Last Updated: 2025-10-20

1. INTRODUCTION

JKL 101 (Pty) Ltd ("StudyHalo") understands the importance of transparency and the Constitutional right of access to information and will do our outmost best to ensure that anyone who requires access to any record to fully exercise and protect their rights has access to the PAIA Guide prepared by the Regulator as well as assistance from us in undertaking the request process. StudyHalo takes extreme care to ensure all the records we hold are protected from unlawful access and are processed in accordance with South African law. To this end, we have prepared this PAIA manual in accordance with the requirements of section 51 of PAIA to assist anyone where they seek to request access to information held by us under PAIA.

2. DEFINITIONS AND INTERPRETATION

In this Agreement, unless otherwise indicated by context, the following words and expressions bear the meanings assigned to them and cognate expressions bear corresponding meanings:

• 2.1. "CEO" means the Chief Executive Officer;
• 2.2. "DIO" means the Deputy Information Officer;
• 2.3. "IO" means Information Officer;
• 2.4. "PAIA" means the Promotion of Access to Information Act, 2 of 2000, as amended;
• 2.5. "POPI" means the Protection of Personal Information Act, 4 of 2013, as amended;
• 2.6. "Regulator" means the Information Regulator established in terms of section 39 of POPI;
• 2.7. "Regulations" means the regulations published in terms of section 92 of PAIA; and
• 2.8. "South Africa" means the Republic of South Africa.

3. PURPOSE OF PAIA MANUAL

The purpose of this PAIA manual is to assist anyone to:

• 3.1. review the categories of records we hold which are available without having to submit a formal PAIA request;
• 3.2. understand how to make a request for access to a record of ours, by providing a description of the subjects on which we hold records and the categories of records held under each subject;
• 3.3. review the types of records which are available in accordance with any other legislation;
• 3.4. access all the relevant contact details of the IO and DIO of StudyHalo who will assist with the records anyone intends to access;
• 3.5. understand how to access the guide on how to use PAIA, as updated by the Regulator;
• 3.6. understand whether we will process personal information, the purposes for which we process personal information and the description of the categories of data subjects and of the information or categories of information relating thereto;
• 3.7. distinguish the categories of data subjects and of the information or categories of information relating thereto;
• 3.8. identify the third parties to whom personal information may be supplied by us;
• 3.9. identify if we have planned to transfer or process personal information outside of South Africa and the parties to whom the personal information may be transferred; and
• 3.10. understand the appropriate security measures we employ to ensure the confidentiality, integrity, and availability of the personal information we process.

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 ("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 POPI.

4.2. The Regulator has made the PAIA Guide available in each of the official languages of South Africa and in braille.

4.3. The PAIA Guide contains the following:

• 4.3.1. The objects of PAIA as well as POPI;
• 4.3.2. How to access the postal address, telephone number and email address of every registered IO and DIO (for both public and private bodies);
• 4.3.3. The manner and form of request for:
  • 4.3.3.1. access to a record of a public body contemplated in section 11 of PAIA; and
  • 4.3.3.2. access to a record of a private body contemplated in section 50 of PAIA.
• 4.3.4. the assistance available from the IO of a body in terms of PAIA and POPI;
• 4.3.5. the assistance available from the Regulator in terms of PAIA and POPI;
• 4.3.6. 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 POPI, including the manner of lodging –
  • 4.3.6.1. an internal appeal;
  • 4.3.6.2. a complaint to the Regulator; and
  • 4.3.6.3. an application with a court against a decision by the IO of a public body, a decision on internal appeal or a decision by the Regulator or a decision of the head of a private body;
• 4.3.7. the provisions of sections 14 and 51 of PAIA requiring a public body and private body, respectively, to compile a manual, and how to obtain access to a manual;
• 4.3.8. the provisions of sections 15 and 52 of PAIA providing for the voluntary disclosure of categories of records by a public body and private body, respectively;
• 4.3.9. the notices issued in terms of sections 22 and 54 of PAIA regarding fees to be paid in relation to requests for access; and
• 4.3.10. the Regulations.

4.4. Anyone can inspect or make copies of the PAIA Guide from the office of the Regulator, during normal working hours.

4.5. The PAIA Guide can also be obtained -

• 4.5.1. upon request to StudyHalo's IO;
• 4.5.2. from the website of the Regulator (https://inforegulator.org.za/)

4.6. A copy of the PAIA Guide is also available in the following two official languages, for public inspection during normal office hours-

• 4.6.1. English; and
• 4.6.2. Afrikaans.

5. CONTACT DETAILS FOR ACCESS TO INFORMATION

5.1. INFORMATION OFFICER

Name:	Michael Braude
Email:	support@studyhalo.com

5.2. GENERAL CONTACT:

Email: support@studyhalo.com

5.3. HEAD OFFICE

Physical Address: 28 Bakersfield, Canart Street, Kyalami Hills, Gauteng, 1684

Postal Address: As above.

Website: https://www.studyhalo.com/

6. PROCEDURE TO REQUEST ACCESS TO INFORMATION

6.1. A request for access to information for a record held by the company must be made on a form which corresponds substantially to that of Form 2 along with proof of payment of the prescribed fee to StudyHalo's IO at the details listed in section 5.

6.2. When completing Form 2 or a form substantially similar, a requester must provide clear and accurate information and clearly state the right which the requestor seeks to exercise or protect, the record which they are seeking to access and an explanation as to how such record will assist them to exercise or protect their rights.

6.3. StudyHalo has 30 (thirty) days within which to respond to any request received. Once a decision has been made, the company's IO will inform a requester of their decision whether to grant or refuse a request and any fees payable on a form that corresponds substantially to that of Form 3 of the Regulations.

6.4. StudyHalo may refuse a request for access to a record on any of the grounds listed in Chapter 4 of PAIA (which are listed in the PAIA Guide).

6.5. A requestor is required to pay the request fee before a request will be processed. The request fee is listed in Annexure B to the Regulations. The current request fee payable is R140.00 (one hundred and forty Rand) per request.

6.6. The request fee must be paid into StudyHalo's nominated bank account, which details are available from our IO on request.

7. REMEDIES

7.1. If a requestor is unhappy with a decision made, they may submit a complaint to the Regulator.

7.2. A complaint to the Regulator must be made on a form which corresponds substantially to that of Form 5 of the Regulations. A complaint to the Regulator must be lodged within 180 (one hundred and eighty) days of receipt of the decision from StudyHalo.

7.3. The complaint will then follow the dispute resolution process described in the Regulations as well as the PAIA Guide.

8. RECORDS WHICH ARE AVAILABLE WITHOUT REQUEST

The following records are made freely available by StudyHalo and do not require any request to access:

Category of records	Types of the Record	Where Available
StudyHalo Policies	Terms of Use	On Website
StudyHalo Policies	Privacy policy	On Website
StudyHalo Policies	PAIA Manual	On Website

9. RECORDS WHICH ARE AVAILABLE IN ACCORDANCE WITH OTHER LEGISLATION

The following records are freely available to the public in accordance with legislation:

Category of Records	Applicable Legislation
Memorandum of Incorporation	Companies Act 71 of 2008
PAIA Manual	Promotion of Access to Information Act 2 of 2000
Privacy Policy	Protection of Personal Information Act 4 of 2013

10. SUBJECTS AND CATEGORIES OF RECORDS HELD

StudyHalo holds records on the following subjects:

Subject of Records	Categories of Records
Company Secretarial	Memorandum of incorporation; share certificates, resolutions, director registrations, minutes of meetings, share register
Human Resources	HR policies and procedures; available employment opportunities; employee records
Finance	Banking/bank account records; contractual agreements, accounting records, financial statements and reports, invoices
Intellectual Property	Trademarks, copyright, knowhow, and contractual agreements; original designs
Tax	Income tax records, contractual agreements
Commercial Agreements	Service level agreements; contractor agreements
Information Technology	Software licenses, data protection measures, data retention formulae, breach recovery processes

11. PROCESSING OF PERSONAL INFORMATION

11.1. Purpose of Processing

11.1.1. StudyHalo processes personal information under one or more legal bases for processing including for legitimate business purposes, as a necessary function of a client's engagement with our services, or with such client's express consent.

11.1.2. StudyHalo therefore processes personal information for the following purposes:

• 11.1.2.1. to provide our services to our users;
• 11.1.2.2. to receive and accept services from service providers;
• 11.1.2.3. to provide it to third party service providers who need personal information to provide services to us;
• 11.1.2.4. to provide it to mandated government authorities when instructed to do so for legal compliance only (such as SARS);
• 11.1.2.5. to improve experiences on our website through analytical data.

11.2. Data Subjects and Information Processed

As a responsible party, we process the following information from the following list of data subjects:

Data Subjects	Personal Information that may be processed
Users	Personal information including name, contact details, company information
Service Providers	Company information such as name, registration number, VAT information, registered address, Information obtained from service level agreements such as, trade secrets confidential information and banking information.
Employees / Possible Employees / Directors / Shareholders	Full name, identify documentation, address, contact information, educational qualifications (including curriculum vitae), gender, race, banking information, and tax information.
Independent Contractors / Sub-Contractors	Company information such as name, registration number, VAT information, registered address, and/or personal information such as full name, address, identity number, contact information, and information obtained from contractual agreements such as confidential information, banking information and/or tax information.

11.3. Third Party Recipients to Whom We Share Personal Information

In accordance with our operational requirements, we share personal information with the following third parties:

Category of personal information	Recipients or Categories of Recipients to whom the personal information may be supplied
Marketing, Financial, Transactional, Contractual	Professional advisors (including lawyers, accountants, and auditors); cloud hosting and infrastructure providers; software service providers for business operations; sub-contractors and independent contractors; GitHub (for user authentication and challenge submissions); OpenAI (for AI-powered features and content moderation); YouTube (for API integration and content embedding); analytics providers (for website usage analysis and improvement).
Identity, Contact, Financial, Transactional, Contractual, Technical and Usage data.	General business software to provide services.

11.4. International Transfers

11.4.1. StudyHalo may transfer personal information outside of South Africa in the following circumstances:

• 11.4.1.1. Personal information which is stored using secure cloud severs hosted outside of South Africa.
• 11.4.1.2. Service providers including software for business operation, based outside of South Africa.
• 11.4.1.3. Personal information may be shared within the StudyHalo group of companies.

11.4.2. Whenever we transfer any personal information outside of South Africa, we always ensure a similar degree of protection is afforded to it by ensuring there are contracts in place with all such third parties, providing warranties that they will process the personal information at standards equal to or better than those applied by us.

11.5. Data Security

To prevent the personal information we process from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed we use industry standard cybersecurity measures. All information processed is also restricted to only those individuals who need access.

12. AVAILABILITY OF PAIA MANUAL

12.1. A copy of this PAIA Manual is available-

• 12.1.1. on our website, at https://www.studyhalo.com/;
• 12.1.2. to any person upon request and upon the payment of a reasonable prescribed fee; and
• 12.1.3. to the Information Regulator upon request.

12.2. The fee for a copy of this PAIA Manual, as contemplated in Annexure B of the Regulations, shall be payable per each A4-size photocopy made.

13. UPDATE TO THIS PAIA MANUAL

13.1. This PAIA Manual will be regularly updated by StudyHalo's IO.

13.2. This PAIA Manual was last updated on 2025-10-20.

Thank you for your interest and if you have any questions, please direct them to the Information Officer.

Information Officer