PAIA Manual
Manual under section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA), also covering the information required under the Protection of Personal Information Act 4 of 2013 (POPIA)
Prepared for: THE EXPONENTIAL COLLECTIVE · Version 1.0 · 30 October 2026
1. Introduction
THE EXPONENTIAL COLLECTIVE ("the Company") is a small private company that makes mobile apps and games. PAIA gives everyone the right to request access to records held by a private body, if the record is needed to exercise or protect a right. This manual explains what records we hold and how to ask for them.
2. Contact details of the Company and its Information Officer
| Company name | THE EXPONENTIAL COLLECTIVE |
|---|---|
| Registration number | 2024/293185/07 |
| Physical and postal address | 1 Burning Bush Avenue, Unit 172 Theresa Park Estate, Pretoria, Gauteng, 0155 |
| Head of the private body and Information Officer | Fortune Shane Mahule, Director |
| Telephone | 074 614 1865 |
| fortuneshanemahule@gmail.com | |
| Website | https://exponentialcollective.co.za |
3. The Information Regulator's guide
The Information Regulator has published a guide on how to use PAIA. You can get it from the Regulator:
- Website: inforegulator.org.za
- Email: enquiries@inforegulator.org.za
- Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
4. Records available without a PAIA request
You can read these on our websites at any time:
- Company information and the list of our apps, at exponentialcollective.co.za.
- The Company privacy policy, and the privacy policy and terms of use of each app.
- Information we publish on app store listings.
5. Records we hold
We hold the following categories of records. Whether we can give you access depends on the grounds for refusal in section 7 below.
- Company records: registration documents, resolutions, and share and director registers.
- Financial and tax records: accounting records, invoices, bank statements, and SARS and VAT records.
- Contracts: agreements with service providers and platforms, such as app stores, advertising and hosting providers.
- Intellectual property: source code, designs, app content, trade marks and domain names.
- Correspondence: emails and messages with users, suppliers and authorities, including support requests sent to us.
- Insurance and legal records, where we have any.
- Employee and contractor records, where we have any.
- User records: our apps are designed to keep settings on the user's phone. We hold only limited personal information, as described in each app's privacy policy.
Records may be held on paper or electronically, and some are kept by our service providers on our behalf.
6. How to request access to a record
- Complete the prescribed request form (Form 2 under the PAIA Regulations), available from the Information Regulator's website or from us on request.
- Send it to the Information Officer at the address or email in section 2. Give enough detail for us to identify the record, say which form of access you want, and explain which right you want to protect or exercise.
- If you are asking for records about someone else, or on behalf of someone else, attach proof that you are allowed to ask.
- Pay the prescribed request fee, if one applies. We will tell you if a fee or deposit is due. The fees are set by the PAIA Regulations and are published by the Information Regulator.
We will decide on your request and tell you within 30 days of receiving it. We may extend this once by up to 30 days in the cases PAIA allows, and we will tell you if we do. If we refuse, we will give you the reasons and tell you how to complain.
7. Grounds on which a request may be refused
PAIA requires or allows us to refuse access in some cases. For example, to protect the privacy of another person, commercial information of a third party or of the Company, confidential information, the safety of people or property, or records protected by legal privilege. If only part of a record falls within these grounds, we will give you access to the rest.
8. If you are unhappy with our decision
You may complain to the Information Regulator, or apply to a court, within the periods PAIA sets. You can submit a PAIA complaint to PAIAComplaints@inforegulator.org.za.
9. Personal information we process (POPIA)
| Purpose of processing | Running our apps and websites, responding to support requests, processing purchases made through app stores, measuring ads and app stability (with consent), meeting legal duties, and keeping our own records. |
|---|---|
| Categories of people | App users, people who contact us, website visitors, suppliers, and our director. |
| Categories of information | Contact details such as an email address, the content of messages you send us, device and app identifiers and diagnostics (with consent where required), purchase status from the app store, and business records. |
| Who we may share it with | Service providers working for us (hosting, analytics, advertising and app-store platforms), professional advisers, and authorities where the law requires. |
| Transfers outside South Africa | Some providers, such as Google, process information outside South Africa. Our privacy policies describe this and the safeguards. |
| Security | We keep as little personal information as possible, store app settings on the user's own phone, limit who can access our accounts, and use the security features of the platforms we use. |
Our privacy policies explain your rights to access, correct and delete your personal information, and how to object or complain. Send requests to the Information Officer. You can also complain to the Information Regulator at complaints.IR@inforegulator.org.za.
10. Updates
We will update this manual when our records or contact details change, and at least once a year.