Thetha AI
MANUAL IN TERMS OF SECTION 51
Promotion of Access to Information Act, 2 of 2000
THETHA AI (PTY) LTD
Registration number: 2026/279930/07
Date of compilation: 2 September 2026
Version: 1.0
Every private body in South Africa must compile and publish a PAIA manual. The exemption that previously covered small private bodies ended on 31 December 2021.
1. Introduction
Thetha AI (Pty) Ltd (“the Company”) is a private company incorporated in the Republic of South Africa. The Company develops and operates SpazaOS, a software platform for informal retail businesses.
This manual is published in terms of Section 51 of the Promotion of Access to Information Act, 2 of 2000 (“PAIA”), read with the Protection of Personal Information Act, 4 of 2013 (“POPIA”).
2. Contact details
| Head of the body / Information Officer | Mojalefa Boikanyo |
| Postal address | 14 South Park Lane, Johannesburg, Gauteng, 2094 |
| Physical address | 14 South Park Lane, Johannesburg, Gauteng, 2094 |
| boikanyo.m@thethaai.co.za | |
| Website | www.thethaai.co.za · www.spazaos.co.za |
Deputy Information Officers: None appointed.
3. Section 10 Guide by the Information Regulator
The Information Regulator has compiled a guide, in terms of Section 10 of PAIA, containing information a person may need to exercise their rights under the Act. It is available from:
The Information Regulator (South Africa)
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
PO Box 31533, Braamfontein, Johannesburg, 2017
Email: inforeg@inforegulator.org.za · PAIAComplaints@inforegulator.org.za
Website: www.inforegulator.org.za
4. Records held by the Company
4.1 Records available in terms of other legislation
| Legislation | Records |
|---|---|
| Companies Act, 71 of 2008 | Memorandum of Incorporation; registers of members, directors and beneficial ownership; annual returns |
| Income Tax Act, 58 of 1962 | Tax returns and assessments |
| Tax Administration Act, 28 of 2011 | Tax records |
| Protection of Personal Information Act, 4 of 2013 | Records of personal information processed |
| Basic Conditions of Employment Act, 75 of 1997 | Employment records (when the Company has employees) |
4.2 Categories of records held
| Category | Description | Available on request? |
|---|---|---|
| Corporate and statutory | Incorporation documents, MOI, registers, resolutions, share certificates | On request, subject to PAIA |
| Financial | Bank records, invoices, accounting records, annual financial statements, tax records | Restricted |
| Product and technical | Source code, system architecture, database design, product documentation | Restricted — trade secrets |
| Customer records | Shop owner accounts, transaction records, credit ledger entries, compliance documentation | Restricted — personal information |
| Commercial | Contracts, agreements, proposals, pricing, partner correspondence | Restricted — confidential |
| Marketing | Website content, published material, brand assets | Freely available |
| Research | Fieldwork notes, market research, sector analysis | Restricted |
5. How to request a record
- Complete Form 2 (“Request for Access to Record of Private Body”), available from the Information Regulator’s website.
- Send it to the Information Officer at the address in section 2.
- Provide sufficient detail to identify the record, your contact details, the form of access required, and the right you seek to exercise or protect.
- Pay the prescribed request fee.
Fees
The prescribed fee structure under PAIA applies: a request fee payable on submission, and an access fee calculated on reproduction, search and preparation time. Current amounts are prescribed by regulation and are published on the Information Regulator’s website. The Company charges no more than the prescribed amounts.
No request fee is payable by a personal requester (a person requesting a record about themselves).
Decision
The Information Officer will decide within 30 days of receipt and notify you in writing. The period may be extended by a further 30 days in the circumstances set out in Section 57.
6. Grounds for refusal
Access may or must be refused where the record involves:
- the unreasonable disclosure of personal information about a third party (Section 63)
- the commercial information of the Company or a third party, including trade secrets (Sections 64 and 68)
- information supplied in confidence (Section 65)
- information that would endanger the life or physical safety of an individual (Section 66)
- privileged legal information (Section 67)
- research information of the Company or a third party (Section 69)
Where access is refused, written reasons will be given, together with information on the right to lodge a complaint with the Information Regulator or to apply to a court.
7. Processing of personal information (POPIA)
| Category of data subject | Personal information processed | Purpose |
|---|---|---|
| Shop owners / customers | Name, ID number, contact details, business address, trading and compliance records | Providing the SpazaOS service; supporting municipal permit and funding applications |
| Customers of shops | Name and amounts owed, where captured in a shop’s credit ledger | Operating the credit ledger on behalf of the shop |
| Suppliers and partners | Contact and banking details | Commercial administration |
| Employees and contractors | Personal and employment details | Employment administration |
| Website users | Technical and usage data | Website operation and security |
Recipients. Personal information may be shared with service providers under written agreement, with municipalities and funding bodies where the data subject has consented, and with regulators or law enforcement where required by law.
Cross-border transfers. Where personal information is stored on servers outside South Africa, the Company complies with Section 72 of POPIA.
Security. The Company applies appropriate technical and organisational measures, including encryption in transit and at rest, access control, and regular backups.
Your rights. Data subjects may request access to, correction of, or deletion of their personal information, and may object to processing, using Form 2 or Form 3 as applicable, addressed to the Information Officer.
8. Complaints
A requester or data subject who is dissatisfied may lodge a complaint with:
The Information Regulator (South Africa)
Email: PAIAComplaints@inforegulator.org.za · POPIAComplaints@inforegulator.org.za
9. Availability of this manual
This manual is available:
- on
www.thethaai.co.zaandwww.spazaos.co.za - at the registered office during business hours
- by email on request to
boikanyo.m@thethaai.co.za
10. Annual reporting
The Company submits an annual PAIA report to the Information Regulator through the Regulator’s eServices portal during the reporting window of 1 April to 30 June each year, covering the preceding period.
Approved by the Information Officer.
M BOIKANYO · Information Officer · Date: 2 September 2026