PAIA and POPIA manual
This manual of AIO Holdings (Pty) Ltd (registration number 2026/832374/07), trading as ClubAIO (“the company”), is published under section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA) and explains how the company processes personal information under the Protection of Personal Information Act 4 of 2013 (POPIA).
Purpose of this manual
This manual helps you understand which records the company holds, how to ask for access to them, and how to contact the people responsible. Listing a category of record does not mean that every such record exists or that access will be given. Requests are decided under PAIA, which protects, among other things, the privacy of third parties and confidential commercial information.
Contact details
- Head of the private body
- Damian D’Oliveira, Director
- Information Officer
- Damian D’Oliveira
- Email for requests
- hi@clubaio.com
- Physical and postal address
- 1 Roslyn Road, Rondebosch, Cape Town, 7700, South Africa
- Website
- www.clubaio.com
The Information Regulator’s guide
The Information Regulator publishes a guide, under section 10 of PAIA, on how to use PAIA and POPIA to exercise your rights. It is available in all official languages at inforegulator.org.za/paia. You may also ask the Information Officer for a copy, or inspect one at the company’s address by appointment during business hours (08:30 to 16:30, Monday to Friday, excluding public holidays).
Records available without a request
The following are freely available on our website, without a formal request: this manual, our privacy and cookie notice, our terms of service, our company information, and product, pricing and service-status information.
Records kept under other laws
The company keeps records as required by, among others:
- the Companies Act 71 of 2008: memorandum of incorporation, registers of directors and securities, minutes and resolutions, and accounting records;
- the Income Tax Act 58 of 1962 and the Tax Administration Act 28 of 2011: tax returns, assessments and supporting records;
- the Value-Added Tax Act 89 of 1991, if the company registers for VAT;
- the Electronic Communications and Transactions Act 25 of 2002: records of electronic transactions;
- the Consumer Protection Act 68 of 2008, where it applies to the company’s customers;
- the Protection of Personal Information Act 4 of 2013 and PAIA: this manual, records of processing, and requests received and decided;
- the Basic Conditions of Employment Act 75 of 1997, the Labour Relations Act 66 of 1995, the Unemployment Insurance Act 63 of 2001 and the Employment Equity Act 55 of 1998, once the company employs staff.
Subjects and categories of records
Company and governance
- Records
- Incorporation documents, memorandum of incorporation, registers, resolutions and statutory returns
Finance and tax
- Records
- Accounting records, invoices, bank records, tax registrations and returns
Customers
- Records
- Club and organisation details, order forms, agreements, billing contacts, correspondence and support records
Prospects
- Records
- Demo requests and related correspondence
Suppliers
- Records
- Agreements with and invoices from hosting, email and other service providers
Service operation
- Records
- Account and access records, configuration, security and error logs, incident and backup records
Records held for clubs
- Records
- Club operational records processed as an operator on the club’s behalf. Requests for these are referred to the club concerned
Personnel
- Records
- Contracts, remuneration and statutory records for any employees and contractors
Privacy and compliance
- Records
- Policies, records of processing, PAIA and POPIA requests and decisions, and Information Regulator correspondence
How to request access
- Complete Form 2 (Request for Access to Record) from the PAIA Regulations, available at inforegulator.org.za/paia, and email it to hi@clubaio.com or deliver it to the address above.
- Describe the record clearly, say how you want access (for example a copy by email), and give your contact details. As section 53 of PAIA requires, identify the right you want to exercise or protect, and explain why the record is needed for it.
- If you request on behalf of someone else, include proof of your authority.
- We may ask you to pay the request fee prescribed in the PAIA Regulations before we process the request, and an access fee for search, preparation and copies before releasing records. We will tell you the amount first. No request fee applies when you ask for your own personal information.
- We will decide within 30 days and tell you on Form 3. We may extend this once by up to 30 days where section 57 of PAIA allows, and will tell you why.
If we refuse access, we will give reasons and explain your options. If you are unhappy with a decision, or we do not respond in time, you may complain to the Information Regulator on Form 5 within 180 days, or apply to court.
The Information Officer will help you with your request if you need assistance, including if you cannot read or write or have a disability.
Processing of personal information
Purposes. The company processes personal information to provide the ClubAIO service to clubs, respond to enquiries and demo requests, administer customer accounts and billing, secure and improve its systems, and meet its legal obligations. Our privacy notice describes each purpose and its lawful basis.
Prospects and customer contacts
- Personal information
- Names, contact details, club details, correspondence
Users of the service (club staff and players)
- Personal information
- Names, contact details, roles, permissions, sign-in records, and the operational records their club keeps
Suppliers
- Personal information
- Contact details, banking and contract details
Personnel
- Personal information
- Identity, contact, banking, tax and employment details
Website visitors
- Personal information
- IP address, browser and device details, pages viewed (in aggregate)
Recipients. Authorised users of the relevant club; company personnel who need the information; hosting, database, sign-in and email providers acting as operators; professional advisers; and authorities where the law requires.
Cross-border flows. Our hosting, database and email providers process information outside South Africa, including in the European Union and the United States, under protections that meet section 72 of POPIA.
Security. Encryption in transit, separation of each club’s records, permission-based access controls, restricted and logged administrative access, managed backups, and reviewed changes to the live service.
Your POPIA rights. You may ask to access, correct or delete your personal information, or object to processing, by emailing hi@clubaio.com. The Regulations under POPIA provide Form 1 for objections and Form 2 for correction or deletion, but an email with the same information is enough.
Availability and updates
This manual is available on our website, and for inspection at the company’s address by appointment. We will provide a printed copy on request at the cost of printing. The Information Officer reviews this manual at least once a year and whenever our records or processing change materially.