PAIA Manual

Draft — pending legal sign-off. This is a working draft manual structured for a South African private company, published so the mechanism exists while it is finalised. It should not be treated as a legally reviewed, final PAIA manual until confirmed by counsel.

1. Body particulars

• DNF Financial Services (Pty) Ltd
• Companies and Intellectual Property Commission (CIPC) — 2025 / 778485 / 07
• Contact: privacy@distinct-app.com

2. Information Officer

Our Information Officer is registered with the Information Regulator. Published contact details for the Information Officer are available on request via privacy@distinct-app.com pending publication of the name directly on this page (see legal-constants.ts in the platform codebase for the configuration point).

3. Records available without a formal PAIA request

• Our Privacy Notice and app-specific privacy pages
• Our Terms of Service and app-specific terms pages
• Pricing and refund/cancellation policies published on each app
• This PAIA manual

4. Categories of records held

• Customer/account records held on behalf of business customers (as Operator)
• Distinct's own account, billing, and platform administration records
• Business, employment, and financial records for internal operations
• Correspondence, including data-subject and PAIA requests

5. How to submit a PAIA request

Submit a request via our Data Subject Request form (select "Access" or "Other"), or email privacy@distinct-app.com with enough detail to identify the record sought. We will confirm receipt and next steps, including any applicable fee, in line with PAIA's prescribed process.

6. Grounds for refusal

Requests may be declined on grounds permitted under PAIA (for example, protection of another person's privacy, legal privilege, or commercially sensitive information), with reasons given in the response.

7. Annual reporting and ongoing obligations

PAIA and POPIA impose ongoing obligations on the Information Officer — including annual reporting where applicable, keeping this manual current, and monitoring the Information Regulator's published guidance. These are tracked internally and are not fully automatable from a codebase; see the platform's internal compliance documentation for the current tracking mechanism.