Jade E-Services South Africa (Pty) Ltd trading as Zando and/or Jumia

Registration Number: 2011/128056/07

This manual was prepared in accordance with section 51 of the Promotion of Access to Information Act,
2000 (“PAIA”) and to address requirements of the Protection of Personal Information Act, 2013 (“POPIA”)

1. Introduction

1.1 PAIA gives third parties (“Requesters”) the right to approach private bodies and the government to request information held by them, which is required in the exercise and/or protection of any rights. On request, the private body is obliged to release such information unless PAIA expressly states that the records containing such information may or must not be released.

1.2 This manual informs Requesters of the procedural and other requirements which a request must meet as prescribed by the PAIA.

1.3 Should Requesters require assistance, they are requested to contact Jade SA’s Information Officer (details below) in respect of the use of this m anual or requesting documents or information from Zando and/or

1.4 The manual may be amended from time to time and the latest version will be made available online.

Date Version Description Author
January 2021 1. Compliance Information officer

2.Nature of the Business

Jade E-Services South Africa (Pty) Ltd t/a Zando and/or Jumia (“Jade SA”) is a private company carrying on business as an online retailer.

3.Company Contact Infomation

Grant Brown (CEO)
Andrew Gill (CFO)
Information Officer Claire le Roux
Physical Address 1st Floor, 97 Durham Road, Salt River, 7925, Cape Town, Western Cape Province
Postal Address PO Box 13829, Mowbray, 7705
Tel (021) 200 7600
Email address of
Website and

4. Section 10 Guide on how to use PAIA

4.1 The Act grants a Requester access to records of a private body, if the record is required for the exercise or protection of any rights. If a public body lodges a request, the public body must be acting in the public interest

4.2 Requests in terms of the Act shall be made in accordance with the prescribed procedures, at the rates provided. The forms and tariff are dealt with in paragraphs 6 and 7 of the Act.

4.3 Requesters are referred to the Guide in terms of Section 10 which has been compiled by the South African Human Rights Commission, which will contain information for the purposes of exercising Constitutional Rights. The Guide is available from the SAHRC

4.4 Any enquiries regarding this guide and its contents should be directed to:

The South African Human Rights Commission: The Information Regulator (South Africa)
PAIA Unit (the Research and
Documentation Department)
Postal address: Private Bag 2700,
Houghton, 2041
33 Hoofd Street, Braampark Forum 3,
Braamfontein, 2198
Telephone: +27 11 877 3600
Fax: +27 11 403 0625
SALU Building, 316 Thabo Sehume Street, Pretoria
Ms. Mmamoroke Mphelo
Tel: 012 406 4818
Fax: 086 500 3351

5.Applicable Legislation

Jade SA keeps records/information in accordance with inter alia the following pieces of legislation:

Basic Conditions of Employment Act 75/1997
Broad Based Black Economic Empowerment Act 53/2003
Companies Act 71/2008
Competition Act 89/1998
Compensation for Occupational Injuries and Diseases Act 130/1993
Consumer Protection Act 68/2008
Copy Right Act 98/1978
Customs and Excise Act 91/1964
Electronic Communications Transactions Act 25/2002
Employment Equity Act 55/1998
Import and Export Control Act 45/1963
Income Tax Act 95/1967
Insolvency Act 24/1936
Intellectual Property Laws Amendment Act 38/1997
Labour Relations Act 66/1995
Liquor Act 59/2003
Merchandise Marks Act 17/1941
Occupational Health and Safety Act 85/1993
Price Control Amendment Act 80/1967
Promotion of Access to Information Act 2/2000
Skills Development Act 97/1998
Skills Development Levies Act 9/1999
Trade Marks Act 194/1993
Unemployment Insurance Act 63/2001
Value Added Tax Act 89/1991

6.Categories of records

Public Affairs
  1. Public product information
  2. Documents of incorporation
  3. Memorandum of Incorporation
  4. Other corporate information such as
    minutes of board and shareholder
  5. Board resolutions
  1. Financial statements
  2. Financial & Tax records
  3. Supplier records
  4. Policies & procedures
  5. Auditors reports
  6. Bank statements and other banking
Human Resources
  1. Personnel records and contracts
  2. Employment Equity plan & report
  3. Skills development plan
  4. IR disciplinary and grievance
    procedures & hearings
  5. CCMA records
  6. Policies & procedures
  1. Market information
  2. Product information
  3. Performance records
  4. Product sales records
  5. Marketing strategies
Admin & General
  1. Trademarks
  2. Copyright & design
  3. Lease agreements
  4. Supplier records and contracts
  5. Service provider records and contracts
  6. Insurance records
  7. Asset registers
  1. Secured Customer Database/Mailing list
  2. Personal customer information

7.Access to records

7.1 To facilitate the processing of your request, kindly:

7.1.1 Use the prescribed Form C, available on the website of SAHRC at and

7.1.2 Address your request to the Information Officer;

7.1.3 Provide sufficient details to enable Jade SA to identify: The record/s requested; The requester; The form of access required; The postal address or fax number of the requester (in the Republic) or if the requester wishes to be informed of the decision in any manner (in addition to written) the manner and particulars thereof; The right which the requester is seeking to exercise or protect with an explanation of the reason the record is required to exercise or protect the right.

7.1.4 All requests will be forwarded to the lnformation Officer immediately and within no more than 24 hours of receipt.

8.Prescribed fees

The following applies to requests (other than personal requests):

8.1 A requester is required to pay the prescribed fees before a request will be processed;

8.2 If the preparation of the record requested requires more than the prescribed hours, a deposit shall be paid (of not more than one third of the access fee payable if the request is granted);

8.3 A requester may lodge an application with a court against the tender/payment of the request fee and/or deposit;

8.4 Records may be withheld until the fees have been paid;

8.5 The fee structure is available on the website of the SAHRC at https://www.

9.Processing Of Personal Information

In terms of POPIA, personal information must be processed for a specified purpose. The purpose for which data is processed by Jade SA will depend on the nature of the data and the particular data subject. This purpose is ordinarily disclosed, explicitly or implicitly, at the time the data is collected. Please also refer to the Jade SA’s Privacy Policy for further information.

9.1 Purpose of Processing: Jade SA uses Personal Information under its care in the following ways:

9.1.1 Registering new customers.

9.1.2 Processing and delivering customer orders.

9.1.3 Managing your relationship with customers

9.1.4 Enabling customers to participate in promotions, competitions and surveys

9.1.5 Improving our website, applications, products and services

9.1.6 Recommending/advertising products or services which may be of interest to customers

9.1.7 Detecting fraud.

9.1.8 Staff administration;

9.1.9 Keeping of accounts and records;

9.1.10 Complying with legislation

9.2 Categories of Data Subjects and their Personal Information: The Company may possess records relating to suppliers, shareholders, contractors, service providers, staff and customers:

  1. Name and Surname
  2. Delivery Address
  3. Email Address
  4. Telephone Number
  5. Mobile Number
  6. Date of Birth
  7. Gender
  8. ID number / passport number;
  9. Info about shopping device
  10. IP address
  11. Info about Provider
  12. Info about Domain server
  13. Amount of time spent on pages
  14. What pages or sections visited
    our Website
  15. The number of clicks & where clicked on website
  16. Search terms on our Website
  17. Other statistical data relating to offering to customers.
Suppliers -Juristic Persons / Entities or
  1. Names of contact persons;
  2. Name of Legal Entit
  3. Physical and Postal address and
    contact details
  4. Financial inform
  5. Registration Nu
  6. Founding document
  7. Tax related information
  8. Authorised sig
Contracted Service Providers
  1. Names of contact persons;
  2. Name of Legal
  3. Physical and Postal address and
    contact details;
  4. Financial info
  5. Registration Number;
  6. Founding docume
  7. Tax related infor
  8. Authorised signatori
Employees / Directors
  1. Gender,
  2. Pregnancy
  3. Marital Status;
  4. Colour;
  5. Age,
  6. Language
  7. Education information
  8. Financial Information
  9. Employment History
  10. ID number
  11. Physical and Postal
  12. Contact details;
  13. Opinions
  14. Criminal behaviour;
  15. Well-being.

10.Categories of Recipients who receive data for processing.

Jade SA may share information with any third parties in the following circumstances:

10.1 Sale of products and services: In order to deliver customer products and services purchased on our marketplace from third parties, we may be required to provide personal data to such third parties.

10.2 Working with third party service providers: We engage third parties to perform certain functions on our behalf. Examples include fulfilling orders for products or services, delivering packages, analyzing data, providing marketing assistance, processing payments, transmitting content, assessing and managing credit risk, and providing customer service.

10.3 Business transfers: As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, customer information may be transferred together with other business assets.

10.4 Detecting fraud and abuse: We release account and other personal data to other companies and organizations for fraud protection and credit risk reduction, and to comply with the law.

10.5 When we share personal data with third parties we:

10.5.1 require them to agree to use your data in accordance with the terms of this Privacy and Cookie Notice, our Privacy Policy and in accordance with the law; and

10.5.2 only permit them to process personal data for specified purposes and in accordance with our instructions. We do not allow our third-party service providers to use personal data for their own purposes.

11.Transborder Flows of Personal Information

11.1 Jade SA may transfer data trans-border in order to store data with third party cloud storage providers and

11.2 Jade SA may share some or all customer Information with parent companies, subsidiaries, or other companies under common control with Jade SA, but who are located internationally.

11.3 When processing of personal information is carried out in other countries, we will take appropriate steps to ensure the provision of the same or a better level of protection of your personal information as that which is required in terms of South African law.

12.General Description of Information Security Measures

Jade SA employs up to date technology to ensure the confidentiality, integrity and availability of the Personal Information under its care. Measures include:

  • Virus protection software and update protocols
  • Access control (e.g. access to server rooms only with key or chip card, office rooms secured with alarm, cameras, security guards, firewalls, BYOD controls)
  • Data integrity (e.g. user authorisations are restricted to specific tasks)
  • Data encryption (e.g. cloud solution with encryption)
  • Transmission control (e.g. using SSL certificate for websites)
  • Confidentiality enforcement (e.g. password policies, non-disclosure agreements)
  • Recoverability support (e.g. backups that are regularly checked for successful recovery)
  • Training (e.g. privacy awareness training, information security training)

13.Remedies Available if request for information is refused

13.1 Internal Remedies: Jade SA does not have an internal appeal procedure. As such, the decision made by the Information Officer pertaining to a request is final, and Requestors will have to exercise external remedies at their disposal if a request is refused, and the Requester is not satisfied with the response provided by the Information Officer.

13.2 External Remedies: A Requester that is dissatisfied with the Information Officer’s refusal to disclose information, may within 30 (thirty) days of notification of the decision, apply to a court for relief. Likewise, a third party dissatisfied with the Information Officer’s decision to grant a request for information, may within 30 (thirty) days of notification of the decision, apply to a court for relief. For purposes of the Act, courts that have jurisdiction over these applications are the Constitutional Court, the High Court or another court of similar status.

14.Availability of this manual (section 51(3) of the Act)

14.1 This Manual is available for inspection at the offices of Jade SA free of charge.

14.2 This Manual can be downloaded from

14.3 Copies of this Manual may be obtained upon payment of the prescribed fees at the offices of the Jade SA.

15.POPIA Forms

15.2 Objection to the processing of personal information:

15.1.1 A data subject who wishes to object to the processing of personal information in terms of section 11(3)(a) of the POPIA, must submit the objection to Jade SA on Form 1 available here: 7-gon1383-POPIregister.pdf

15.1.2 Jade SA shall render such reasonable assistance as is necessary, free of charge, to enable the data subject to make an objection on Form 1.

15.2 Request for correction or deletion of personal information or destruction or deletion of record of personal information:

15.2.1 A data subject who wishes to request a correction or deletion of personal information or the destruction or deletion of a record of personal information in terms of section 24(1) of the POPIA, must submit a request to the responsible party on Form 2. 7-gon1383-POPIregister.pdf

15.2.2 The responsible party, or a designated person, must render such reasonable assistance, as is necessary free of charge, to enable a data subject to complete Form 2.

This PAIA Manual is approved and signed by Chief Executive Officer of Jade E Services South Africa