PAIA manual

1. Purpose of this manual

This manual helps you understand what records GetBitcoinLoans holds, how to ask for access to them, and how we process personal information. PAIA gives everyone the right to request access to records held by a private body where the record is required to exercise or protect a right. This manual is required by section 51 of PAIA, and it sits alongside our Privacy Policy, which explains in plainer terms how we handle personal information under POPIA.

2. About GetBitcoinLoans

GetBitcoinLoans (Pty) Ltd (registration number 2025/573818/07) is a private company and the private body to which this manual applies. We are a bitcoin-backed lender, an authorised financial services provider (FSP 55552) and a registered credit provider (NCRCP22583). In this manual, “we”, “us” and “our” mean GetBitcoinLoans.

3. Contact details

Direct all access requests and questions about this manual to our Information Officer.

Head of the body / Information Officer: Taryn Walker (Chief Executive Officer)

Postal address: PO Box 16350, Vlaeberg, Cape Town, Western Cape, 8018

Email (Information Officer): privacy@getbitcoin.loans

General queries: hello@getbitcoin.loans

Website: https://getbitcoinloans.co.za/

4. The PAIA Guide

The Information Regulator has published a guide on how to use PAIA. It explains your rights, how to make a request, and the remedies available to you. The guide is available from the Information Regulator, in each official language and in braille, using the contact details in section 11. You do not need this manual to use the guide, and you do not need the guide to use this manual.

5. Records available without a request

Some records are already available to the public and do not need a PAIA request. These include our website content, our Terms of Service, our Privacy Policy, this manual, and general information about our products. You can access these on our website or by asking us.

6. Records held under other legislation

We hold and keep certain records because other laws require it. This does not mean the records are automatically available; it lists the laws under which we hold them. They include:

• the Companies Act 71 of 2008;
• the Financial Advisory and Intermediary Services Act 37 of 2002 (FAIS);
• the National Credit Act 34 of 2005;
• the Financial Intelligence Centre Act 38 of 2001 (FICA);
• the Protection of Personal Information Act 4 of 2013 (POPIA);
• the Tax Administration Act 28 of 2011 and the Value-Added Tax Act 89 of 1991; and
• employment legislation, where we have employees.

7. Categories of records we hold

We hold records in the following broad categories. Not every record in a category is available on request; access is decided under PAIA.

• Company and statutory records: registration documents, memorandum of incorporation, resolutions, the share register and beneficial-ownership information.
• Financial records: management accounts, tax records, bank records, and invoices.
• Regulatory and compliance records: our FSP licence, NCR registration, FICA and goAML records, our Risk Management and Compliance Programme, POPIA registration, and our policies.
• Customer and loan records: applications, identity and verification records, loan agreements, collateral and custody records, statements, and communications with customers.
• Supplier and service-provider records: contracts and related correspondence.
• Employee records, where we have employees.
• Website and technology records: account, usage and security records.

8. How to request access

To request access to a record, complete the prescribed form (Form 02 of the PAIA Regulations) and send it to our Information Officer at the details in section 3. In your request, give enough detail to identify the record and yourself, say which right you are seeking to exercise or protect and how the record will help, and state how you would like to receive the record.

We will respond within 30 days. We may extend this by a further period allowed under PAIA, and will tell you if we do. We may refuse access on the grounds set out in Chapter 4 of PAIA, for example to protect another person’s personal information, or commercial or confidential information. If we refuse, we will tell you why and explain your remedies.

9. Fees

PAIA provides for two fees: a request fee, payable when you make the request, and an access fee, which covers the cost of finding, preparing and giving you the record. The amounts are those prescribed in the PAIA Regulations. We will let you know what is payable before we do the work.

10. How we process personal information (POPIA)

Our Privacy Policy is the main document explaining how we process personal information, and you should read it for the detail. In summary, and as PAIA requires this manual to record:

• Purposes: to provide and administer loans, to meet our legal and regulatory duties, to prevent fraud, to report to regulators, and to run and improve our service.
• Categories of data subjects: our customers and prospective customers, our website users, our employees, and our suppliers and their representatives.
• Categories of recipients: our service providers, credit bureaux, our professional advisers, and regulators and authorities.
• Cross-border flows: some information is processed outside South Africa, including in the United Kingdom, under a lawful basis and with appropriate safeguards.
• Security: we take reasonable technical and organisational measures to protect personal information.

11. Remedies and the Information Regulator

If we refuse your request, or you are unhappy with how we handled it, you may lodge a complaint with the Information Regulator, or apply to a court, as PAIA allows. The Information Regulator’s details are:

The Information Regulator (South Africa)

Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191.

General enquiries: enquiries@inforegulator.org.za.

PAIA complaints: PAIAComplaints@inforegulator.org.za.

POPIA complaints: POPIAComplaints@inforegulator.org.za.

Telephone: 010 023 5200. Toll free: 0800 017 160.

12. Availability of this manual

This manual is available on our website, at our head office for inspection during office hours, from our Information Officer on request (a fee may apply for a copy), and to the Information Regulator.

13. Updating this manual

We review and update this manual as our records and processing change. The current version and its date appear below.