PAIA and POPIA Manual

MOYENA GROUP (PTY) LTD
Trading as Moyena Learning
www.moyenalearning.co.za

PAIA AND POPIA MANUAL

Prepared in terms of the Promotion of Access to Information Act 2 of 2000 and the Protection of Personal Information Act 4 of 2013

Version 1.0
Effective Date: 3 June 2026

PART A: COMPANY DETAILS

A1. Name of Private Body

Moyena Group (Pty) Ltd
Trading as Moyena Learning

A2. Registration and Business Details

Company Registration Number: 2026/168599/07
Nature of Business: Educational publishing, printed workbooks, digital learning resources, free educational downloads, and related educational content.
Website: www.moyenalearning.co.za
Email: info@moyenalearning.co.za

Physical Address:
99 Sunshine Crescent,
Nietgedacht, Fourways,
Johannesburg, 1739
South Africa

A3. Information Officer

In terms of POPIA and PAIA, Moyena Group (Pty) Ltd trading as Moyena Learning’s Information Officer is:

Name: Masego Mokgatlha
Title: Founder and Director
Email: info@moyenalearning.co.za

The Information Officer is responsible for ensuring compliance with POPIA and PAIA and may be contacted for requests relating to personal information, access to records, correction of personal information, deletion requests, objection requests, or related privacy and access-to-information matters.

PART B: PROMOTION OF ACCESS TO INFORMATION ACT

B1. Purpose of this Manual

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 such access is required for the exercise or protection of any right.

This Manual describes the categories of records held by Moyena Group (Pty) Ltd trading as Moyena Learning and explains the process for requesting access to such records.

This Manual is intended to help members of the public understand:

The categories of records held by Moyena Group (Pty) Ltd trading as Moyena Learning
How to request access to records
Who to contact for PAIA and POPIA matters
What personal information may be processed
The purposes for which personal information may be processed
The rights of data subjects under POPIA

B2. Records Held by Moyena Group (Pty) Ltd trading as Moyena Learning

Moyena Group (Pty) Ltd trading as Moyena Learning may hold the following categories of records:

B2.1 Corporate and Legal Records

Company registration documents
Memorandum of Incorporation and related company records
Shareholder and director records
Company resolutions and minutes
Tax registration and compliance records
Legal agreements and contracts
Policy documents and compliance records

B2.2 Financial Records

Annual financial statements
Accounting records
Bank records and transaction histories
Invoices and receipts
Purchase orders
Supplier payment records
Tax-related records
Payroll records, where applicable

B2.3 Operational and Commercial Records

Supplier and service provider agreements
Distribution agreements
Delivery and fulfilment arrangements
Partnership agreements
Campaign records
Publishing records
ISBN or product registration records, where applicable
Intellectual property records
Product development records
Website and e-commerce platform records

B2.4 Customer and User Records

Customer order records
Transaction records
Delivery and fulfilment records
Download registration data
Name, email address, contact details, and region where provided
Customer support correspondence
Email marketing subscriber records
Consent and communication preference records
Website interaction records

B2.5 Educational Content Records

Workbook production files
Digital resource files
Educational content development records
Print specifications
Design and illustration briefs
Curriculum alignment references
Supplier and creative partner briefs
Campaign materials
Moyena Learning Weekly Guide materials

B2.6 Programme, School, Partner, and Impact Records

School or institutional programme records
Partnership reporting records
Aggregated and anonymised campaign reach data
Sponsored learning initiative records
Corporate social investment or foundation-related records
Records relating to partners such as Pick n Pay School Club, delivery partners, or other approved programme partners

B3. Records Available Without a Formal PAIA Request

Certain information may be available on the Moyena Learning website without the need to submit a formal PAIA request, including:

Product information
Website policies
Privacy Policy
Terms of Service
Refund and Cancellation Policy
Shipping and Delivery Policy
Cookie Policy
Contact information
Public campaign information
Publicly available educational resources
Free downloads made available on the website

B4. How to Request Access to Records

Requests for access to records must be submitted in writing to the Information Officer at:

info@moyenalearning.co.za

A request should include:

Full name of the requester
Contact details of the requester
Postal or physical address, where applicable
Description of the record requested
Sufficient detail to identify the record
The right the requester seeks to exercise or protect
Explanation of why the requested record is required to exercise or protect that right
Preferred format of access, such as electronic copy, printed copy, or inspection
Proof of identity, where required
Proof of authority, where the request is made on behalf of another person or organisation

Moyena Group (Pty) Ltd trading as Moyena Learning may require the requester to complete the prescribed PAIA request form or provide additional information required by law.

B5. Fees

A request fee may be payable where prescribed by PAIA or applicable regulations.

Additional fees may apply for:

Searching for records
Preparing records
Copying records
Printing records
Electronic reproduction
Postage or delivery, where applicable

The requester will be informed of any applicable fees before access is granted.

B6. Grounds for Refusal

Access to records may be refused on grounds permitted under PAIA, including but not limited to:

Protection of personal information of third parties
Protection of commercial or confidential information
Protection of intellectual property
Legal privilege
Information provided in confidence
Protection of the safety of individuals
Protection of business operations
Records that cannot reasonably be found or do not exist
Requests that are frivolous, vexatious, or unreasonable

Where access is refused, Moyena Group (Pty) Ltd trading as Moyena Learning will provide reasons for refusal where required by law.

B7. PAIA Guide

The Information Regulator has made available a guide on how to use PAIA and how to exercise rights under PAIA and POPIA.

The PAIA Guide and PAIA Manual templates are available from the Information Regulator of South Africa.

Information Regulator of South Africa
Website: www.inforegulator.org.za
Email: inforeg@justice.gov.za

B8. Remedies Available

If a requester is not satisfied with the outcome of a PAIA request, they may seek relief through the Information Regulator or the courts, where applicable.

Requests, complaints, or enquiries may be directed to the Information Regulator of South Africa.

PART C: PROTECTION OF PERSONAL INFORMATION ACT

C1. Purpose

The Protection of Personal Information Act 4 of 2013 (“POPIA”) regulates the lawful processing of personal information by responsible parties.

Moyena Group (Pty) Ltd trading as Moyena Learning is committed to processing personal information lawfully, transparently, responsibly, and only for purposes that are necessary and relevant to our business, website, products, downloads, communications, and educational programmes.

C2. Categories of Data Subjects

Moyena Group (Pty) Ltd trading as Moyena Learning may process personal information relating to the following categories of data subjects:

Website visitors
Customers
Parents, guardians, caregivers, and educators
Download users
Newsletter subscribers
Learners, where limited information is provided by an authorised adult or institution
School representatives and administrators
Corporate, foundation, and programme partners
Suppliers and service providers
Employees, contractors, and consultants
Job applicants, where applicable
Business contacts and professional advisers

C3. Categories of Personal Information Processed

Moyena Group (Pty) Ltd trading as Moyena Learning may process the following categories of personal information:

Name and surname
Email address
Phone number
Delivery address
Billing information
Province, region, or general location
Order history
Transaction records
Download records
Marketing preferences
Customer support correspondence
Website usage data
IP address and device information
Browser information
School name, grade level, or programme participation information where provided by an authorised adult or institution
Supplier and service provider contact details
Employee, contractor, or applicant information where applicable

Moyena Learning does not knowingly collect personal information directly from children under the age of 18 through standard website downloads or purchases. Downloads and purchases are intended to be completed by a parent, guardian, caregiver, educator, or authorised adult.

C4. Purpose of Processing Personal Information

Personal information may be collected and processed for the following purposes:

Processing and fulfilling product orders
Providing access to free and paid digital downloads
Sending download links and order confirmations
Delivering printed products
Managing customer support queries
Sending educational updates and product information
Sending Moyena Learning Weekly Guide updates
Managing email marketing subscriptions and preferences
Measuring website usage and improving website functionality
Measuring campaign reach and educational programme impact
Reporting aggregated and anonymised campaign data to partners or funders
Managing partnerships, suppliers, and service providers
Complying with legal, tax, accounting, and regulatory obligations
Protecting the security and integrity of the website and business systems
Responding to PAIA, POPIA, legal, or regulatory requests

C5. Lawful Basis for Processing

Moyena Group (Pty) Ltd trading as Moyena Learning processes personal information on the following lawful bases:

Consent: where a person opts in to communications, downloads, marketing, or campaign updates
Contractual necessity: where processing is required to fulfil an order, download request, delivery, or customer service request
Legitimate interest: where processing is necessary to improve educational offerings, website functionality, customer service, programme impact measurement, or business operations
Legal obligation: where processing is required by applicable South African law
Protection of rights: where processing is necessary to establish, exercise, or defend legal rights

C6. Recipients or Categories of Recipients

Personal information may be shared with the following categories of recipients where necessary:

Shopify and e-commerce platform service providers
Payment processing providers
Email marketing and communication platforms
Courier, delivery, pickup point, logistics, and fulfilment partners
Digital download delivery providers
Website analytics providers
Customer support tools
Professional advisers, including accountants, legal advisers, or auditors
Regulators, public bodies, courts, or law enforcement authorities where required by law
Programme partners, funders, or campaign partners, but only in aggregated and anonymised form unless consent has been obtained

Moyena Learning does not sell personal information.

C7. Cross-Border Transfers

Some personal information may be processed or stored outside South Africa where Moyena Group (Pty) Ltd trading as Moyena Learning uses international service providers, platforms, hosting providers, communication tools, or cloud-based systems.

Where personal information is transferred outside South Africa, Moyena Learning will take reasonable steps to ensure that appropriate safeguards are in place and that personal information remains protected in accordance with POPIA.

C8. Security Measures

Moyena Group (Pty) Ltd trading as Moyena Learning implements reasonable technical and organisational measures to protect personal information against loss, unauthorised access, misuse, disclosure, alteration, or destruction.

These measures may include:

Secure hosting through Shopify
Access controls
Password protection
Limited access to personal information by authorised personnel only
Secure payment processing through third-party providers
Internal data handling procedures
Periodic review of privacy and security practices
Supplier and service provider controls where applicable

C9. Retention and Deletion

Personal information is retained only for as long as necessary to fulfil the purpose for which it was collected, or as required by law.

Retention periods may be influenced by:

Order fulfilment requirements
Customer support needs
Tax, accounting, and legal record-keeping obligations
Consent and marketing preference records
Programme impact reporting
Legal claims or dispute resolution requirements

A data subject may request deletion of their personal information, subject to legal retention requirements and any lawful basis for continued processing.

C10. Data Subject Rights

In terms of POPIA, data subjects have the right to:

Be notified when personal information is collected
Access their personal information held by Moyena Group (Pty) Ltd trading as Moyena Learning
Request correction of inaccurate, outdated, or incomplete personal information
Request deletion of personal information, subject to legal retention requirements
Object to the processing of personal information
Withdraw consent at any time, without affecting prior lawful processing
Request details of third parties who have received their personal information
Lodge a complaint with the Information Regulator of South Africa

Requests may be submitted to the Information Officer at:

info@moyenalearning.co.za

C11. Information Regulator Contact Details

Data subjects may lodge complaints with the Information Regulator of South Africa:

Information Regulator of South Africa
Website: www.inforegulator.org.za
Email: inforeg@justice.gov.za
Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001

PART D: AVAILABILITY AND REVIEW

D1. Availability of this Manual

This PAIA and POPIA Manual is available on the Moyena Learning website at:

www.moyenalearning.co.za

A copy may also be requested by contacting the Information Officer at:

info@moyenalearning.co.za

D2. Review of this Manual

This Manual will be reviewed periodically and may be updated where necessary to reflect changes in:

Applicable laws
Business operations
Personal information processing activities
Website functionality
Product, campaign, or programme activities
Regulatory requirements

D3. Approval

This Manual was approved by the Information Officer of Moyena Group (Pty) Ltd trading as Moyena Learning.

Information Officer: Masego Mokgatlha
Title: Founder and Director
Date: 3 June 2026

Moyena Group (Pty) Ltd
Trading as Moyena Learning
Company Registration Number: 2026/168599/07
Address: 99 Sunshine Crescent, Nietgedacht, Fourways, Johannesburg, 1739
Email: info@moyenalearning.co.za
Website: www.moyenalearning.co.za