1. Introduction
This manual is published by Tapnet Solutions (Pty) Ltd (registration number 2023/135522/07) in accordance with section 51 of the Promotion of Access to Information Act 2 of 2000 (“PAIA”) and in satisfaction of the internal record-keeping obligation under section 17 of the Protection of Personal Information Act 4 of 2013 (“POPIA”).
PAIA gives every person the right to access records held by a private body where the record is required for the exercise or protection of any right. This manual describes what records we hold and how to request them.
2. Information Officer and Contact Details
| Field | Detail |
|---|---|
| Head of the Private Body / Information Officer | Wynand de Beer |
| Postal and physical address | 594 Bombani Street, Elarduspark, Gauteng, 0181 |
| Telephone | +27 79 174 8357 |
| Email for PAIA requests | privacy@tradejournal.co.za |
| Alternative email | wynand@tapnet.co.za |
3. Regulator's Guide
The Information Regulator has published a guide for requesters under section 10 of PAIA. It is available from the Regulator’s website at inforegulator.org.za. The guide explains your rights, the procedures, and the remedies available under PAIA.
4. Records Available Without a Formal Request
The following records are already published on our website and may be accessed freely:
5. Records Available Under Other Legislation
Certain records are maintained in compliance with other statutes. Request procedures may be subject to those statutes in addition to PAIA.
| Legislation | Records held |
|---|---|
| Companies Act 71 of 2008 | Memorandum of Incorporation, register of directors, share register, beneficial-ownership register, board minutes |
| Tax Administration Act 28 of 2011 | Company tax records, PAYE records, invoices |
| Value-Added Tax Act 89 of 1991 | VAT records (after VAT registration) |
| Income Tax Act 58 of 1962 | Corporate income tax returns |
| Basic Conditions of Employment Act 75 of 1997 | Employment records (when applicable) |
| Electronic Communications and Transactions Act 25 of 2002 | Website supplier disclosures, transaction records |
| Protection of Personal Information Act 4 of 2013 | User account data, consent records, breach register |
| Consumer Protection Act 68 of 2008 | Subscription records, cancellation records, complaints register |
6. Categories of Records Held
| Category | Description |
|---|---|
| Company records | MOI, share register, directors register, CIPC filings, beneficial-ownership register |
| Financial records | Management accounts, bank statements, invoices, subscription and billing records, tax returns |
| User trade journal data | User-supplied trade entries, trading-account metadata, tags, notes, screenshots |
| User psychological data (special personal information) | Mood scores, psychological notes, pre-trade checklist responses, mindset session records - processed only with explicit consent under POPIA s27(1)(a) |
| Subscription / billing records | Plan type, billing cycle, payment status, payment processor references (when payment processor is integrated) |
| Consent records | legal_consent_log entries: user ID, consent type, version hash, timestamp, IP address, user agent |
| IT and security records | Application logs, authentication logs, rate-limit data, incident register, penetration-test reports |
| Support correspondence | Emails and messages between users and Tapnet Solutions |
7. How to Request Access
- Complete the prescribed Form 02 (request for access to record held by a private body) available from the Information Regulator’s website.
- Submit the form by email to privacy@tradejournal.co.za, or by post to the address above.
- Specify the record requested with sufficient particularity for it to be identified, and the right you are seeking to exercise or protect.
- Pay the prescribed request fee (see paragraph 9). We will acknowledge receipt within five business days and respond within 30 days of receipt of a valid request.
8. Grounds for Refusal
We may refuse access to a record on the grounds set out in PAIA sections 62–69 (Chapter 4, Part 3), including:
- mandatory protection of the privacy of a third party (s63);
- mandatory protection of commercial information of a third party (s64);
- mandatory protection of certain confidential information of a third party (s65);
- mandatory protection of the safety of individuals and of property (s66);
- records privileged from production in legal proceedings (s67);
- commercial information of the private body (s68); and
- research information (s69).
9. Fees
The prescribed request fee, access fee and deposit are as published in the PAIA regulations. The current amounts are available from the Information Regulator and will be communicated to you when you submit a request.
10. Remedies
A requester who is dissatisfied with a decision may apply to the Information Regulator or to a court of competent jurisdiction for appropriate relief, as provided for in PAIA Chapter 5.
11. POPIA Record-Keeping (s17)
As required by POPIA section 17, Tapnet Solutions maintains documentation of all processing operations under its responsibility. That documentation includes:
- a record of the personal information we process and its purpose;
- a record of the data subjects and categories of personal information concerned;
- a description of the recipients and operators;
- information about cross-border transfers;
- a general description of the technical and organisational security measures; and
- retention periods.
Much of this documentation is published in our Privacy Policy, Operator Agreements and Data Retention Policy pages.