PAIA Manual

1. About this manual

This manual is published by Apex Pace in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA). It explains what records we hold and how you can request access to them.

It should be read alongside our Privacy Policy, which explains what personal information we process and why, and our Cookie Policy, which covers browser storage.

2. Contact details

Apex Pace is a sole proprietorship operating in South Africa. The head of the private body is also its Information Officer.

All PAIA and POPIA requests, and any question about this manual, should be sent to privacy@apexpace.co.za. We operate online and correspond by email.

3. The PAIA Guide

The Information Regulator has compiled a guide, in terms of section 10 of PAIA, on how to use the Act. It is available free of charge from the Regulator.

Information Regulator (South Africa), JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001. Postal: PO Box 31533, Braamfontein, Johannesburg, 2017. Email: enquiries@inforegulator.org.za. Website: https://inforegulator.org.za/

4. Records available without a request

The following are published on our website and may be accessed without submitting a PAIA request:

• This PAIA manual.
• The Privacy Policy.
• The Cookie Policy.

5. Records available in terms of other legislation

Records may be accessible under other legislation, including the Protection of Personal Information Act 4 of 2013 (a data subject's own personal information), the Companies Act 71 of 2008 where applicable, and tax legislation administered by SARS.

If you are asking for your own personal information as a data subject, you do not need this manual — see the Privacy Policy, which sets out the access, correction and deletion mechanisms built into the app.

6. Categories of records we hold

We hold records in the following broad categories. This describes the subjects and categories, not every individual record.

• Athlete account records — identity, contact details, and profile settings.
• Training records — activities, planned workouts, notes, goals and events.
• Health and wellness records — physiology, device-synced daily metrics, and daily check-in answers.
• Original activity files uploaded or synced from a connected device.
• Coaching records — links between athletes and coaches, and squad membership.
• Consent records — cookie and health-processing decisions.
• Operational records — security and administrative audit logs, and system backups.

7. How to request a record

A request must be made on the prescribed form (Form 2 of the PAIA Regulations) and sent to the Information Officer at the address in section 2 above.

The request must give enough detail to identify the record and the requester, state the form of access required, and give an address in South Africa for our reply. If you are requesting on behalf of somebody else, you must attach proof of your authority.

We will respond within 30 days of receiving the request. That period may be extended in the circumstances PAIA allows, and we will tell you if it is.

Prescribed fees may apply, as set out in the PAIA Regulations. Where a fee is payable we will send you a written estimate before doing the work, and we may require a deposit. A request for your own personal information carries no request fee.

8. Grounds for refusal

PAIA requires or permits a request to be refused in defined circumstances, including where disclosure would unreasonably disclose someone else's personal information, would breach a duty of confidence, or would prejudice commercial information. Where only part of a record must be withheld, we will give you the rest.

If we refuse, we will tell you in writing, give reasons, and set out your remedies.

9. Remedies

There is no internal appeal against a decision of a private body — internal appeal applies to public bodies only.

If you are dissatisfied, you may lodge a complaint with the Information Regulator (POPIAComplaints@inforegulator.org.za) or apply to a court with jurisdiction, in terms of PAIA.

10. Availability of this manual

This manual is published on our website and is available by email on request, free of charge, from the Information Officer.