PAIA Manual — Vibermacher (Pty) Ltd
Prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 (as amended), and covering the processing of personal information under the Protection of Personal Information Act 4 of 2013.
Date of compilation: 22/10/2026 · Date of revision: 22/10/2026
1. Acronyms and abbreviations
| Term | Meaning |
|---|---|
| ”Company” | Vibermacher (Pty) Ltd, registration number 2025/272998/07 |
| ”IO” | Information Officer |
| ”DIO” | Deputy Information Officer |
| ”Minister” | Minister of Justice and Constitutional Development |
| ”PAIA” | Promotion of Access to Information Act 2 of 2000 (as amended) |
| “POPIA” | Protection of Personal Information Act 4 of 2013 |
| ”Regulator” | Information Regulator (South Africa) |
| “Republic” | Republic of South Africa |
2. Purpose of this manual
This manual helps the public to:
- see which categories of the Company’s records are available without a formal PAIA request;
- understand how to request access to a record, and which subjects and categories of records the Company holds;
- see which records are available under other legislation;
- find the contact details of the Information Officer;
- find the Regulator’s Guide on how to use PAIA, and how to get it;
- know whether the Company processes personal information, for what purposes, and about which categories of data subjects;
- know the recipients or categories of recipients to whom personal information may be supplied;
- know whether the Company transfers personal information outside the Republic, and to whom; and
- know the security measures the Company uses to protect the confidentiality, integrity and availability of personal information.
3. Key contact details
3.1 Information Officer
| Name | Zachary Bucheister, Director (registered with the Information Regulator, registration number 2026-070005, 22 October 2026) |
| Tel | +27 73 411 5129 |
| zach@vibermacher.com |
3.2 Deputy Information Officer
None designated. All requests go to the Information Officer.
3.3 Access to information: general contact
Email: zach@vibermacher.com
3.4 Head office
| Postal address | 37 Boundary Road, Highlands North, Johannesburg, Gauteng, 2192 |
| Physical address | 37 Boundary Road, Highlands North, Johannesburg, Gauteng, 2192 |
| Telephone | +27 73 411 5129 |
| zach@vibermacher.com | |
| Website | https://vibermacher.com |
4. The Regulator’s Guide on how to use PAIA
4.1 Under section 10(1) of PAIA, the Regulator has updated and made available the revised Guide on how to use PAIA (“Guide”), in an easily understood form, for anyone who wishes to exercise a right under PAIA or POPIA.
4.2 The Guide is available in each of the official languages and in braille.
4.3 The Guide describes:
- the objects of PAIA and POPIA;
- the postal and street address, phone and fax number and, if available, email address of the Information Officer of every public body and every Deputy Information Officer of every public and private body designated under section 17(1) of PAIA and section 56 of POPIA;
- how and in what form to request access to a record of a public body (section 11) and of a private body (section 50);
- the help available from the Information Officer of a public body and from the Regulator under PAIA and POPIA;
- all remedies in law for an act or failure to act under PAIA and POPIA, including how to lodge an internal appeal, a complaint to the Regulator, and an application to court;
- the provisions of sections 14 and 51 requiring public and private bodies to compile a manual, and how to get one;
- the provisions of sections 15 and 52 on voluntary disclosure of categories of records;
- the notices under sections 22 and 54 on fees for requests; and
- the regulations made under section 92.
4.4 Anyone may inspect or copy the Guide at the offices of public and private bodies, including the Regulator, during normal working hours.
4.5 The Guide can also be obtained on request to the Information Officer, or from the Regulator’s website: https://inforegulator.org.za/paia/.
4.6 A copy of the Guide is available for public inspection during normal office hours in these two official languages: English and Afrikaans.
5. Records available without a formal request
| Category of records | Types of record | On the website | On request |
|---|---|---|---|
| Public information about the Company | Company description, products and services, contact details | X | X |
| Privacy and access documents | This PAIA manual; the Privacy Notice | X | X |
| Product information | Product descriptions, data dictionaries, free samples where offered | X | X |
6. Records available under other legislation
| Category of records | Applicable legislation |
|---|---|
| Memorandum of Incorporation, register of directors, securities register, company records and annual returns | Companies Act 71 of 2008 |
| Accounting records and financial statements | Companies Act 71 of 2008; Tax Administration Act 28 of 2011 |
| Tax records and returns | Income Tax Act 58 of 1962; Tax Administration Act 28 of 2011 |
| PAIA manual and records of PAIA requests | Promotion of Access to Information Act 2 of 2000 |
| Records of personal information processing, objections and data subject requests | Protection of Personal Information Act 4 of 2013 |
| Records of electronic transactions and communications | Electronic Communications and Transactions Act 25 of 2002 |
| Exchange control records for foreign receipts | Currency and Exchanges Act 9 of 1933 and the Exchange Control Regulations |
7. Subjects on which the Company holds records
| Subject | Categories of records |
|---|---|
| Company administration | Incorporation documents, statutory registers, resolutions, contracts |
| Finance and tax | Accounting records, invoices, bank statements, tax returns |
| Data products | Source records, collected and compiled datasets, samples, documentation |
| Sales and marketing | Business contact lists, correspondence |
| Customers | Customer details, orders, licences and terms, invoices, correspondence |
| Suppliers and service providers | Contracts, invoices, correspondence |
| Information technology | Website content, system and access records |
| Privacy and access to information | This manual, the Privacy Notice, PAIA and POPIA requests and responses |
8. Processing of personal information
8.1 Purposes of processing
The Company processes personal information to:
- Create, compile and sell data products and services. The Company obtains information from publicly available sources (including public registers, official publications and published business, professional and online sources), from its own observation, measurement and querying of publicly accessible systems and services, and from third-party data providers. It compiles, analyses and enriches this information into datasets, research and related products and services about organisations, markets and technology, and the people associated with them in a business capacity. These are provided, sold or licensed to customers for business purposes. Most of this information concerns juristic persons, but some of it can identify a natural person.
- Find and contact potential business customers. The Company identifies people in business roles who may buy its products, and contacts them at their work addresses, in line with section 69 of POPIA and the laws of the recipient’s country.
- Run the business. This covers dealing with customers and suppliers, invoicing and payment, accounting and tax, and keeping legal records.
- Operate the website and answer enquiries.
- Meet legal obligations, including responding to data subject requests, objections and PAIA requests.
8.2 Categories of data subjects and their personal information
| Category of data subject | Personal information that may be processed |
|---|---|
| People associated with organisations in a business capacity (for example sole traders, partners, directors, officers, owners, employees and licence holders) | Name; business or trading name; role or title; business contact details; registration, licence or other business identifiers; published records, statements and activities relating to the business, with their source and date |
| Business contacts (prospects, customers’ and partners’ staff) | Name; job title and role; organisation; work contact details; location; professional profile links; publicly available professional information; records of correspondence and preferences |
| Operators of publicly accessible systems and services | Technical identifiers and information that those systems publish or return (for example domain names, network addresses, service endpoints, responses and metadata), and published operator or contact details |
| Customers and their representatives | Name; organisation; contact details; billing details; order and licence history; correspondence |
| Suppliers and service providers | Name; organisation; registration and VAT numbers; contact details; bank details; contracts and invoices |
| Website visitors and enquirers | Contact details they provide; message content; basic technical data (e.g. IP address, browser) held by the website host |
| Juristic persons (companies, close corporations, partnerships, trusts and other organisations) | Name; registration and other identifiers; addresses and contact details; industry and activities; registrations, licences, filings and notices; financial, regulatory, commercial and technical information |
8.3 Recipients of personal information
| Category of personal information | Recipients or categories of recipients |
|---|---|
| Data product contents | Customers who buy or license the Company’s products and services, in South Africa and abroad; distributors, marketplaces and partners through which they are offered |
| Business contact information | Service providers that host, store or process the Company’s data, communications and systems; data, verification and communication service providers |
| Customer and supplier information | Banks and payment providers; professional advisers, accountants and auditors; the South African Revenue Service |
| Any personal information | Professional advisers; actual or prospective investors, acquirers or successors in connection with a financing, sale or reorganisation of the business; and the Regulator, courts, law enforcement and other authorities where required or permitted by law |
8.4 Planned transborder flows of personal information
Yes. Personal information is transferred outside the Republic:
- To customers, distributors and partners abroad, including in the United Kingdom, the European Union, the United States and other countries.
- To service providers that host, store or process the Company’s data, communications and systems, whose servers may be outside South Africa, including in the United States and the European Union.
Transfers are made under section 72 of POPIA: to recipients subject to a law, binding corporate rules or a binding agreement giving adequate protection (for example the UK GDPR or the EU GDPR, or contract terms); or where the transfer is necessary for a contract with, or in the interest of, the data subject.
8.5 Information security measures
The Company takes reasonable technical and organisational measures, appropriate to the nature of the information and the risks, to protect its confidentiality, integrity and availability. These include access controls, authentication, encryption provided by its service providers, data minimisation, the use of reputable service providers, and a procedure to notify the Regulator and affected data subjects of a security compromise, as section 22 of POPIA requires.
8.6 Objections, correction and deletion
A data subject may object to processing (section 11(3) of POPIA) or ask for correction or deletion (section 24 of POPIA) by writing to the Information Officer, using the Regulator’s prescribed forms (POPIA Regulations, Forms 1 and 2) or any written request with the same details. The Company will stop processing and suppress the data subject’s information in its data products from the next refresh, unless the law requires otherwise. A data subject may complain to the Regulator: https://inforegulator.org.za, enquiries@inforegulator.org.za, 010 023 5200.
9. Availability of the manual
9.1 This manual is available:
- on https://vibermacher.com/paia;
- at the Company’s head office for public inspection during normal business hours;
- to any person on request, against payment of a reasonable prescribed fee; and
- to the Regulator on request.
9.2 A fee for a copy of the manual, as set out in Annexure B of the PAIA Regulations, is payable per A4-size photocopy made.
10. Updating the manual
The head of Vibermacher (Pty) Ltd will update this manual regularly, and whenever its products or processing change materially.
Issued by
Zachary Bucheister Director and Information Officer, Vibermacher (Pty) Ltd Date: 22/10/2026