PAIA MANUAL

DITSHEGO VENTURES (PTY) LTD t/a SCHOOL

In terms of Section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA)

Version: 1.0 Adopted: 2026-08-25 Responsible Party / Private Body: DITSHEGO VENTURES (PTY) LTD (Registration No. 2026/349873/07), trading as SCHOOL Information Officer: MK Ditshego (Moloti Komane Ditshego) Email: moloti@ditshego-ventures.co.za Phone: +27 71 525 7454 Physical address: 273 Ferguson Crescent, Eersterus, Pretoria, 0022, Gauteng, South Africa

This manual is published to satisfy PAIA Section 51 (private bodies) and is cross-referenced by the SCHOOL Privacy Policy (POPIA). A copy is available at https://school.ditshego-ventures.co.za/legal/paia and on request from the Information Officer.

1. INTRODUCTION AND PURPOSE

The Promotion of Access to Information Act 2 of 2000 (PAIA) gives effect to the constitutional right of access to any information held by a public or private body that is required for the exercise or protection of any rights. This manual explains how a person may request records from DITSHEGO VENTURES (PTY) LTD (the "Body") and describes the categories of records the Body holds.

This manual is prepared in compliance with:

• PAIA (Act 2 of 2000) and the Promotion of Access to Information Act Regulations (Government Notice R.598 of 15 April 2011, as amended);
• The Information Regulator's Guidance on PAIA manuals for private bodies; and
• Section 32 of the Constitution of the Republic of South Africa, 1996.

2. THE GUIDE TO PAIA (FORM C) AND WHERE TO GET HELP

PAIA requires the Body to draw a requester's attention to the Guide on how to use PAIA (issued by the South African Human Rights Commission in terms of Section 10 of PAIA, commonly referred to as "Form C"). The Guide explains how to request information in plain language and is available:

• South African Human Rights Commission (SAHRC): https://www.sahrc.org.za
• Information Regulator of South Africa: https://www.justice.gov.za/inforeg/ (PAIA resources)
• By request, free of charge, from the Body's Information Officer (contact details in Section 9).

If a requester is unable to put their request in writing, the Body will assist them to do so, or accept an oral request where the record is clearly identified.

3. PARTICULARS OF THE BODY

No Deputy Information Officers are currently appointed; the Information Officer handles all PAIA and POPIA requests directly. This will be reviewed as the Body grows.

4. STRUCTURE OF THE BODY AND HOW TO LOCATE RECORDS

The Body is a single operating company with functional divisions (product, engineering, finance, legal/compliance, partnerships). Records are held in the following systems:

• Corporate records: CIPC portal, company MOI, SARS eFiling, internal document store.
• Platform / product records: SCHOOL application database (hosted on Supabase; application hosting on Vercel).
• Financial records: Accounting system, payment processors (PayFast for ZAR, Stripe for the bookstore), bank statements (FNB).
• Customer / user records: SCHOOL user accounts and associated personal information (governed by the Privacy Policy and POPIA).
• Communications: Corporate email (Zoho) and platform transactional email (Resend).
• Partnership records: Marketplace partner agreements, NVIDIA Inception correspondence.

Requests are received and logged by the Information Officer, who directs them to the relevant custodian and consolidates the response.

5. DESCRIPTION OF RECORDS (SECTIONS 14 AND 15 OF PAIA)

5.1 Records available without a request (Section 14 / automatic disclosure)

The following records are, or will be, publicly available (on the website or on request):

• This PAIA manual.
• The SCHOOL Privacy Policy and Cookie Policy.
• The Terms of Service and Marketplace Partner Agreement templates.
• The CIPC registration certificate and MOI (on request, subject to data-protection redactions).
• Published product, pricing, and bursary content.

5.2 Records requiring a formal request (Section 15)

The following categories of records are held and may be requested under PAIA. Access may be subject to the grounds for refusal in Chapter 4 of PAIA (e.g. protection of commercial information, confidentiality, personal information of third parties, legally privileged information).

6. HOW TO REQUEST A RECORD (SECTION 18 AND FORM A)

A request for access to a record of the Body must be made using the prescribed form (Form A — Request for access to record of private body), obtainable from the SAHRC, the Information Regulator, or the Body's Information Officer. The completed form must be delivered to the Information Officer by:

• Email: moloti@ditshego-ventures.co.za
• Post: 273 Ferguson Crescent, Eersterus, Pretoria, 0022, Gauteng
• Hand delivery: at the registered address during business hours

The request must:

1. Provide sufficient particularity to enable the record to be identified (see the Guide / Form C for help);
2. Indicate the form of access requested (copy, inspection, or both);
3. State the right being exercised or protected; and
4. Be accompanied by the prescribed request fee (see Section 7), where applicable.

Where the request requires the Body to search for or prepare a record, or to transcribe it, the Body may require the requester to pay a deposit before processing, and the access fee once the record is located.

7. FEES (PAIA REGULATION 9 SCHEDULE)

The Information Officer will confirm the exact fee and any deposit in writing before processing a request that attracts a fee. Indigent requesters may apply for remission of fees in terms of Regulation 11.

8. TIMEFRAMES AND INTERNAL APPEALS (SECTIONS 25–32)

• The Body will notify the requester of its decision within 30 days of receiving a compliant request and the request fee (extendable by up to 30 further days where the request is complex or voluminous, with written notice).
• If the Body refuses access, it will give written reasons citing the specific PAIA ground relied upon and notify the requester of their right to an internal appeal.
• A requester may lodge an internal appeal (Form B) within 60 business days of the refusal or deemed refusal, addressed to the Information Officer.
• If the internal appeal is unsuccessful, or no decision is given, the requester may apply to the Information Regulator or the High Court for appropriate relief.

This manual is reviewed at least annually and upon any material change to the Body's structure, systems, or PAIA/POPIA obligations.

9. CONTACT DETAILS — INFORMATION OFFICER

For POPIA data-subject requests (access, correction, deletion, objection) and PAIA record requests, contact the Information Officer using the details above.

Prepared for DITSHEGO VENTURES (PTY) LTD t/a SCHOOL. Version 1.0 — adopted 2026-08-25. Next review: annual, or upon material change.