PROMOTION OF ACCESS TO INFORMATION ACT (PAIA) MANUAL

She Rox (Pty) Ltd
Registration Number: 2025/443156/07
Trading as SheRox

Prepared in terms of Section 51 of the Promotion of Access to Information Act 2 of 2000, as amended.

Published date: 23 October 2026
Version: 1.0

1. Introduction

This manual provides information about records held by She Rox (Pty) Ltd and explains the process for requesting access to information under the Promotion of Access to Information Act (PAIA).

It also provides information relating to the processing of personal information under the Protection of Personal Information Act (POPIA).

2. Details of the Private Body

Registered name: She Rox (Pty) Ltd

Registration number: 2025/443156/07

Trading name: SheRox

Business address:
Shop 108, The Paddocks Shopping Centre
Corner of Racecourse Road and Grand National Boulevard
Milnerton, Cape Town
7441
South Africa

Website: https://sherox.co.za

Email: info@sherox.co.za

Telephone: 0632660495

3. Information Officer

Information Officer: Michelle Geldenhuys

Email: info@sherox.co.za

Telephone: 0632660495

Status: Formal authorisation, role and registration with the Information Regulator to be verified.

4. Purpose of the Manual

The purpose of this manual is to help requesters:

• Understand the categories of records held by SheRox.
• Identify records available without a formal PAIA request.
• Understand how to request access to other records.
• Obtain information about the processing of personal information.
• Understand the procedures and remedies available under PAIA.

5. PAIA Guide

The Information Regulator publishes a guide explaining how to exercise rights under PAIA.

This guide is available through the Information Regulator: https://inforegulator.org.za

6. Records Held by SheRox

Subject to the records actually maintained by the business, SheRox may hold the following categories of records.

Company and Corporate Records

• Company registration documents.
• Statutory records.
• Business ownership and management records.
• Business policies and agreements.

Financial and Accounting Records

• Accounting records.
• Invoices and receipts.
• Banking and payment records.
• Membership payment records.
• Tax and related financial documents.

Membership and Customer Records

• Membership applications and agreements.
• Membership package and account information.
• Class bookings and attendance.
• Payment status and billing information.
• Membership cancellation requests.
• Member communications and complaints.

Health and Safety Records

• Relevant member health disclosures.
• Emergency contact information.
• Accident and incident records, where maintained.
• Safety procedures and operational documents.

Employment and Supplier Records

• Personnel records where applicable.
• Supplier agreements.
• Service provider records.
• Contractual and procurement information.

Website and Technology Records

• Website administration records.
• Website enquiries.
• Technical and security information.
• Website analytics and related information.

7. Records Available Without Formal PAIA Requests

Records ordinarily available publicly include:

• Published website information.
• General membership package descriptions.
• Published policies.
• General contact information.
• Public promotional materials.

Access to other records may require a formal request.

8. Records Available Under Other Legislation

Depending on the nature of the records and business activities, records may be subject to legislation including:

• Companies Act 71 of 2008.
• Consumer Protection Act 68 of 2008.
• Protection of Personal Information Act 4 of 2013.
• Promotion of Access to Information Act 2 of 2000.
• Income Tax Act 58 of 1962.
• Tax Administration Act 28 of 2011.
• Employment legislation where applicable.

9. Personal Information Processing

SheRox processes personal information relating to the following categories of individuals, where applicable:

• Members.
• Prospective members.
• Trial participants.
• Employees and contractors.
• Suppliers and service providers.
• Website visitors.

Information may include:

• Names and contact information.
• Membership account information.
• Payment and transaction records.
• Attendance and booking information.
• Health and safety information.
• Emergency contact information.
• Website usage information.

Processing purposes include membership administration, service delivery, billing, safety, communications, security, legal compliance and lawful marketing.

10. Recipients of Information

Information may be disclosed where lawfully necessary to:

• Octiv and approved membership-management providers.
• Payment service providers.
• Website hosting and technology providers.
• Professional advisers.
• Relevant public authorities.
• Other service providers lawfully engaged by SheRox.

11. Cross-Border Transfers

Some external technology or cloud service providers may process information outside South Africa.

Any such transfers must comply with applicable POPIA requirements.

The final manual must reflect verified processing locations and safeguards.

12. Information Security

SheRox takes reasonable steps to protect information through measures including:

• Restricted system access.
• Account authentication.
• Appropriate staff access controls.
• Secure website connections.
• Technical security measures.
• Service provider safeguards.
• Reasonable retention and disposal practices.

13. Requesting Access to Records

Requests must be submitted in the prescribed manner, using the applicable PAIA request form.

Requests should be directed to the Information Officer using the contact details provided in this manual.

Applicants may be required to:

• Supply sufficient identification.
• Identify the records requested.
• Explain the right they seek to exercise or protect.
• Provide necessary supporting details.
• Pay any applicable prescribed fees.

Requests will be assessed according to PAIA.

14. Grounds for Refusal

Access may be refused where permitted or required by law, including where disclosure would unlawfully interfere with personal privacy, confidentiality, commercial interests or other legally protected information.

15. Remedies

A requester who is dissatisfied with the handling or outcome of a request may exercise remedies available under PAIA, including approaching the Information Regulator or a competent court where applicable.

16. Availability of the Manual

Once formally approved, this manual will be made available:

• On the SheRox website.
• At the principal business premises.
• To persons requesting access in accordance with applicable law.
• To the Information Regulator when required.

17. Review and Updates

The manual will be reviewed and updated when necessary to reflect changes to the company, its records or legal obligations.

18. Supporting Documents

The final approved manual must be issued with the applicable prescribed PAIA request forms, fee information and other required attachments.

Approval: Michelle Geldenhuys

Approval date: 17 October 2026

Information Officer registration: [To be confirmed]