Legal
PAIA Manual
This manual explains what records 43xEvents keeps, how to ask for access to them under the Promotion of Access to Information Act 2 of 2000 (PAIA), and how we process personal information under the Protection of Personal Information Act 4 of 2013 (POPIA).
Last updated 28 October 2026
1. Introduction
43xEvents is an online platform for publishing announcements of life events (such as funerals and memorials, weddings, birthdays and graduations) and sharing them with family, friends and communities. It is operated by Linkpot (Pty) Ltd (Private company, registration number [CIPC registration number]), a private body as defined in PAIA.
Section 32 of the Constitution gives everyone the right of access to information held by another person that is required to exercise or protect a right. PAIA gives effect to that right, and section 51 requires private bodies to publish a manual like this one. Access is subject to the procedures and grounds for refusal set out in PAIA.
2. Contact details
- Business name
- Linkpot (Pty) Ltd
- Head of the private body
- Mr NP Sithole
- Information Officer
- Mr NP Sithole
- Physical address
- Midrand, Johannesburg, South Africa
- hello@43xevents.com
- Website
- https://43xevents.com
- Company website
- www.linkpot.co.za
Requests and questions about this manual or about personal information should be sent to the Information Officer.
3. The Information Regulator's guide
The Information Regulator has published a guide (under section 10 of PAIA) on how to use PAIA and POPIA, in all official languages. It explains your rights, how to make a request and what to do if a request is refused. It's available from the Information Regulator:
- Website: inforegulator.org.za (guides, forms and current contact details)
- Email: enquiries@inforegulator.org.za
You may also ask our Information Officer for a copy, and inspect it at our offices during normal business hours.
4. Records available without a request (section 52)
The following are available without a formal PAIA request:
- Information published on our website, including our Terms & Conditions, Privacy Policy, Refund & Cancellation Policy, Cookie Policy and this manual;
- package descriptions and prices;
- published, public announcements (available to anyone with the link).
Account holders can also see and download their own account details, announcements and order history from their dashboard.
5. Records kept under other laws
Where applicable to us, we keep records in terms of, among others:
- Companies Act 71 of 2008
- Income Tax Act 58 of 1962 and 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 and Unemployment Insurance Act 63 of 2001
- Consumer Protection Act 68 of 2008
- Electronic Communications and Transactions Act 25 of 2002
- Financial Intelligence Centre Act 38 of 2001
- Protection of Personal Information Act 4 of 2013
6. Categories of records we hold
| Subject | Records |
|---|---|
| Company | Registration documents, memorandum of incorporation, director and shareholder records, minutes and resolutions |
| Finance and tax | Financial statements, accounting records, invoices, bank statements, tax and VAT returns |
| Customers | Account details, announcements and their content, orders and payment references, support correspondence |
| Followers and visitors | Account details of followers, which announcements they follow, contact form messages |
| Suppliers and service providers | Contracts and correspondence (e.g. payment gateway, hosting, email) |
| Employees and contractors | Contracts, payroll, tax and statutory records (where applicable) |
| Technology and security | System and security logs, backups, website analytics (with consent) |
| Legal and compliance | Policies, this manual, POPIA records, legal correspondence |
Listing a category doesn't mean records in it will be released — each request is considered under PAIA, including the grounds for refusal in section 10.
7. Processing of personal information (POPIA)
7.1 Purpose of processing
- To provide the service: accounts, publishing announcements and sending updates to followers;
- to process payments and keep financial records;
- to keep the platform secure and prevent fraud and abuse;
- to respond to enquiries and provide support;
- to improve the service (analytics, only with consent);
- to meet legal and regulatory obligations.
7.2 Categories of data subjects and their information
| Data subjects | Personal information |
|---|---|
| Customers (people who publish announcements) | Name, email address, password (hashed), sign-in details from Google if used, order and payment references, announcement content they provide |
| People named in announcements | Names, ages, dates (e.g. of birth, passing or the event), hometown, photos and other details the customer chooses to publish — including information about deceased persons and their families |
| Followers | Name, email address, the announcements they follow |
| Website visitors and enquirers | IP address, browser and device information, cookie choices, contact form messages (name, email, optional phone) |
| Suppliers and service providers | Contact persons' names and contact details, banking details for payment |
| Employees and contractors | Identity, contact, banking, tax and employment details (where applicable) |
We don't intentionally collect special personal information (such as religious beliefs or health information) beyond what a customer chooses to include in an announcement.
7.3 Recipients
- Visitors to an announcement — whatever its publisher chooses to make visible;
- PayFast, which processes payments (we never receive card or bank details);
- our hosting, email and technology providers;
- Google, for sign-in with Google and, with consent, Google Analytics;
- professional advisers (e.g. accountants, auditors, attorneys);
- regulators, SARS, courts and law enforcement where the law requires it.
7.4 Transfers outside South Africa
Some service providers (for example email, analytics or cloud hosting) may store or process information outside South Africa. We only do this where section 72 of POPIA allows — for example where the recipient is bound by laws, binding corporate rules or an agreement giving protection comparable to POPIA.
7.5 Security measures
- Encrypted connections (HTTPS) and hashed passwords;
- payment credentials stored encrypted, and card details handled only by PayFast;
- access to systems limited to people who need it, with individual accounts;
- regular software updates, backups and monitoring of system logs;
- agreements with service providers requiring them to protect personal information;
- a process for responding to security incidents and notifying the Information Regulator and affected people as section 22 of POPIA requires.
7.6 Your rights
You may ask what personal information we hold about you, and ask us to correct, delete or stop using it, or object to its processing — see our Privacy Policy. Requests for your own personal information can be made under section 23 of POPIA by contacting the Information Officer; correction or deletion requests may use Form 2 of the POPIA Regulations, available from the Information Regulator's website.
8. How to request access
- Complete Form 2 (Request for access to record) prescribed by the PAIA Regulations, 2021, available from the Information Regulator's website or from our Information Officer.
- Send it to the Information Officer by email or to our physical address (see section 2), with proof of identity.
- Give enough detail to identify the records, say how you'd like access (e.g. a copy or inspection), and explain which right you want to exercise or protect and why the record is needed for it.
- If you're asking on behalf of someone else, include proof of your authority to do so.
- Pay the request fee, if it applies (see section 9).
We'll decide within 30 days of receiving a complete request and tell you the outcome. This period may be extended once by up to 30 days where PAIA allows (for example, for a large number of records); we'll tell you if so. If you can't read or write, or have a disability, the Information Officer will help you make the request orally.
9. Fees
Fees are set by the PAIA Regulations, 2021 and may change; the Information Officer will confirm the amount before any work is done.
| Item | Fee |
|---|---|
| Request fee (not payable for your own personal information) | R140.00 |
| Photocopy or printed copy, per A4 page | R2.00 |
| Copy on flash drive or other electronic media (provided by requester) | R40.00 |
| Search and preparation, per hour or part of an hour (excluding the first hour) | R145.00 |
| Deposit, if search and preparation will take more than 6 hours | One third of the access fee |
| Postage, email or courier | Actual cost |
Some requesters, such as those who earn below the threshold set in the regulations, may be exempt from fees. Access is only given once the fees due have been paid.
10. Grounds for refusal
We may, or in some cases must, refuse access on the grounds set out in Chapter 4 of Part 3 of PAIA, including to protect:
- the privacy of a third party who is a natural person, including a deceased person (section 63);
- commercial information of a third party or of 43xEvents (sections 64 and 68);
- confidential information of a third party (section 65);
- the safety of people and property (section 66);
- records privileged from production in legal proceedings (section 67);
- research information (section 69).
Requests that are manifestly frivolous or vexatious, or that would substantially and unreasonably divert our resources, may also be refused. Access must be granted despite these grounds where the public interest override in section 70 applies.
11. Remedies
There is no internal appeal procedure against a decision of a private body. If you're not satisfied with our decision, you may, within 180 days of being notified:
- lodge a complaint with the Information Regulator (using Form 5, available on its website); or
- apply to a court with jurisdiction.
12. Availability and updates
This manual is published at https://43xevents.com/paia-manual and is available for inspection at our offices free of charge. A printed copy can be requested from the Information Officer (copying fees may apply). We review it at least once a year and whenever our records or processing change materially.
Approved by: Mr NP Sithole · Date: 28 October 2026