ANYRARE GROUP

PAIA Manual

AnyRare Group (Pty) Ltd, Registration number 2026/355440/07
Version 1.0 - September 2026

Prepared under section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA), read with the Protection of Personal Information Act 4 of 2013 (POPIA). This Manual explains how to request records held by AnyRare Group (Pty) Ltd and describes relevant categories of records and personal-information processing.

1. About AnyRare and this Manual

1.1. AnyRare Group (Pty) Ltd is a South African private company developing a holding and intellectual-property business for digital platforms. Its initial public website presents AnyRare and the AnyRare Auto brand and receives stakeholder enquiries. Proposed marketplace, VIN, vehicle-history and analytics services remain subject to separate implementation and legal arrangements.

1.2. This Manual concerns the company’s records generally, not only website records. It does not extend automatically to a separate subsidiary or operating company. Listing a record category does not mean that every record exists or that it is available without restriction. Access is determined under the applicable law and the records actually held.

2. Head of the company and Information Officer

ParticularDetails
CompanyAnyRare Group (Pty) Ltd
Registration number2026/355440/07
Head and Information OfficerCharmain Eloff, Chief Executive Officer
Email for access requestsinfo@anyrare.co.za
Mark for the Information Officer
LocationKempton Park, Gauteng, 1619, South Africa
Websitehttps://anyrare.co.za

Requests may be delivered by email, post or by hand using these contact details. Please contact the Information Officer if you need assistance identifying a record or completing the request procedure. Requests addressed to a Deputy Information Officer, if one is designated, may also be routed through this address.

3. The Regulator’s guide and assistance

The Information Regulator publishes a guide under section 10 of PAIA explaining the legislation, the roles of information officers, how to obtain records, fees, remedies and assistance available. The guide is available in South Africa’s official languages through the Regulator. A copy or assistance obtaining it may also be requested from AnyRare’s Information Officer; the prescribed Guide request forms are available through the links below.

Information Regulator PAIA guide and language versions

PAIA forms including requests for the Guide

Information Regulator (South Africa)

Address: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191.

Telephone: 010 023 5200 | Toll free: 0800 017 160

General enquiries: enquiries@inforegulator.org.za

PAIA complaints: PAIAComplaints@inforegulator.org.za

POPIA complaints: POPIAComplaints@inforegulator.org.za

Information Regulator contact details and complaints channels

4. Records available without a formal PAIA request

4.1. The following published records may be accessed free of charge on the website, when available, without submitting Form 2: this Manual, the Website Privacy Policy, the Website Terms of Use, published business descriptions, public announcements and other material expressly made publicly available. Copies of this Manual may also be requested from the Information Officer, subject to a lawful reproduction charge where applicable.

4.2. This public availability does not make unpublished business plans, private investor materials, correspondence or underlying datasets automatically available. AnyRare has not published a notice under section 52(2) of PAIA. If such a notice is published in future, it will govern the records identified in it.

5. Records available under other legislation

Records may be accessible under legislation other than PAIA, where the relevant conditions and requester’s entitlement are met. The legislation below identifies relevant recordkeeping or access frameworks; it does not make all records public or mean that every listed framework applies to every activity.

LegislationRelevant records or context
Companies Act 71 of 2008Incorporation documents, MOI, securities and beneficial-ownership records, company resolutions, financial statements and other statutory records; access subject to the relevant provisions, including section 26.
POPIA 4 of 2013 and PAIA 2 of 2000Privacy notices, processing documentation, requests, decisions and personal-information access/correction records.
Income Tax Act 58 of 1962 and Tax Administration Act 28 of 2011Tax and supporting accounting records to the extent applicable. Tax recordkeeping does not confer general public access.
Value-Added Tax Act 89 of 1991VAT registration, invoices and supporting records if the company is registered or required to register.
Electronic Communications and Transactions Act 25 of 2002Electronic communications and transaction records where relevant.
Copyright Act 98 of 1978 and Trade Marks Act 194 of 1993Relevant IP ownership, licence and application/registration records to the extent held.
Applicable employment legislationEmployment and payroll records if personnel are engaged, including records under the Basic Conditions of Employment Act 75 of 1997, Labour Relations Act 66 of 1995 and applicable UIF, skills-development and compensation legislation.

6. Record subjects and categories

6.1. The following categories relate to the company’s present corporate and development activities and apply to the extent that records are held or come into existence in those activities. Requests are assessed against the actual record, the right relied upon and any statutory ground for refusal.

SubjectRecord categories
Corporate administrationCIPC documents; MOI; registers; shareholder/director records; resolutions; governance correspondence.
Business developmentBusiness plans; budgets and forecasts; stakeholder and investor correspondence; presentations; meeting records; proposed commercial arrangements.
Finance and taxationAccounting records; invoices; receipts; bank records; tax returns and supporting documents; professional-adviser correspondence.
Contracts and intellectual propertyExecuted contracts and drafts; confidentiality arrangements; supplier/developer agreements; assignments and licences; brand artwork; relevant applications and correspondence.
Website and technologyDomain and hosting records; configuration and access records; maintenance/support records; logs; development documents and provider agreements.
Stakeholder engagementContact-form submissions; expressions of interest; business contact details; correspondence; marketing choices and suppression records.
Privacy and information accessNotices and policies; processing assessments; Information Officer records; operator arrangements; requests and responses; security incident records.
Personnel where applicableRecruitment, engagement, employment, payroll, leave and training records, subject to privacy and other applicable restrictions.

6.2. Future marketplace purchases, payment records, consumer accounts, VIN histories and supplier datasets are not represented as existing merely because the business intends to offer those services. The record descriptions will be updated as the relevant activities begin.

7. How to request a record

7.1. Use the prescribed PAIA Form 2 (Request for Access to Record) and submit it to the Information Officer at the email or physical/postal address in section 2. The current form is available from the Regulator or on request from AnyRare.

Download the prescribed PAIA Form 2

7.2. Provide sufficient details to identify you and the record; specify the form and manner of access requested; provide contact details; identify the right you seek to exercise or protect and explain why the record is required for that purpose, where PAIA requires this; and attach proof of identity and, if acting for someone else, proof of authority. State any claimed fee exemption and relevant reasons.

7.3. Access to records of a private body under section 50 generally requires that the record be needed to exercise or protect a right, that the procedural requirements be met and that no applicable ground for refusal prevents access. PAIA does not ordinarily require us to create a record that does not exist or answer general questions in place of supplying records.

7.4. Access to your own personal information is also governed by section 23 of POPIA. Free confirmation of whether we hold your personal information is distinct from a request for a copy or description. We may request adequate proof of identity and assist with the appropriate procedure. Ordinary privacy enquiries, marketing objections and consent withdrawals need not be made as formal PAIA requests.

7.5. We will consider the requested form of access, accessibility needs and the available format of the record in accordance with PAIA. Please tell us if you require assistance because of a disability or cannot complete the form without help.

8. Fees and deposits

8.1. Only fees lawfully payable under PAIA and its current regulations will be charged. A request fee may be payable before processing where applicable. Reproduction, search, preparation and delivery charges depend on the request and applicable tariff. Personal requesters and other qualifying persons benefit from the exemptions provided by law; confirmation under section 23(1)(a) of POPIA is free.

8.2. If the estimated search and preparation time exceeds the prescribed threshold, a lawful deposit may be required. It may not exceed one third of the applicable access fee. We will give the required fee/deposit notice, explain the calculation and available remedies, and refund a deposit where required, including if access is refused. Access may be withheld until lawfully payable access fees are paid.

8.3. The prescribed Form 3 records the outcome and fees payable. The Information Officer will provide the applicable tariff or calculation on request; no fee is imposed solely by this Manual beyond what the law permits.

Current PAIA forms including Form 3

9. Decisions and time periods

9.1. We will decide a properly received request as soon as reasonably possible and ordinarily within 30 days after receipt, subject to the applicable statutory provisions. Section 57 permits one extension of no more than a further 30 days on specified grounds. Any extension notice will give the period, reasons and applicable remedies within the initial period.

9.2. The decision will state whether access is granted and explain fees, the form of access or adequate reasons and statutory grounds for refusal, as applicable. Failure to give a decision within the applicable period is a deemed refusal under section 58. Third-party notification and representations may be necessary; the related statutory procedures and time periods will be observed.

10. Refusal and partial access

10.1. PAIA provides grounds for refusing access, including protection of third-party personal information, commercial or confidential information, safety and property, legally privileged records, certain commercial information of the company and research information. We will assess the actual record and applicable exceptions; describing information as confidential is not by itself a sufficient refusal ground.

10.2. Where reasonably severable, a non-exempt part will be disclosed. The mandatory public-interest override in section 70 will be considered where its requirements are satisfied. If a record cannot be found or does not exist, the required account of the search and statutory notice will be provided; if subsequently found, it will be dealt with as PAIA requires.

11. Remedies

11.1. AnyRare is a private body and PAIA does not provide a compulsory internal appeal against its decisions. You may ask the Information Officer to clarify or reconsider a decision, but doing so does not extend statutory time limits or prevent you from using an external remedy.

11.2. A complaint concerning a refusal, deemed refusal or other qualifying PAIA decision may be lodged with the Information Regulator using prescribed Form 5. The ordinary complaint period is 180 days from the relevant decision or deemed refusal; the Regulator may consider condonation where the requirements are met. Submit the form and supporting material to PAIAComplaints@inforegulator.org.za or through an available official complaints channel.

11.3. An application to a court with jurisdiction may also be available under section 78, subject to the applicable procedure and time limit, ordinarily 180 days from the relevant decision. A complaint process and court proceedings should not be pursued in a manner inconsistent with PAIA. Obtain advice promptly if considering either remedy; an informal reconsideration request does not stop time running.

PAIA complaint Form 5 and other prescribed forms

12. Personal information processing

12.1. Purposes

The company processes personal information for corporate administration and statutory compliance; communication with directors, shareholders and professional advisers; financial and contract administration; business development and stakeholder enquiries; website administration and security; optional marketing; personnel administration where applicable; and the establishment, exercise or defence of legal rights. A lawful ground under POPIA is required for each activity.

12.2. Data subjects and information categories

Data subjectsInformation categories
Website visitorsTechnical access and usage information; device/browser details; logs and identifiers where collected.
Enquirers, stakeholders and prospective investorsNames, contact details, roles, business particulars, interests and correspondence.
Directors, shareholders and beneficial ownersIdentity, contact, appointment, shareholding and statutory particulars where required.
Suppliers, contractors and professional advisersBusiness and representative details; contracts; service, invoice and payment information where relevant.
SubscribersContact details, consent records, communication preferences and minimal opt-out/suppression information.
Personnel and applicants where applicableIdentity/contact details, qualifications, engagement and payroll information and other lawfully necessary personnel records.

12.3. Recipients

Where lawfully necessary, recipients may include authorised company personnel; hosting, email, cloud, security, IT and development providers; professional advisers; banks and payment-service providers used for the company’s own administration; contracting parties where required for a transaction; and statutory or regulatory authorities. A service provider acting as an operator must be subject to the required written safeguards. These categories do not authorise unrestricted sharing or sale of information.

12.4. Planned overseas processing

The use of hosting, email, cloud and technical-support services may involve processing or access outside South Africa, depending on the selected providers and their subprocessors. Any planned transfer must be assessed under section 72 of POPIA and supported by adequate legal or contractual protection or another applicable statutory ground. The countries, recipient categories and protection applicable to a planned transfer must be reflected in the relevant collection notice before that processing begins and this Manual updated when necessary.

12.5. Security arrangements

The company’s security framework is to provide reasonable access restrictions and authentication; secure transmission and suitable hosting; maintenance and updates; backups and restoration arrangements; restricted physical access to paper records; staff confidentiality and awareness; written operator safeguards; and incident assessment and response. Controls must be proportionate to the information and risks, checked periodically and adjusted when new risks arise. This public description does not disclose passwords, system configurations or other security-sensitive details.

12.6. Retention and rights

Information is retained for its lawful purpose and applicable statutory or contractual periods, taking account of disputes and legal holds. It must be deleted, destroyed or de-identified when no longer lawfully required, or restricted where the law requires. POPIA provides access, correction/deletion, objection, consent-withdrawal and complaint rights subject to statutory requirements. Contact the Information Officer; current POPIA Forms 1 and 2 and the complaints form are available below.

POPIA forms and procedures

13. Availability and updates

13.1. This Manual is available on the company’s website and for public inspection during normal business hours at its principal place of business. Contact the Information Officer to confirm inspection arrangements; this does not make a formal PAIA request a condition of inspecting the Manual. Copies are available on request subject to a lawful reproduction charge, and to the Information Regulator on request.

13.2. The Information Officer is responsible for keeping the Manual current as the company’s contact details, records and processing activities change. The version date appears on the first page.