PAIA Manual, SA FitFoodz (Pty) Ltd

> Names verified against CIPC on 2026-08-21 through the Information Regulator's own eServices > portal, which validates live against the CIPC register. The registered enterprise name is > SA FITFOODZ (type: Private Company) and the sole director is REYNDERS, WILLEM CHRISTIAAN. > Where "SA FitFoodz (Pty) Ltd" appears in our other documents it is a styling of the same entity, > but this manual uses the registered name.

Manual published in terms of section 51 of the Promotion of Access to Information Act, 2 of 2000 ("PAIA"), read with the Protection of Personal Information Act, 4 of 2013 ("POPIA").

Last updated: 2026-09-16

---

1. Purpose of this manual

PAIA gives everyone a right of access to information held by a private body where that information is required to exercise or protect a right. Section 51 requires every private body to compile and publish a manual explaining what records it holds and how to ask for them.

This manual is available:

• on our website at fitfoodz.co.za;
• at our head office during business hours; and
• by email on request to [email protected].

It is provided free of charge.

---

2. Particulars of the private body

Information Officer

All requests for access to records, and all queries about personal information, must be addressed to the Information Officer.

Deputy Information Officers

None are currently designated. All requests are handled by the Information Officer above.

---

3. Section 10 Guide of the Information Regulator

The Information Regulator has compiled a guide, in terms of section 10 of PAIA, containing information a person may need to exercise their rights under the Act. The guide is available in each official language.

Information Regulator (South Africa) JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001 PO Box 31533, Braamfontein, Johannesburg, 2017 Telephone: 010 023 5200 General enquiries: [email protected] PAIA complaints: [email protected] POPIA complaints: [email protected] Website: https://inforegulator.org.za

---

4. Records available in terms of other legislation

Records are kept in accordance with, among others:

• Companies Act, 71 of 2008
• Income Tax Act, 58 of 1962
• Tax Administration Act, 28 of 2011
• Value Added Tax Act, 89 of 1991
• 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, and Unemployment Insurance Contributions Act, 4 of 2002
• Compensation for Occupational Injuries and Diseases Act, 130 of 1993
• Occupational Health and Safety Act, 85 of 1993
• Skills Development Act, 97 of 1998, and Skills Development Levies Act, 9 of 1999
• Consumer Protection Act, 68 of 2008
• Foodstuffs, Cosmetics and Disinfectants Act, 54 of 1972
• Protection of Personal Information Act, 4 of 2013
• Promotion of Access to Information Act, 2 of 2000
• Electronic Communications and Transactions Act, 25 of 2002

Access to a record under this legislation is not automatic and remains subject to PAIA.

---

5. Categories of records held

Records are not automatically available. A request must be made under PAIA and may be refused on any ground set out in Chapter 4 of the Act.

5.1 Company and statutory records

Founding documents, share register, minutes and resolutions, statutory registers, CIPC filings.

5.2 Financial records

Annual financial statements, management accounts, ledgers, invoices, bank records, tax returns and assessments, asset register, insurance policies, loan and finance agreements.

5.3 Employee and human resources records

Employment contracts, personnel files, payroll and remuneration records, leave records, disciplinary and grievance records, training records, medical certificates, statutory returns (PAYE, SDL, UIF, COIDA), health and safety records.

> Some of these are special personal information under POPIA (in particular medical > certificates and any biometric records) and attract additional protection.

5.4 Customer records

Customer names and contact details, delivery addresses, order and transaction history, payment records, correspondence and support conversations, marketing preferences and consent records, loyalty programme records.

5.5 Health and nutrition records

Where a customer has chosen to provide them through our app or nutrition calculators: body measurements, body composition, dietary goals, nutritional targets, food and activity logs, and progress photographs.

> These are special personal information concerning health under section 26 of POPIA and are > subject to stricter conditions. They are held only where the data subject has provided them.

5.6 Supplier and service provider records

Contracts, purchase orders, invoices, delivery notes, correspondence, quality and compliance documentation.

5.7 Operational and product records

Recipes and specifications, production and stock records, nutritional analyses, food safety and quality records, delivery and courier records.

5.8 Marketing records

Campaign material and creative assets, advertising account records, subscriber and audience lists, consent and opt-out records, analytics and performance data.

5.9 Information technology records

System documentation, access logs, backups, security records, agreements with technology providers.

---

6. How to request access to a record

6.1 Form of request

A request must be made on the prescribed form (Form C of the PAIA Regulations, as amended) and addressed to the Information Officer at [email protected] or at the head office address above.

The request must:

• provide sufficient particulars to identify the record and the requester;
• state the form of access required;
• give an address or email in the Republic for delivery of the decision;
• identify the right the requester is seeking to exercise or protect, and explain why the record is required to exercise or protect that right; and
• where the request is made on behalf of another person, include proof of that authority.

6.2 Fees

A requester other than a personal requester must pay the prescribed request fee before the request is processed, and may be required to pay an access fee for search, reproduction and delivery. The fees are those prescribed in the PAIA Regulations from time to time. The Information Officer will notify the requester of any fee payable before processing the request.

A personal requester, a person asking for a record containing their own personal information, is not required to pay a request fee.

6.3 Decision

The Information Officer will decide within 30 days of receipt and notify the requester in writing. That period may be extended by a further 30 days in the circumstances allowed by section 57, in which case the requester will be notified.

6.4 Grounds for refusal

A request may be refused on the grounds in Chapter 4 of PAIA, including:

• the mandatory protection of the privacy of a third party who is a natural person (s63);
• the mandatory protection of commercial information of a third party (s64);
• the mandatory protection of confidential information of a third party (s65);
• the protection of the safety of individuals and of property (s66);
• records privileged from production in legal proceedings (s67);
• the protection of our own commercial activities, including trade secrets and information which could put us at a disadvantage in negotiations or prejudice us in commercial competition (s68);
• the protection of research information (s69);
• a request that is manifestly frivolous or vexatious, or would involve a substantial and unreasonable diversion of resources (s45).

Where a request is refused, the requester will be given reasons and informed of their right to approach a court, and of their right to lodge a complaint with the Information Regulator.

6.5 Remedies

There is no internal appeal against a decision of a private body. A requester who is dissatisfied may lodge a complaint with the Information Regulator, or apply to a court for appropriate relief within 180 days.

---

7. Processing of personal information under POPIA

7.1 Purposes of processing

We process personal information to: take and fulfil orders; deliver goods; take payment; provide customer support; operate our loyalty programme; provide our mobile application and nutrition tools; send transactional and, where lawful, marketing communications; run and measure advertising; maintain our accounts and records; employ and pay staff; meet legal, tax and regulatory obligations; prevent fraud and secure our systems; and analyse and improve our business.

7.2 Categories of data subjects and the information relating to them

7.3 Recipients

Personal information may be shared with the categories of recipient set out in our Privacy Policy at fitfoodz.co.za/policies/privacy-policy, including our e-commerce platform, payment processor, courier, communications and marketing providers, advertising and analytics platforms, technology and hosting providers, professional advisers, and public authorities where the law requires it.

7.4 Transfers outside the Republic

Certain recipients are located outside South Africa. Such transfers are made only on a basis permitted by section 72 of POPIA, and are described in our Privacy Policy.

7.5 Security safeguards

We maintain technical and organisational measures appropriate to the harm that would result from loss or unauthorised access, including encrypted connections, access controls, authentication, vendor due diligence and secured hosting, and we review them.

7.6 Rights of data subjects

A data subject may: ask what personal information we hold about them and request access to it; request correction or deletion of information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or unlawfully obtained; object to processing; withdraw consent where we rely on it; object to direct marketing; and lodge a complaint with the Information Regulator.

Requests are made to the Information Officer at [email protected], using Form 2 of the POPIA Regulations for access or correction, and Form 1 to object to processing.

7.7 Retention

Records are retained for as long as necessary for the purpose for which they were collected, or for longer where the law requires it, including the five-year retention of transactional and tax records required by South African tax legislation.

---

8. Availability and updates

This manual is reviewed at least annually and whenever our processing changes materially. The current version is always the one published at fitfoodz.co.za.

Approved by:

Willem Christiaan Reynders Information Officer, SA FITFOODZ Date: ______________