Legal

PAIA Manual

How to request access to records held by Pumpkn under the Promotion of Access to Information Act, 2000.

Last updated: 19 May 2026

1. Introduction

This manual is published by AG-Digital Ventures (Pty) Ltd, trading as Pumpkn (registration number 2022/434429/07) ("Pumpkn", "we", "our") in compliance with section 51 of the Promotion of Access to Information Act, No. 2 of 2000 ("PAIA"). It sets out the procedure a requester must follow to request access to records held by Pumpkn.

PAIA gives effect to the constitutional right of access to any information held by the State and any information held by a private body that is required for the exercise or protection of any right. The size-based exemption that previously applied to small private bodies in South Africa expired on 31 December 2021. From that date onwards, all private bodies — regardless of size or turnover — must publish a PAIA manual.

2. Contact details of the head of the private body

  • Head of the private body (responsible party for PAIA purposes): the Chief Executive Officer of AG-Digital Ventures (Pty) Ltd.
  • Information Officer (per POPIA s.55, deemed to act as the PAIA contact under s.51 of PAIA): Zaheer Dindar
  • Email: compliance@pumpkn.io
  • Postal address: The Heritage Firestation, 16 Baker Street, Rosebank, Johannesburg, 2193, South Africa
  • Website: https://pumpkn.io/

3. Section 10 guide on how to use PAIA

The Information Regulator of South Africa has published a guide on how to use PAIA, as required by section 10 of PAIA. The guide is available on request from the Regulator in each of the official languages, and is available for download at:

The Information Regulator can also be contacted at:

4. Categories of records held by Pumpkn

Pumpkn holds the following broad categories of records:

4.1 Records held in the ordinary course of business

  • Company records: certificate of incorporation, memorandum of incorporation, share register and statutory registers.
  • Financial records: management accounts, accounting records, audited financial statements, tax records (SARS).
  • Operational records: credit assessment files, loan agreements and ancillary security documents, repayment records, KYC and FICA records, customer correspondence.
  • Employee records: employment contracts, payroll, leave and disciplinary records, where applicable.
  • Service-provider records: vendor agreements, supplier invoices, statements.
  • Marketing and website records: lead-capture forms, newsletter subscriptions, analytics (consent-gated), CRM records.

4.2 Records held by Pumpkn that are subject to other legislation

  • Companies Act 71 of 2008
  • National Credit Act 34 of 2005 (NCA) and supporting regulations
  • Financial Intelligence Centre Act 38 of 2001 (FICA)
  • Tax Administration Act 28 of 2011 and the Income Tax Act 58 of 1962
  • Basic Conditions of Employment Act 75 of 1997, Labour Relations Act 66 of 1995, Employment Equity Act 55 of 1998
  • Protection of Personal Information Act 4 of 2013 (POPIA)
  • Electronic Communications and Transactions Act 25 of 2002 (ECT)
  • Consumer Protection Act 68 of 2008 (CPA)

5. Records automatically available without a PAIA request

The following Pumpkn records are publicly available without the need to submit a PAIA request:

  • The Pumpkn website (pumpkn.io) and any of its pages.
  • Pumpkn's Privacy Policy: pumpkn.io/privacy-policy
  • Pumpkn's Terms and Conditions: pumpkn.io/terms-conditions
  • This PAIA Manual.
  • CIPC registration information for AG-Digital Ventures (Pty) Ltd (publicly searchable on the CIPC website).
  • NCR Credit Provider registration NCRCP18413 (publicly searchable on the NCR website).

6. How to request access to records

6.1 Form of the request

A request for access to a record must be made on the prescribed PAIA Form 02 (request to a private body), which is available for download from the Information Regulator at inforegulator.org.za. The completed form must be submitted to the Information Officer at compliance@pumpkn.io or by post to the address in clause 2 above.

6.2 Required information

The requester must provide:

  • Sufficient particulars to enable the Information Officer to identify the record and the requester.
  • An indication of the form of access required (e.g. inspection, copy, transcript).
  • A postal address, fax number or email address in South Africa.
  • If the request is made on behalf of another person, proof of the capacity in which the requester is making the request, to the reasonable satisfaction of the Information Officer.
  • The right that the requester is seeking to exercise or protect, and an explanation of why the requested record is required for that purpose.

6.3 Decision and timeframes

The Information Officer will decide on the request and notify the requester of the decision within 30 days of receipt of the request, as required by section 56 of PAIA. The 30-day period may be extended in the circumstances permitted by section 57 of PAIA.

7. Fees

The fee structure prescribed under section 54 of PAIA and the Regulations applies. The current categories are:

  • Request fee: payable on submission of a request (waived for personal-information requests by the data subject).
  • Access fee: payable before access is given; calculated per Annexure B of the Regulations and depending on the form in which access is granted (photocopy, electronic copy, transcription, etc.).
  • Deposit: if the Information Officer estimates that preparation will take more than six hours, a deposit equal to one third of the estimated access fee may be required.

The current prescribed fees are published in the Information Regulator's PAIA Regulations and are revised from time to time. Pumpkn will confirm the applicable fee in writing before any record is prepared.

8. Grounds for refusal

Pumpkn may refuse a request for access to a record on the grounds set out in Chapter 4 of Part 3 of PAIA, including but not limited to:

  • Mandatory protection of the privacy of a third party who is a natural person (s.63).
  • Mandatory protection of commercial information of a third party (s.64).
  • Mandatory protection of confidential information of a third party (s.65).
  • Mandatory protection of the safety of individuals and the protection of property (s.66).
  • Mandatory protection of records privileged from production in legal proceedings (s.67).
  • Commercial information of the private body (s.68).
  • Research information (s.69).

The Information Officer will provide written reasons for any refusal, in accordance with sections 56 and 25 of PAIA.

9. Remedies available to a requester

A requester who is aggrieved by a decision of the Information Officer may:

  • Lodge a complaint with the Information Regulator under section 77A of PAIA.
  • Apply to a court for appropriate relief in terms of section 78 of PAIA.

10. Availability of this manual

This manual is available:

This manual is published in accordance with PAIA s.51. Updated 19 May 2026.