This manual explains which records Subtraction (Pty) Ltd keeps and how to ask for them under the Promotion of Access to Information Act (PAIA). It also describes how we process personal information under POPIA.
1. The company
| Company | Subtraction (Pty) Ltd, registration 2016/092758/07 |
|---|---|
| Head of the body and information officer | Lawrence Smit, director |
| Postal and physical address | 15 York Street, Claremont, Cape Town 7708, South Africa |
| Telephone | To be confirmed before launch |
| hello@subtraction.co | |
| Website | subtraction.co |
2. The Regulator’s guide
The Information Regulator publishes a guide on how to use PAIA and POPIA, in every official language. It is available at inforegulator.org.za and from the Regulator’s offices. A copy is available from us on request.
3. Records available without a request
Everything published on this website, including the notes, the privacy notice, the legal page and this manual.
4. Records kept under other laws
Where they apply to us: the Companies Act 71 of 2008, the Income Tax Act 58 of 1962, the Tax Administration Act 28 of 2011, the Basic Conditions of Employment Act 75 of 1997, the Labour Relations Act 66 of 1995, the Electronic Communications and Transactions Act 25 of 2002 and the Protection of Personal Information Act 4 of 2013.
5. Records we hold
- Company: registration documents, the memorandum of incorporation, director records, minutes and resolutions.
- Finance and tax: accounting records, invoices, statements, bank records and tax returns.
- Clients: proposals, terms of business, correspondence, project records and the work delivered.
- Suppliers and contractors: agreements, invoices and correspondence.
- Website and newsletter: enquiries, subscriber records and server logs.
6. How we process personal information
- Purpose: to answer enquiries, deliver and invoice client work, send the newsletter to people who asked for it, and meet our legal and tax duties.
- Whose information: clients and their staff, people who write to us, newsletter subscribers, suppliers and contractors.
- What: names, contact details, company details, correspondence and, for clients and suppliers, billing details.
- Who receives it: our service providers (email, workflow and hosting, as listed in the privacy notice), our accountant, and authorities where the law requires.
- Outside South Africa: Brevo stores newsletter and email data in the European Union, under the GDPR.
- Security: access limited to the director, strong passwords and two-step sign-in, HTTPS throughout.
7. How to ask for a record
Use the request form (Form 2) prescribed under PAIA, available from the Information Regulator’s website, and send it to hello@subtraction.co. Say which record you want and how you want to receive it. We answer within 30 days. The fees set by the PAIA regulations may apply, and we will tell you before any are due. Some records may be refused on the grounds PAIA allows, for example to protect another person’s privacy or commercial information; we will explain why.
If a request is refused and you disagree, you can complain to the Information Regulator or apply to court.
8. Where to find this manual
On this website and from us by email. Last updated 30 October 2026.