PAIA and POPIA Manual — Agnostic AI (Pty) Ltd (trading as SpecialShelf)
Version 1.0
Date of compilation: 15 October 2026 · Revised: 15 October 2026
1. About this manual
This manual tells you what records Agnostic AI (Pty) Ltd ("the Company") holds, how to ask for access to them under PAIA, and how the Company processes personal information under POPIA.
2. Company details and Information Officer (PAIA s51(1)(a))
| Company | Agnostic AI (Pty) Ltd, registration number 2025/950332/07, trading as SpecialShelf |
| Head of the body | Johannes Petrus (Jannie) Jordaan, Director |
| Information Officer | Johannes Petrus (Jannie) Jordaan (registration with the Information Regulator in progress) |
| Deputy Information Officer | None appointed |
| Physical address | 52 Hillview, 14 Sparrowhawk Street, Centurion, Gauteng, 0157 |
| Postal address | 52 Hillview, 14 Sparrowhawk Street, Centurion, Gauteng, 0157 |
| Phone | +27 76 982 3868 |
| support@agnosticai.co.za | |
| Website | https://specialshelf.agnosticai.co.za |
3. The Information Regulator's guide (PAIA s10)
The Information Regulator publishes a guide on how to use PAIA and POPIA, in each official language. It is available on the Regulator's website (inforegulator.org.za) and from the Regulator: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191; 010 023 5200 (toll-free 0800 017 160); enquiries@inforegulator.org.za (as listed on its website, 2026-10-15). The Company also keeps a copy for public inspection at its office during normal business hours.
4. Records available without a request (PAIA s52)
The following are available on the website without a formal request: the Terms of Service, Privacy Policy, Data Processing Addendum, Acceptable Use Policy, Text Messaging Terms, Refund Policy and sub-processor list.
5. Records held by the Company (PAIA s51(1)(b))
| Subject | Categories of records |
|---|---|
| Company | Incorporation documents, memorandum of incorporation, director and shareholder registers, minutes and resolutions |
| Finance and tax | Financial statements, accounting records, tax and VAT records, bank records, Paddle payout statements |
| Contracts | Customer agreements (Terms acceptance, pilot agreements), supplier and sub-processor agreements |
| Customers (shops) | Account and contact records, subscription and billing status, support correspondence, texting registration details |
| Customer Personal Information processed for shops | Shoppers' contact and order records — held as operator for the shops; requests about these records are referred to the shop concerned (see 8) |
| Product and technology | Software source code, system documentation, security records and logs |
| Marketing | Website content, published materials |
| Personnel (if any) | Employment contracts, payroll and tax records, contractor agreements |
6. Records held under other legislation (PAIA s51(1)(b)(iii))
Records kept as required by, among others: the Companies Act 71 of 2008; the Income Tax Act 58 of 1962; the Value-Added Tax Act 89 of 1991 (if registered); the Tax Administration Act 28 of 2011; the Electronic Communications and Transactions Act 25 of 2002; POPIA; and labour legislation (Basic Conditions of Employment Act 75 of 1997, Labour Relations Act 66 of 1995) where the Company employs people.
7. How to request access
- Complete the request form prescribed under the PAIA regulations (available from the Information Regulator's website or from the Information Officer).
- Send it to the Information Officer at the email or address in section 2.
- Give enough detail to identify the record, the form of access you want, and how you want to be told of the decision. If you are asking on behalf of someone else, show your authority.
- Pay the prescribed request fee (if any) and, if the request is granted, the prescribed access fee, as set by the regulations in force at the time. Requesters seeking their own personal information pay no request fee.
- The Information Officer will decide within 30 days (extendable once by up to 30 days with notice and reasons) and notify you.
- Access may be refused only on grounds in Chapter 4 of Part 3 of PAIA (for example, to protect another person's privacy, commercial information of a third party, confidential information, or records privileged in legal proceedings).
- If you're unhappy with the decision, you may complain to the Information Regulator or apply to court within the periods PAIA sets.
8. Processing of personal information (POPIA, via PAIA s51(1)(c))
| Purposes | Providing the SpecialShelf service to shops; billing (through Paddle); support; security; meeting legal duties. For shoppers' information: only as operator on each shop's instructions, to run its orders and send order updates |
| Categories of data subjects and information | Shop owners and staff: names, emails, roles, actions, business and texting registration details. Shoppers: names, phone numbers, emails, order details, payment status, text consent and messages. Suppliers: contact and contract details |
| Recipients | Sub-processors (database, hosting, background jobs, email, text messages, billing, error tracking) under written agreements; Square as the shop's own provider; authorities where the law requires |
| Trans-border flows | Mainly to the United States (and Paddle in the United Kingdom), under POPIA s72 — binding agreements providing adequate protection, and necessity for the contract with the shop |
| Security measures | Encryption in transit and of stored credentials (AES-256-GCM); database isolation between shops; least-privilege access; audit records; automatic deletion schedules; regular review of safeguards |
Data subjects may object to processing (POPIA s11(3)) or ask for correction or deletion (POPIA s24) using the forms prescribed under the POPIA regulations, sent to the Information Officer.
9. Availability of this manual
This manual is on the website and available at the Company's office for inspection free of charge, and from the Information Officer on request (a copy fee may apply as prescribed).