← Back to MyNeuroPod

PAIA Manual

Manual in terms of section 51 of the Promotion of Access to Information Act, 2000 (Act No. 2 of 2000)

Effective date: 25 May 2026 | Last updated: 26 June 2026

1. Particulars in terms of section 51

This manual is published by EPromotions (Pty) Ltd (Registration No. 2018/560839/07), trading as MyNeuroPod, in compliance with section 51 of the Promotion of Access to Information Act, 2000 (PAIA), as required by South Africa's Information Regulator. It also serves the transparency obligations of the Protection of Personal Information Act, 2013 (POPIA).

2. Contact details

Head of the private body

  • Private body: EPromotions (Pty) Ltd (Registration No. 2018/560839/07), trading as MyNeuroPod
  • Designation: Founder / Information Officer
  • Postal address: Available on request via legal@myneuropod.com
  • Email: legal@myneuropod.com

Information Officer

Our Information Officer can be contacted at legal@myneuropod.com. The Information Officer is responsible for processing all PAIA requests and POPIA data subject access requests.

Information Regulator (South Africa)

3. Guide on how to use the Act

The Information Regulator has compiled a guide in terms of section 10 of PAIA which contains information on how to use the Act. The guide is available at the Regulator's website above and at the South African Human Rights Commission. Members of the public who require assistance may contact the Information Officer above.

4. Notice in terms of section 52(2)

No notice has been published by the Minister to date in terms of section 52(2) of PAIA in respect of records held by MyNeuroPod that are automatically available without a formal access request. Where information is published voluntarily by MyNeuroPod (on the website, in product documentation, or in this manual), no formal request is required.

5. Records held by MyNeuroPod

5.1 Records about the organisation

  • Company registration documents
  • Tax registration and SARS filings
  • Statutory financial records (retained 7 years per Companies Act + Income Tax Act)
  • Sub-processor Data Processing Agreements (DPAs)
  • This PAIA manual and the published Privacy Policy

5.2 Records about users (personal information)

The complete inventory of personal information categories held about each user is set out in the Privacy Policy, section 2. Summary:

  • Account: name, email, password hash, role, registration date
  • Trading profile: experience, instruments, account size band, schedule
  • Voice + session: transcripts, prosody metrics (numerical only), session metadata (raw audio deleted within minutes)
  • Behavioural: scores, intervention records, pre-session checklist, habit pulse responses, foundation interview responses
  • Programme + content: enrolment history, knowledge progress, question bank history, session insights
  • Billing: tier, billing cycle, payment-provider transaction references (no card numbers stored)
  • Technical: IP address, browser/device, session tokens, audit logs
  • Email logs + cookie consents + cancellation reasons + refund/dispute records

5.3 Records held in terms of other laws

  • POPIA: a register of data subject access requests, a register of cookie and analytics consents, a register of consents to process special personal information (health data), risk-disclosure and Terms acceptances, and an audit log of administrator access to user data
  • SARS: transaction history + invoices (7-year retention)
  • Companies Act: shareholder + director registers

6. How to request access to records

6.1 Records about yourself (data subject)

If you are a MyNeuroPod user requesting your own data, the fastest route is the in-product Data Export request in Settings → Privacy. Your request is logged, your identity is verified, and your export is prepared and sent to your account email within 30 days as required by POPIA. No PAIA form is required for your own data.

Alternatively, email legal@myneuropod.com with the subject "Data subject access request — POPIA". We aim to respond within 30 days as required by POPIA.

6.2 Records about other persons or the organisation

Requests for records that are not your own personal information must be made on the prescribed Form C published by the Information Regulator (inforegulator.org.za). The completed form must be emailed to legal@myneuropod.com together with proof of identity.

The Information Officer will respond within 30 days. Refusal grounds and the right to internal appeal are set out in sections 62–76 of PAIA.

6.3 Fees

No fee is charged for a data subject's own personal information (POPIA section 23(1)). Other PAIA requests are subject to the prescribed Regulations under PAIA — a request fee plus access fees calculated per the schedule. The Information Officer will provide a fee quotation before fulfilling such a request.

7. Grounds for refusal

Access may be refused in line with Part 3, Chapter 4 of PAIA, including but not limited to:

  • Protection of third-party personal information (section 63)
  • Protection of commercial information of MyNeuroPod or a third party (section 68)
  • Protection of confidential information supplied in confidence (section 65)
  • Records that would jeopardise security of operations, systems, or persons (section 70)
  • Records subject to legal privilege (section 67)

Mandatory disclosure in the public interest will be assessed in terms of section 70.

8. Right of internal appeal

MyNeuroPod is a private body, so PAIA's internal appeal mechanism does not directly apply. A requester whose request has been refused may either:

  • Lodge a complaint with the Information Regulator (contact details in section 2), or
  • Apply to a court for relief under section 78 of PAIA.

9. Availability of this manual

10. Changes to this manual

MyNeuroPod reserves the right to amend this manual. The effective date at the top of the document reflects the most recent revision. Material changes will be published on the website and, where required by POPIA, communicated to data subjects.