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 Jumia.co.za
1.4 The manual may be amended from time to time and the latest version will be made available online.
|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||www.zando.co.za and www.jumia.co.za|
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
Postal address: Private Bag 2700,
33 Hoofd Street, Braampark Forum 3,
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
Jade SA keeps records/information in accordance with inter alia the following pieces of legislation:
|LIST OF LEGISLATION||ACT NO.|
|Basic Conditions of Employment Act||75/1997|
|Broad Based Black Economic Empowerment Act||53/2003|
|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|
|Intellectual Property Laws Amendment Act||38/1997|
|Labour Relations Act||66/1995|
|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
|Admin & General||
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 www.sahrc.org.za and https://www.justice.gov.za/forms/paia/J752_paia_Form%20C.pdf
7.1.2 Address your request to the Information Officer;
7.1.3 Provide sufficient details to enable Jade SA to identify:
126.96.36.199 The record/s requested;
188.8.131.52 The requester;
184.108.40.206 The form of access required;
220.127.116.11 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;
18.104.22.168 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.
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. sahrc.org.za/home/21/files/PAIA%20Notice%20on%20fees.pdf
9.Processing Of Personal 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:
|ENTITY TYPE||PERSONAL INFORMATION
|Suppliers -Juristic Persons / Entities or
|Contracted Service Providers||
|Employees / Directors||
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:
10.5.2 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 www.zando.co.za
14.3 Copies of this Manual may be obtained upon payment of the prescribed fees at the offices of the Jade SA.
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:
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.
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