PAIA MANUAL — SILINTITHIA (PTY) LTD

Section 51 Manual in terms of the Promotion of Access to Information Act 2 of 2000 ("PAIA")

Last updated: 31 October 2026

1. Introduction

This manual is published in terms of 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").

The purpose of this manual is to:

• Inform the public of the structure and functions of Silintithia (Pty) Ltd;
• Describe the categories of records held by the company;
• Explain how to request access to records;
• Provide the contact details of the Information Officer.

2. Details of the private body

3. Information Officer

The Information Officer is responsible for:

• Receiving and responding to access requests under PAIA;
• Receiving and responding to data subject requests under POPIA;
• Ensuring compliance with PAIA and POPIA.

4. Guide on how to use PAIA

The South African Human Rights Commission ("SAHRC") has compiled a guide on how to use PAIA ("the Guide"), as contemplated in section 10 of PAIA. The Guide is available from the SAHRC:

South African Human Rights Commission Website: www.sahrc.org.za Phone: 011 877 3600 Email: info@sahrc.org.za

5. Description of the business

Silintithia (Pty) Ltd operates SilinTrade, an online marketplace that connects South African homeowners (buyers) with service professionals (plumbers, electricians, painters, builders, etc.) and sellers of secondhand goods, vehicles, and property.

The Platform facilitates:

• Job posting and quoting for home services
• Payment protection through TradeSafe escrow
• Professional verification and rating
• Goods, vehicle, and property listings

6. Applicable legislation

The following legislation may apply to records held by Silintithia (Pty) Ltd:

• Promotion of Access to Information Act 2 of 2000
• Protection of Personal Information Act 4 of 2013
• Electronic Communications and Transactions Act 25 of 2002
• Consumer Protection Act 68 of 2008
• Companies Act 71 of 2008
• Income Tax Act 58 of 1962
• Value-Added Tax Act 89 of 1991
• Basic Conditions of Employment Act 75 of 1997
• Banks Act 94 of 1990 (for reference regarding escrow compliance)
• Financial Intelligence Centre Act 38 of 2001 (FICA)

7. Categories of records held

7.1 Company records

• CIPC registration documents
• Director records
• Memorandum of Incorporation
• Minutes of meetings and resolutions
• Contracts and agreements (including TradeSafe merchant agreement, PayFast merchant agreement)

7.2 Financial records

• Accounting records
• Bank statements
• Tax records (income tax, VAT if applicable)
• Transaction records (escrow and non-escrow)
• Invoices issued and received

7.3 User records

• User account information (names, email, phone)
• Professional profiles and qualifications
• Verification documents
• Transaction history
• Communication logs (messages, support requests)
• Reviews and ratings
• Dispute records

7.4 Operational records

• Platform source code and technical documentation
• System logs and error reports
• Security incident records
• Data processing records and consent logs

7.5 Marketing records

• Marketing consent records
• Newsletter subscriber lists
• Advertising agreements

8. Records available without a request

The following records are publicly available on the SilinTrade platform without the need for a formal PAIA request:

• This PAIA Manual
• Terms of Service
• Privacy Policy
• Professional and Seller Terms
• Advertiser Terms
• Fee schedule and pricing

9. Request procedure

9.1 Form of request

A request for access to records must be made on the prescribed form (Form C, as set out in Annexure B of the Regulations to PAIA). The form is available from:

• The Information Officer (contact details in section 3 above)
• The Department of Justice and Constitutional Development website

9.2 Where to submit

Requests may be submitted to the Information Officer by:

• Email: neokg@silintithia.co.za
• Post: 1001 Rabie Rd, Eldoraigne, Centurion, 0157

9.3 Fees

PAIA prescribes two categories of fees:

• Request fee: A non-refundable fee payable upon submission of the request (currently R50 for a natural person; R50 for a juristic person).
• Access fee: A fee payable if the request is granted, covering the cost of reproduction, search, and preparation.

The prescribed fee amounts are set by regulation and may change from time to time.

9.4 Processing time

The Information Officer will respond to a request within 30 days of receipt. This period may be extended by a further 30 days if:

• The request is for a large number of records;
• Searching for the records requires a search through a large number of records;
• Consultation with another body or third party is necessary.

10. Grounds for refusal

Access to a record may be refused on one or more of the following grounds (as set out in PAIA Chapter 4, Part 3):

• Mandatory protection of privacy of a third party (section 63)
• Mandatory protection of commercial information of a third party (section 64)
• Mandatory protection of certain confidential information and protection of certain other confidential information (sections 65 and 66)
• Mandatory protection of safety of individuals and property (section 67)
• Mandatory protection of records privileged from production in legal proceedings (section 67A)
• Commercial information of the private body (section 68)
• Mandatory protection of research information of a third party and of the private body (sections 69 and 69A)

11. Remedies

If a request for access is refused, the requester may:

• Lodge an internal appeal (if applicable);
• Apply to a court for relief in terms of section 78 of PAIA;
• Lodge a complaint with the Information Regulator.

The Information Regulator (South Africa) Address: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191 Phone: 010 023 5200 Toll-free: 0800 017 160 General enquiries: enquiries@inforegulator.org.za PAIA complaints: PAIAComplaints@inforegulator.org.za

12. Availability of this manual

This manual is available:

• On the SilinTrade platform at https://trade.silintithia.co.za/paia
• From the Information Officer on request
• On the website of the Information Regulator (once filed)

13. Updates

This manual will be updated as and when required. The current version is always available on the Platform.