PAIA manual
Grampus (Pty) Ltd · registration number 2026/860544/07 · last updated 31 October 2026.
This is the company’s manual under section 51 of the Promotion of Access to Information Act, 2000 (PAIA). It says what records the company holds, which of them anyone can have without asking, and how to ask for the rest. It also says how the company processes personal information, as the Protection of Personal Information Act, 2013 (POPIA) requires.
1. Contact details
A request for a record, and any question about this manual, goes to the company. It publishes no email address or telephone number, to keep them from being collected and misused; every message on the contact page is answered by email.
| Company | Grampus (Pty) Ltd, registration number 2026/860544/07 |
|---|---|
| Street address | 814 Mary Ethel Street, Moreleta Park, Pretoria, Gauteng, 0044 |
| Postal address | 814 Mary Ethel Street, Moreleta Park, Pretoria, Gauteng, 0044 |
| Online | The contact page, choosing “A PAIA request”; we answer by email |
| Website | www.grampus.co.za |
2. The Information Regulator’s guide
The Information Regulator publishes a guide, under section 10 of PAIA, on how to use the Act to get access to a record, in each of the official languages. It is on the Regulator’s website, inforeg.org.za, and a copy can be read at the company’s address above during office hours.
3. Records available without a request
These are open to anyone, with no request and no fee (section 52 of PAIA):
- this manual and the company’s privacy notice;
- everything on this website and on www.copycub.co.za, including CopyCub’s terms, privacy notice and prices;
- the company’s registration details, which the CIPC also publishes.
4. Records kept under other laws
The company keeps records as these laws require, where they apply to it. Some of them are available under the law that requires them, and otherwise through a request under this manual.
- Companies Act 71 of 2008
- Income Tax Act 58 of 1962
- Tax Administration Act 28 of 2011
- Value-Added Tax Act 89 of 1991
- Consumer Protection Act 68 of 2008
- Electronic Communications and Transactions Act 25 of 2002
- Protection of Personal Information Act 4 of 2013
- Promotion of Access to Information Act 2 of 2000
- Copyright Act 98 of 1978
- Basic Conditions of Employment Act 75 of 1997, Labour Relations Act 66 of 1995, Unemployment Insurance Act 63 of 2001 and Compensation for Occupational Injuries and Diseases Act 130 of 1993, once the company employs anyone
5. What records the company holds
A record being listed here does not mean a request for it will be granted: each request is decided under PAIA, including its grounds for refusal (section 9).
| Subject | Records |
|---|---|
| The company | Memorandum of incorporation, registration certificate and CIPC filings, registers of directors and of shareholders, share certificates, minutes and resolutions |
| Finance and tax | Accounting records, annual financial statements, bank statements, invoices and receipts, tax and VAT registrations and returns, and correspondence with SARS |
| CopyCub | Parents’ accounts, the children they add, devices, progress, purchases and refunds, as CopyCub’s privacy notice describes; payment records from PayFast; what people write to support |
| Intellectual property | The CopyCub software and its source code, artwork, recordings and words; agreements assigning them to the company; trade marks and domain names |
| Suppliers and contractors | Agreements, quotes, invoices, correspondence and payment details |
| Technology | Agreements with hosting, email, payment and monitoring services; system and security logs |
| Correspondence | Email to and from the company |
6. Processing of personal information
Why it is processed
To provide and sell CopyCub to families; to answer people who write to us; to buy from and pay suppliers and contractors; to keep the company’s books and registers; and to meet what the law requires of the company.
Whose information, and what
| Data subjects | Personal information |
|---|---|
| Parents and guardians using CopyCub | Email address, sign-in records, devices, purchases and payment status (never card or bank details), and what they write to us |
| Children, through their parent | A nickname chosen by the parent, languages, avatar, levels and progress in the game; processed with the parent’s consent |
| People who write to us | Name, email address and what they wrote |
| Suppliers and contractors | Names, contact details, banking details, tax and VAT numbers, agreements and invoices |
| Directors and shareholders | Names, identity numbers, addresses and contact details, shareholdings |
Who receives it
Operators that process it for the company under agreement: a hosting provider, an email service, PayFast for payments, and an error and performance monitoring service; the company’s bank and accountant; and SARS, the CIPC and other authorities where the law requires it. The company does not sell personal information.
Information sent outside South Africa
CopyCub’s database is hosted in the European Union, and some of the services above are outside South Africa. Information goes there only as section 72 of POPIA allows: to a place whose law gives it protection like POPIA’s, or under an agreement that binds the service to that protection.
How it is kept safe
Everything travels encrypted. Access is limited to the people who run the company, each behind their own sign-in, and the services the company uses are chosen for their security. Secret sign-in codes are stored only in a form that cannot be turned back. If a breach touches anyone’s information, the company tells them and the Information Regulator, as section 22 of POPIA requires.
7. How to ask for a record
- Fill in Form 2, the request form in the PAIA Regulations, from the Information Regulator’s website, inforeg.org.za, or ask us for a copy on the contact page.
- Send it to us: on the contact page, choosing “A PAIA request” (we answer by email, and you can reply with the completed form), or by post or hand to the address in section 1. Say which record you want, in enough detail to find it; how you want access (a copy, or to look at it); and which of your rights the record is needed to exercise or protect (section 53 of PAIA).
- If you ask on someone else’s behalf, include proof that you may.
- If a fee applies, we tell you, and the request goes ahead once it is paid (section 8).
- We decide within 30 days and tell you, in the way you asked. That can be extended once by up to 30 days in the cases section 57 of PAIA allows, and we would tell you why.
- If a record holds a third party’s information, we tell them and give them a chance to object before we decide (Chapter 5 of PAIA).
Someone who cannot read or write, or has a disability, may make the request orally, and we will write it down on Form 2 for them.
8. Fees
A request and access to a record may carry the fees prescribed in the PAIA Regulations, as the Information Regulator publishes them; a person asking for their own personal information pays no request fee. We tell you what is due before going ahead.
9. Refusal, and what you can do about it
PAIA requires or allows a request to be refused to protect, among other things: someone else’s privacy; the commercial information of the company or of a third party; information given in confidence; anyone’s safety, or property; records privileged from production in legal proceedings; and the company’s research (sections 63 to 69 of PAIA). A record must nonetheless be given where disclosing it would reveal a serious breach of the law or an imminent and serious risk to public safety or the environment, and the public interest in that clearly outweighs the harm (section 70). If we refuse, we say why and which section we rely on.
The company is a private body and has no internal appeal. If you are not satisfied with a decision, including a fee or an extension, you may within 180 days complain to the Information Regulator (inforeg.org.za), or apply to court.
10. This manual
It is on this website and can be read at the company’s address free of charge; a copy on paper costs only the prescribed fee for copies. We review it at least once a year and whenever anything in it changes, and the date at the top moves when it does.