Stellr PAIA Manual

Manual in terms of Section 51 of PAIA

Promotion of Access to Information Act 2 of 2000

Last updated: 27 August 2026

1. Introduction

This Manual is published by Stellr South Africa (Pty) Ltd (“Stellr”, “the Body”, “we”, “us” or “our”) in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA). PAIA gives effect to the constitutional right of access to any information held by a person or body that is required for the exercise or protection of any right. This Manual is intended to assist members of the public in exercising that right in relation to records held by Stellr.

This Manual describes the structure and functions of Stellr, the categories of records we hold, which records are available without having to submit a formal request, and how to submit a request for access to a record under PAIA.

2. Details of the Body

Name: Stellr SA

Nature of business: Technology platform enabling the activation, distribution and sale of digital products, vouchers, gift cards and alternative payment solutions, connecting global and local brands with retail, digital, banking, mobile and B2B distribution channels in South Africa.

Registered address: Level 2, The Zone, 177 Oxford Road, Rosebank, 2196, South Africa

Postal address: POSTNET Suite 789, Private Bag X9, Benmore Gardens, Gauteng, 2010

Company registration number: 2004/021702/07

Website: www.stellr-net.com

General email: contact@stellr-net.com

3. Contact Details of the Information Officer

Requests for access to records, and any queries regarding this Manual, POPIA or PAIA, should be directed to the Information Officer:

Information Officer: Bradley Turkington

Email: brad@stellr-net.com

Telephone: 083 655 5500

Address: Level 2, The Zone, 177 Oxford Road, Rosebank, 2196

4. How to Use this Manual and PAIA

The Information Regulator has, in terms of section 10 of PAIA, published a Guide containing information to assist a person wishing to exercise a right of access to a record under PAIA. The Guide is available from the Information Regulator:

Information Regulator (South Africa)

Website: www.justice.gov.za/inforeg/

General enquiries: enquiries@inforegulator.org.za

PAIA complaints: PAIAComplaints@inforegulator.org.za

Postal address: P.O. Box 31533, Braamfontein, 2017

5. Categories of Records Held by Stellr

Stellr holds records relating to its business operations. Not all of the records described below are automatically available on request; access will be granted or refused in accordance with PAIA, including its grounds for refusal in Chapter 4 of Part 2 (relating to private bodies).

5.1. Corporate and Governance Records

Constitutional and incorporation documents, company registration and regulatory filings.
Board and management records, policies and procedures.
B-BBEE certification and compliance documentation.

5.2. Customer, Consumer and Partner Records

Enquiry, partnership and onboarding form submissions.
Content Partner and Distribution Partner agreements and records.
Consumer support and helpdesk correspondence relating to product queries.

5.3. Marketing and Website Records

Website content, analytics and cookie/consent records.
Marketing material, campaigns and communications records.

5.4. Human Resources Records

Employee and job applicant records.
Payroll, benefits and employment contract records.

5.5. Financial Records

Accounting records, invoices, settlement and reconciliation records.
Tax and statutory financial records.

5.6. Information Technology and Security Records

System, network and information security records, including those maintained under ISO 27001-aligned practice
Incident, access control and audit logs.

5.7. Legal and Compliance Records

Contracts, legal correspondence and dispute records.
Anti-Money Laundering (AML) and Know-Your-Customer (KYC) records, where applicable.
Regulatory correspondence, including with the Information Regulator.

6. Records Available Without Having to Submit a PAIA Request

Certain records are voluntarily and automatically available to the public without the need to submit a formal PAIA request. These include:

This PAIA Manual;
The Website Terms and Conditions;
The Stellr Privacy Policy;
The Stellr Cookie Policy;
General marketing and product information published on the website;
Publicly available regulatory filings (for example, company registration information available through the Companies and Intellectual Property Commission).

These records can be accessed directly on the website at www.stellr-net.com or requested from the Information Officer free of charge.

7. Records Available Under Other Legislation

Some records held by Stellr may also be available in terms of other legislation, including:

The Consumer Protection Act 68 of 2008 (for example, in relation to voucher and gift card terms);
The Protection of Personal Information Act 4 of 2013 (for example, in relation to a data subject’s own personal information, which may be requested directly under POPIA rather than PAIA);
The Companies Act 71 of 2008 (for example, certain company records available through the Companies and Intellectual Property Commission);
The Electronic Communications and Transactions Act 25 of 2002.

8. How to Request Access to a Record

A requester who wishes to obtain access to a record of Stellr must complete the prescribed request form (Form 2, or Form 3 for third-party requests, under the PAIA Regulations) and submit it, together with any prescribed request fee, to the Information Officer using the contact details in section 3 above.

The request form should:

Provide sufficient detail to enable the record to be identified;
Indicate the form of access required (for example, a copy, inspection, or a written transcript);
Indicate a postal address, fax number or email address for correspondence;
Indicate the right that the requester is seeking to exercise or protect, and explain why the requested record is required for the exercise or protection of that right, where the requester is not the data subject.

8.1. Fees

A requester may be required to pay a request fee, and where applicable, an access fee and reproduction costs, calculated in accordance with the fee schedule prescribed under PAIA and its Regulations. Requests for a requester’s own personal information under POPIA are not subject to the PAIA request fee, but a reasonable fee may apply for reproduction. Fee amounts will be communicated once a request has been assessed.

8.2. Response Timeframes

Stellr will respond to a request as soon as reasonably possible, and in any event within the 30-day period prescribed by PAIA (or such extended period as PAIA permits, of which the requester will be notified in writing, together with reasons for the extension).

8.3. Grounds for Refusal

Access to a record may be refused on grounds set out in Chapter 4 of Part 2 of PAIA, which may include, among others, protection of the privacy of a third party who is a natural person, protection of certain commercial or confidential information of a third party, protection of records privileged from production in legal proceedings, and protection of the safety of individuals or property. Where access is refused, the requester will be given adequate reasons for the refusal and information on the available internal appeal or Information Regulator complaint procedures.

9. Internal Appeals and Complaints to the Information Regulator

If a requester is dissatisfied with a decision made in response to a PAIA request, the requester may lodge a complaint with the Information Regulator, or, where applicable, pursue any other remedy available under PAIA, including an application to court. Complaints to the Information Regulator can be submitted as follows:

Email: PAIAComplaints@inforegulator.org.za

Website: www.justice.gov.za/inforeg/

10. Availability of this Manual

This Manual is available on the Website at www.stellr-net.com, and a copy may also be requested free of charge from the Information Officer using the contact details set out in section 3. This Manual will be reviewed and updated periodically to remain accurate and to reflect any changes in Stellr’s structure, records or contact details.