by law
  • Professional advisors (legal, accounting, auditing)

6.5 Cross-Border Transfers

Where personal information is transferred outside the Republic of South Africa (for example, to cloud service providers with servers in other jurisdictions), such transfers are conducted in accordance with Section 72 of POPIA. We ensure that the recipient country has adequate data protection laws, or that binding contractual agreements are in place to protect the information.

6.6 Security Measures

PetGuru implements appropriate technical and organisational measures to secure personal information, as detailed in our Privacy Policy and POPIA Notice.

7. Request Procedure

Any person may request access to a record held by RealTeasy (Pty) Ltd in terms of Section 53 of PAIA, provided that the prescribed requirements are met.

7.1 How to Submit a Request

Requests for access to information must:

  1. Be made in writing using the prescribed Form C (available from the Information Regulator's website at www.inforegulator.org.za).
  2. Provide sufficient detail to identify the record(s) requested.
  3. Specify the form of access required (e.g., inspection, copy, electronic format).
  4. Include the requester's contact details and, if applicable, proof of identity.
  5. State whether the requester wishes to be informed of the decision in any particular manner.

Completed forms should be submitted to:

7.2 Processing of Requests

  • The Information Officer will acknowledge receipt of a request within 3 (three) business days.
  • A decision on the request will be communicated within 30 (thirty) days of receipt, as required by PAIA.
  • If the request is granted, access will be provided in the form requested, where reasonably practicable.
  • If the request is refused, the requester will be informed of the reasons for refusal and of their right to lodge an application with a court or complaint with the Information Regulator.

7.3 Grounds for Refusal

Access to records may be refused on the grounds set out in Chapter 4, Part 3 of PAIA (Sections 62 to 70), which include but are not limited to:

  • Privacy of a third party (Section 63): Where disclosure would unreasonably reveal the personal information of a third party.
  • Commercial information (Section 64): Where disclosure would cause harm to the commercial or financial interests of a third party or PetGuru.
  • Confidential information (Section 65): Where the record contains information supplied in confidence by a third party.
  • Safety of individuals (Section 66): Where disclosure would endanger the life or physical safety of an individual.
  • Privileged records (Section 67): Where the record is subject to legal professional privilege.
  • Research information (Section 69): Where the record contains research information that would expose the research to serious disadvantage.
  • Operations of the body (Section 68): Where disclosure would prejudice the functioning of PetGuru, including negotiations, internal decision-making, or security procedures.

8. Prescribed Fees

The following fees may apply to requests for access to information, as prescribed in terms of Section 54 of PAIA and the regulations published thereunder:

  • Request fee: A non-refundable fee is payable on submission of a request for access to a record (currently R50.00, or as prescribed by regulation).
  • Access fee: An additional fee may be payable for the reproduction of the record and for search and preparation time, depending on the form of access requested.
  • Deposit: Where the cost of searching for and preparing the record is likely to exceed R100.00, a deposit of one-third of the estimated cost may be required.

Fees are waived where the requester is seeking access to their own personal information and is the data subject, or where the request is made by a personal requester (as defined in PAIA) in certain circumstances.

9. Availability of This Manual

This manual is available:

10. Updates to This Manual

This manual will be reviewed and updated periodically to ensure continued compliance with PAIA and POPIA. The "Last updated" date at the top of this page indicates the most recent revision.