PAIA Manual

1.1 The Promotion of Access to Information Act 2 of 2000 (“PAIA”) gives effect to the constitutional right of access to information held by public and private bodies where that information is required for the exercise or protection of a right.

1.2 This Manual has been prepared by Coin Pro (Pty) Ltd (“Coin Pro”) in terms of section 51 of PAIA. It describes the categories of records held by Coin Pro and explains how a person may request access to those records.

1.3 Access to a record is not automatic. A requester must comply with the requirements of PAIA, identify the right which the requester seeks to exercise or protect and explain why the requested record is required for that purpose.

1.4 Access may be restricted where disclosure would unjustifiably affect privacy, confidentiality, legal privilege, security, commercial interests or another right protected by law.

2.1 Coin Pro’s details are:

Full registered name: Coin Pro (Pty) Ltd
Registration number: 2023/147377/07
FSP number: 54194
Physical address: 1 Test Street, Sandton, Johannesburg, 2196, South Africa
Postal address: PO Box 0000, Sandton, 2146, South Africa
Telephone number: +27 10 000 0000
Website: https://coinpro.test
Email address: [email protected]

2.2 Information Officer: Marios Papaharidemou

2.3 No Deputy Information Officer has been designated.

3.1 The Information Regulator has published a guide explaining how to exercise rights under PAIA, including how to submit a request, the prescribed forms and fees, the assistance available to requesters and the remedies available where a request is refused.

3.2 The Guide and the current prescribed PAIA forms are available from the Information Regulator’s official website.

3.3 The Information Regulator’s contact details are:

Information Regulator (South Africa)
Woodmead North Office Park
54 Maxwell Drive
Woodmead, Johannesburg, 2191
Telephone: 010 023 5200
Toll-free number: 0800 017 160
Email: [email protected]

4.1 Records published on Coin Pro’s website may be accessed without submitting a formal PAIA request.

4.2 These records may include this PAIA Manual, Coin Pro’s Privacy Policy, Terms of Service, Risk Disclosure, Complaints Policy and other legal, regulatory or service information published on the website.

4.3 Publicly available company and licensing information may also be obtained from the relevant company, regulatory or public registers.

4.4 A record being listed in this section does not mean that all related or underlying records are publicly available.

5.1 Coin Pro holds, or may generate and hold in the ordinary course of its activities, the following categories of records.

5.2 Corporate and governance records

These may include incorporation documents, the Memorandum of Incorporation, registers of directors and securities holders, beneficial ownership records, share certificates, board and shareholder resolutions, minutes of meetings, annual returns and other statutory corporate records.

5.3 Licensing and regulatory records

These may include Coin Pro’s FSP licence and authorisations, regulatory applications and correspondence, statutory disclosures, compliance reports, regulatory submissions, complaints records and records required under applicable financial-services legislation.

5.4 Client and transaction records

These may include client registration and verification records, identity and address information, bank and payment details, customer due-diligence records, Source of Funds and Source of Wealth information, screening results, transaction instructions, transaction records, external wallet addresses, blockchain transaction information, communications and complaints.

5.5 Financial and taxation records

These may include bank records, accounting records, management accounts, annual financial statements, invoices, payment records, ledgers, asset records, tax records and supporting financial documents.

5.6 Employee records

These may include employment applications and agreements, identification and contact information, payroll and remuneration records, banking and tax information, leave records, training records and other records required under employment legislation.

5.7 Supplier and service-provider records

These may include agreements, due-diligence records, invoices, banking information, correspondence, confidentiality arrangements and records relating to the performance of services.

5.8 Legal, information-technology and security records

These may include contracts, legal correspondence, claims and disputes, software licences, system documentation, access records, security policies, incident records, business-continuity records and technical service-provider agreements.

6.1 Coin Pro may hold records in accordance with the following legislation, where applicable:

• the Companies Act 71 of 2008;
• the Financial Advisory and Intermediary Services Act 37 of 2002;
• the Financial Intelligence Centre Act 38 of 2001;
• the Financial Sector Regulation Act 9 of 2017;
• the Protection of Personal Information Act 4 of 2013;
• the Promotion of Access to Information Act 2 of 2000;
• the Electronic Communications and Transactions Act 25 of 2002;
• applicable tax legislation; and
• applicable employment and labour legislation.

6.2 The inclusion of a law in this section does not create an unrestricted right of access to records held under that law. Access remains subject to PAIA, the relevant legislation and applicable confidentiality requirements.

7.1 Coin Pro processes Personal Information relating to clients and prospective clients, employees, directors and office holders, suppliers, contractors, professional advisers, website users and other persons who interact with Coin Pro.

7.2 Coin Pro may process identification, contact, verification, financial, employment, transaction, compliance, technical and communication information for purposes connected with providing its services, processing transactions, managing employment and business relationships, meeting legal and regulatory obligations, preventing fraud, maintaining records and protecting its systems and legal rights.

7.3 Where necessary and permitted by law, Personal Information may be provided to identity-verification and screening providers, banks, payment-service providers, liquidity providers, blockchain analytics providers, technology and hosting providers, professional advisers, auditors, regulators, courts and law-enforcement authorities.

7.4 Some service providers or technical systems used by Coin Pro may be located outside South Africa. Any transfer of Personal Information outside South Africa will be handled in accordance with section 72 of POPIA.

7.5 Coin Pro applies reasonable technical and organisational measures intended to protect Personal Information against loss, unlawful access, unauthorised disclosure, alteration, damage or destruction.

7.6 Further information about the collection and processing of Personal Information is contained in Coin Pro’s Privacy Policy.

8.1 A requester must complete the current prescribed Form 2: Request for Access to Record and submit it to Coin Pro using the contact details in section 2.1 of this Manual.

8.2 The request must contain sufficient information to identify:

• the requester;
• the requested record or relevant part of the record;
• the form in which access is required;
• the right which the requester seeks to exercise or protect;
• why the requested record is required for the exercise or protection of that right; and
• where a request is made on behalf of another person, the requester’s authority to act for that person.

8.3 Coin Pro may request proof of identity, proof of authority or additional information necessary to locate the record and prevent unauthorised disclosure.

8.4 The current Form 2 may be obtained from the Information Regulator’s official website.

9.1 A request may be subject to the fees prescribed under PAIA and the applicable regulations.

9.2 Coin Pro will notify the requester of any request fee, access fee, reproduction cost, delivery cost or deposit payable before continuing to process the request.

9.3 Coin Pro will ordinarily notify the requester of its decision within 30 days after receiving a properly completed request.

9.4 The response period may be extended once for a period not exceeding a further 30 days where permitted under PAIA, including where the request involves a large number of records, an extensive search, records held at another location or consultation with another person.

9.5 If access is granted, Coin Pro will specify the form in which access will be provided and any applicable fee.

9.6 If access is refused, Coin Pro will provide reasons for the refusal and identify the relevant provisions of PAIA.

10.1 Coin Pro may or must refuse access to a record where refusal is permitted or required under PAIA.

10.2 Grounds for refusal may include the protection of:

• the privacy and Personal Information of another person;
• confidential, commercial, financial, scientific or technical information belonging to Coin Pro or a third party;
• trade secrets and intellectual property;
• information supplied in confidence;
• the safety of individuals and the security of property, systems or networks;
• records protected by legal professional privilege;
• Coin Pro’s commercial activities, negotiations and competitive position; and
• information which Coin Pro is prohibited from disclosing under another law.

10.3 A request may also be refused if it is manifestly frivolous or vexatious or would involve a substantial and unreasonable diversion of Coin Pro’s resources.

10.4 Where a protected part of a record can reasonably be separated from the remainder, Coin Pro will consider granting access to the remaining part.

11.1 Coin Pro does not have an internal appeal procedure for decisions made under PAIA.

11.2 A requester who is dissatisfied with Coin Pro’s decision, fee, form of access or failure to respond may lodge a complaint with the Information Regulator using the prescribed Form 5: Complaint Form.

11.3 A complaint should ordinarily be submitted within 180 days of the relevant decision or failure to respond.

11.4 Complaints may be directed to:

Information Regulator (South Africa)
Email: [email protected]

11.5 A requester or affected third party may also apply to a competent court for relief in accordance with PAIA.

12.1 This Manual is available:

• on Coin Pro’s website;
• from Coin Pro upon request using the contact details in section 2.1; and
• for inspection at Coin Pro’s physical address during normal business hours, by prior arrangement.

12.2 Coin Pro may update this Manual where necessary to reflect material changes to its records, contact details, activities or legal obligations.