PAIA Manual — CDSoft (Pty) Ltd
Manual prepared in terms of section 51 of the Promotion of Access to Information Act, 2 of 2000 ("PAIA"), and incorporating information required under the Protection of Personal Information Act, 4 of 2013 ("POPIA").
This manual covers the juristic person CDSoft (Pty) Ltd and all of its trading names (Hassle Bot, smorg, gigz, permz). It is the company's single PAIA manual. The authoritative copy is published here at cdsoft.co.za/paia and is linked from the company's brand websites; a copy is also kept at the company's principal place of business for public inspection during normal business hours.
1. Introduction
CDSoft (Pty) Ltd ("CDSoft", "the Company", "we") is a private body as defined in PAIA. This manual explains what records the Company holds and how a requester may ask for access to them. It is intended to promote transparency and to assist any person who wishes to exercise their rights under PAIA and POPIA.
2. Particulars of the private body (s51(1)(a))
| Registered name | CDSOFT (PTY) LTD |
| Type | Private company (Pty) Ltd |
| Registration number | 2023/618547/07 |
| Trading names | Hassle Bot · smorg · gigz · permz |
| Websites | cdsoft.co.za · hasslebot.co.za · smorg.co.za · gigz.co.za · permz.co.za |
| Registered / postal address | 16 Sering Street, Red Swallow Room, Stellenbosch, Western Cape, 7600 |
| Information Officer | Brent Greeff (Managing Director) |
| IO email | brent@cdsoft.co.za |
| IO telephone | +27 71 644 3570 |
| Registered with the Information Regulator | Yes — IO registration no. 2026-063294 (29 July 2026) |
| Deputy Information Officer(s) | None |
3. The section 10 Guide on how to use PAIA
The Information Regulator has compiled a Guide (in terms of PAIA s10) on how to use the Act. It is available from the Regulator, free of charge:
- The Information Regulator (South Africa)
- Physical: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
- Postal: P.O. Box 31533, Braamfontein, Johannesburg, 2017
- Tel: 010 023 5200
- PAIA complaints: PAIAComplaints@inforegulator.org.za · general enquiries: enquiries@inforegulator.org.za
- Website: https://inforegulator.org.za
4. Records held in terms of other legislation
CDSoft holds and maintains records in accordance with, among others, the following legislation (list as applicable):
- Companies Act, 71 of 2008
- Tax Administration Act, 28 of 2011; Income Tax Act, 58 of 1962 (CDSoft is not registered for VAT)
- 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
- Employment-related statutes (BCEA, LRA, UIF, COIDA) currently do not apply — CDSoft has no employees; they become relevant only if it takes on staff.
5. Records available without a formal request
- Information published on the Company's websites (product information, terms of service, privacy policies, this PAIA manual).
- Marketing and promotional material made generally available.
Access to the above does not require a PAIA request.
6. Categories of records held (s51(1)(e))
Grouped by subject:
- Company & statutory records — incorporation documents, MOI, CIPC filings, director records, income-tax records, annual financial statements (compiled by the Company's accountant).
- Financial records — client invoices and contracts, supplier records, bank records (FNB), accounting records.
- Customer / user records (across the Company's products — Hassle Bot, smorg, gigz, permz, diacrit) — account and contact details, documents users upload (e.g. CVs), chat/correspondence, job-application data, payment records, and usage/technical data.
- Supplier / operator records — agreements and correspondence with the Company's processors and vendors (e.g. Cloudflare, Resend, Anthropic, PayFast, FNB).
- Marketing records — mailing/newsletter lists, advertising-campaign data, website analytics.
- IT / systems records — application databases and file storage, logs, backups, and security/access records.
7. How to request access (s18)
- Complete the prescribed Form 2 — Request for Access to Record of Private Body (Regulation 7, PAIA Regulations 2021).
- Submit it to the Information Officer at brent@cdsoft.co.za (or the postal address in §2).
- Provide enough detail to identify the record and the requester, the form of access required, and a contact address; and state the right you seek to exercise where required.
- Pay the prescribed request fee (see §8). Processing begins once the fee is received.
- We will decide within 30 days and notify you of the decision, any access fee payable, and your remedies. This period may be extended in limited circumstances under PAIA.
8. Fees (Annexure B, PAIA Regulations, 2021)
| Fee | Amount |
|---|---|
| Request fee (per request) | R140.00 |
| — where the requester asks for their own personal information | No request fee |
| Photocopy / printed black-and-white A4 page | R2.00 per page (or part) |
| Copy on flash drive or CD supplied by the requester | R40.00 |
| Copy on CD supplied by the Company | R60.00 |
| Transcription of audio | R24.00 per A4 page |
| Transcription of visual images | Outsourced — at the service provider's quotation |
| Search & preparation (first hour free) | R145.00 per hour or part, capped at R435.00 |
| Deposit (where the search is estimated to exceed 6 hours) | One-third of the total access fee |
| Postage / email / electronic transfer | At actual cost |
Access begins once the applicable fees are paid. These are the statutory amounts in Annexure B to the PAIA Regulations, 2021 (GNR 757, 27 Aug 2021); the Minister may amend them — re-check the current gazette when reviewing this manual.
9. Grounds for refusal
Access may be refused on the grounds set out in Chapter 4 of Part 3 of PAIA, including the mandatory protection of the privacy of a third party, commercial information of a third party or the Company, confidential information, and records privileged from production in legal proceedings.
10. Remedies
A private body has no internal appeal. If a request is refused (or deemed refused), a requester may:
- Lodge a complaint with the Information Regulator using Form 5 (Reg 10), emailed to PAIAComplaints@inforegulator.org.za (a complaint may be deferred if the requester has not first given the Company an opportunity to respond via Form 2); or
- Apply to a court for appropriate relief.
11. POPIA information
- Responsible party: CDSoft (Pty) Ltd. Information Officer: Brent Greeff (details in §2).
- Purpose of processing: providing and improving the Company's products and services (see each product's privacy policy).
- Categories of data subjects: customers/users, prospective users, suppliers, website visitors.
- Categories of personal information: identity and contact details, account and payment information, documents users upload (e.g. CVs), correspondence, and usage/technical data.
- Recipients / operators: infrastructure and service providers acting as processors (e.g. Cloudflare, Resend, Anthropic, PayFast, FNB).
- Cross-border transfers: personal information may be processed outside South Africa by the above providers, subject to POPIA Chapter 9 safeguards. See the applicable privacy policy.
- Data subject rights: to access, correct or delete personal information, to object to processing, and to complain to the Information Regulator. Direct requests to the Information Officer.
12. Availability of this manual
This manual is available:
- On each Company website at /paia;
- At the Company's principal place of business for inspection during normal business hours (free of charge);
- On request to any person (a reasonable fee may be charged for hard copies);
- To the Information Regulator on request.
13. Updates
This manual is reviewed and updated as necessary, and at intervals of not more than one year. The Information Officer's particulars here are kept consistent with the Company's privacy policies and its registration with the Information Regulator.