1. Purpose of this manual
PAIA gives you the right to request access to records held by a private body, where the record is required to exercise or protect a right. This manual explains what records Valentry (Pty) Ltd holds, how to ask for them and how your request will be handled.
2. Company details
| Name | Valentry (Pty) Ltd |
|---|---|
| Registration number | [to be confirmed] |
| Physical address | [to be confirmed] |
| Postal address | [to be confirmed] |
| Telephone | [to be confirmed] |
| support@valentry.co.za | |
| Website | www.valentry.co.za |
3. Information Officer
Requests under PAIA and POPIA are handled by the Information Officer.
| Information Officer | [to be confirmed] |
|---|---|
| Deputy Information Officer | [to be confirmed] |
| support@valentry.co.za |
4. Guide from the Information Regulator
The Information Regulator publishes a guide on how to use PAIA and POPIA, in each official language. It is available from the Information Regulator at inforegulator.org.za. A copy can also be requested from our Information Officer.
5. Records available without a request
The information published on this website, including our privacy notice, website terms, cookie policy and this manual, is available without a formal request.
6. Records held under other legislation
Where applicable to our business, we keep records as required by legislation including:
- 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
- Employment Equity Act 55 of 1998
- Unemployment Insurance Act 63 of 2001
- Compensation for Occupational Injuries and Diseases Act 130 of 1993
- Electronic Communications and Transactions Act 25 of 2002
- Protection of Personal Information Act 4 of 2013
7. Categories of records we hold
| Subject | Records |
|---|---|
| Company | Incorporation documents, statutory registers, resolutions and minutes |
| Finance and tax | Financial statements, accounting records, tax and VAT records, banking records |
| People | Employment contracts, payroll, leave and benefits records |
| Customers | Agreements with brokerages, billing records, support correspondence |
| Suppliers | Supplier agreements, invoices and correspondence |
| Platform operations | Access logs, audit records, security and incident records |
Records we hold for brokerages
Brokerages that use Valentry store their own clients' records on the platform. For those records the brokerage is the responsible party and Valentry is an operator. A request for a brokerage's client records should be made to that brokerage. If we receive such a request, we will refer it to the brokerage concerned.
8. Processing of personal information
Purposes
- Providing, supporting, securing and billing for the Valentry platform
- Responding to enquiries and arranging demonstrations
- Managing employees, suppliers and contractors
- Meeting legal, tax and regulatory obligations
Categories of data subjects and information
| Data subjects | Personal information |
|---|---|
| Brokerage users | Name, work email, role, sign-in and activity records |
| Prospective customers | Name, work email, phone number, organisation and enquiry details |
| Employees and contractors | Identity, contact, banking, tax and employment information |
| Suppliers | Contact persons, banking and contract information |
Recipients
Service providers that host and operate the platform, professional advisers, and authorities where the law requires it. A list of subprocessors: [to be confirmed]
Transborder flows
Platform client records and documents are stored on Google Cloud in the africa-south1 region (Johannesburg). Information processed by service providers outside South Africa, and the safeguards for it: [to be confirmed]
Security measures
Measures include separation of each brokerage's data by design, role-based access, session revocation when access is withdrawn, private document storage served through short-lived signed links, and an append-only audit trail.
9. How to request access
- Complete Form 2 (Request for access to record) prescribed under the PAIA Regulations. It is available from the Information Regulator's website or from our Information Officer.
- Send it to the Information Officer at support@valentry.co.za.
- Give enough detail to identify the record and yourself, and state the right you want to exercise or protect.
- If you ask on behalf of someone else, include proof of your authority.
10. Fees
The fees prescribed in the PAIA Regulations apply. A requester asking for their own personal information does not pay a request fee. We will tell you of any fee payable before we process your request.
11. Timeframes
We will decide on your request within 30 days of receiving it. We may extend this once, by up to a further 30 days, where the law permits, and will tell you why.
12. Grounds for refusal
Access may be refused on the grounds set out in Part 3, Chapter 4 of PAIA, including to protect:
- the privacy of a third party who is a natural person
- commercial information of a third party or of Valentry (Pty) Ltd
- confidential information owed to a third party
- the safety of individuals and the protection of property
- records privileged from production in legal proceedings
13. Remedies
If you are not satisfied with a decision, you may lodge a complaint with the Information Regulator or apply to a court with appropriate jurisdiction, within the periods PAIA allows.
14. Availability of this manual
This manual is published at www.valentry.co.za/paia and is available from the Information Officer on request.