PAIA Manual

Promotion of Access to Information Act 2 of 2000. Last updated: 18 April 2026.

This manual is published in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 by Nanamantis Investment Holdings (Pty) Ltd, a private body operating the Vaulora platform.

1. Contact Details

Private body: Nanamantis Investment Holdings (Pty) Ltd (operating as Vaulora)

Information Officer: Craig G. Lawrence

Email: legal@nanamantis.com

Physical address: Nanamantis Investment Holdings (Pty) Ltd, KwaDukuza, KwaZulu-Natal, South Africa

Deputy Information Officer: Craig Lawrence, legal@nanamantis.com

2. Purpose of This Manual

This manual assists members of the public to exercise their rights under PAIA, describes the categories of records held by Nanamantis Investment Holdings, explains the process for requesting access to records, and sets out the grounds on which access may be refused.

3. Availability

This manual is available on the Vaulora website at vaulora.com/legal/paia, in hard copy on written request to legal@nanamantis.com, and at the South African Human Rights Commission (www.sahrc.org.za).

4. Records Held

4.1 User Account Records

Name, email address, account creation date, settings, and payment history. Data subjects: registered users (senders).

4.2 Vaulora Content Records

Letters, photos, voice notes, videos, delivery dates, occasion tags, and creation and sealing timestamps. Data subjects: registered users. Note: sealed Vaulora content cannot be deleted or modified.

4.3 Recipient Records

Recipient name, email address, WhatsApp number (where provided), delivery timestamps, and first-open timestamps. Data subjects: Vaulora recipients.

4.4 Payment Records

Transaction amounts, dates, and Stripe transaction references. Data subjects: registered users.

4.5 Technical and Operational Records

Server access logs, IP address logs, and error logs. Data subjects: all users.

4.6 Correspondence Records

Support emails, legal correspondence, and regulatory correspondence.

5. Records Available Without a Formal Request

The Terms of Use, Privacy Policy, Cookie Policy, and this PAIA Manual are publicly available at vaulora.com/legal without a formal request.

6. How to Submit a Request

Requests must be submitted on prescribed Form C in terms of section 53(1) of PAIA. Form C is available from the South African Human Rights Commission at www.sahrc.org.za or on written request to legal@nanamantis.com.

Completed Form C must be submitted to legal@nanamantis.com or to the physical address above. Your request must include your full name and contact details, a description of the record requested, your preferred format for access, and if requesting on behalf of another person, proof of authority.

We will respond within 30 days of receipt. If an extension is required, we will notify you before the 30-day period expires.

7. Fees

A request fee of R50.00 is payable before processing, unless you are a personal requester requesting your own personal information. If the request is granted, an access fee based on the prescribed PAIA tariff may apply. We will notify you of the applicable fee before providing access. Where the estimated access fee exceeds R600.00, a deposit of up to one third may be required. Fees are payable by electronic transfer.

8. Grounds for Refusal

Access may be refused on the grounds set out in sections 62 to 69 of PAIA, including mandatory protection of privacy of a third party (s62); protection of commercial information of a third party (s63); protection of confidential information of a third party (s64); protection of safety of individuals (s65); protection of records privileged from production in legal proceedings (s67); and commercial information of the private body (s68).

Where access is refused, we will provide written reasons and inform you of your right to internal appeal and judicial review.

9. Remedies if Request is Refused

You may lodge an internal appeal in terms of section 74 of PAIA within 60 days of our decision; apply to court for relief in terms of section 78 of PAIA within 30 days after the outcome of the internal appeal; or lodge a complaint with the Information Regulator (www.inforeg.org.za).

10. Information Regulator Contact Details

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

11. Updates

This manual will be updated as required by law or when there are material changes to the records held. The current version is always available at vaulora.com/legal/paia.