PAIA manual
The Promotion of Access to Information Act, 2000 (PAIA) gives everyone the right to ask for records held by a private body when those records are needed to exercise or protect a right. This manual explains which records Sticky Pebble holds, how to ask for them, and what it costs. It also explains how we process personal information, as the Protection of Personal Information Act, 2013 (POPIA) requires.
1. Our details
| Company | Sticky Pebble, a private company, registration number 2026/566743/07, trading as RealShare |
|---|---|
| Head of the company | Francois Erasmus, director |
| Street and postal address | 6 Cape Francolin Road, Monte Christo, Hartenbos, Western Cape, 6520 |
| support@realshare.co.za | |
| Website | https://realshare.co.za |
2. Information Officer
Our Information Officer is Francois Erasmus. Send every PAIA request and every question about personal information to support@realshare.co.za, or by post to the address above. We have no Deputy Information Officer, because we have no other staff.
3. The Regulator's guide to PAIA
The Information Regulator (South Africa) publishes a guide on how to use PAIA, in all eleven official languages. It explains your rights, how to make a request, and what to do if a request is refused. You can read the English guide here or ask the Regulator for a copy:
- Office: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191
- Post: P.O. Box 31533, Braamfontein, Johannesburg, 2017
- Phone: 010 023 5200
- Email: enquiries@inforegulator.org.za
- Website: https://inforegulator.org.za
4. Records you can get without a request
We have not published a notice under section 52(2) of PAIA. These records are freely available on our website, with no request or fee:
- Privacy policy
- Terms
- Delete my data
- This manual
5. Records we keep because the law requires it
- Companies Act 71 of 2008
- Income Tax Act 58 of 1962
- Tax Administration Act 28 of 2011
- Value-Added Tax Act 89 of 1991, where it applies
- Electronic Communications and Transactions Act 25 of 2002
- Consumer Protection Act 68 of 2008
- Protection of Personal Information Act 4 of 2013
6. The records we hold
| Subject | Records |
|---|---|
| Company | Registration documents, the share register, and resolutions of the director |
| Finance and tax | Bank statements, invoices, payment records, accounts and tax returns |
| Customers | Accounts and profiles, imported listings, posts, channel connections, subscription and payment records, and support messages |
| Suppliers | Agreements and correspondence with the companies we use to run the service |
| Security and operations | Activity logs, the audit trail and database backups |
7. How to ask for a record
- Fill in Form 2, the request for access to a record, which you can get from the Regulator's website or from us.
- Send it to our Information Officer at support@realshare.co.za. Say which record you want, how you want to receive it, and which right you need it to exercise or protect.
- We will decide within 30 days. We may extend that once, by up to 30 more days, and will tell you why in writing. If we do not answer in time, the law treats the request as refused.
- If we refuse, we will give our reasons. PAIA allows a private body to refuse on grounds such as protecting another person's privacy or a company's confidential commercial information.
Fees
If you are asking for your own personal information, there is no request fee. Otherwise these fees, set by the PAIA Regulations, apply:
| Request fee | R140.00 |
|---|---|
| Copy of an A4 page | R2.00 per page |
| Search and preparation | R145.00 per hour or part of an hour, the first hour free, at most R435.00 |
| Postage or email | What it actually costs |
If the search will take more than six hours, we may ask for a deposit of one third of the fee first.
If you disagree with our decision
You may complain to the Information Regulator (South Africa) within 180 days, by email to PAIAComplaints@inforegulator.org.za or on its eServices portal, or apply to a court.
8. How we process personal information
Our privacy policy has the full detail. In short:
Why we process it
To run RealShare: to provide agents' accounts, turn their listings into posts, publish those posts to the channels they connect, take subscription payments, answer support messages, keep the service secure, and keep the financial records the law requires.
Whose information, and what
- Customers (estate agents): name, email address, phone and WhatsApp numbers, agency and professional details, brand images, channel connections, listings, posts, and subscription records
- People who contact us: name, email address and what they wrote
- Suppliers: business contact and payment details
- People named in listings an agent imports: whatever the public listing contains
Who receives it
- Vercel, which runs the website and its servers (United States and Europe)
- Neon, which stores the database (Europe)
- Cloudflare R2, which stores photos, videos and backups (Europe)
- Resend, which sends account and billing email (Europe (Ireland))
- ImprovMX, which forwards email sent to our addresses into our inbox (Europe (France))
- Google (Gmail), which holds our support inbox, where your emails to us arrive (United States and elsewhere)
- Anthropic, which generates the wording of posts from listing details (United States)
- Geoapify, which suggests addresses and areas as you type them (Europe)
- Paystack, which takes subscription card payments on its own secure page (South Africa and abroad)
- Meta, X, Google and ByteDance, which receive a post only when you publish to them (United States)
Information sent outside South Africa
Most of the companies above keep information in Europe or the United States. The companies that run the service for us are bound by data processing terms that protect it to a standard comparable to POPIA, as section 72 of POPIA allows. Email you send us passes through ImprovMX and Gmail under their own terms, because you chose to write to us. A post reaches Meta, X, Google or ByteDance only when an agent asks us to publish it there, and from then on that platform's own terms apply.
How we keep it safe
Everything travels over encrypted connections. Passwords are stored only as one way hashes. Access tokens for connected channels are encrypted before they are stored. Sign in and sign up are rate limited, important actions are written to a tamper evident audit trail, the database is backed up every night, and access to our systems is limited to the director.
9. Where to find this manual
This manual is on our website at https://realshare.co.za/paia-manual, and a printed copy can be seen at our registered office by appointment. We will send a copy to anyone who asks, and to the Regulator on request. We update it whenever something in it changes.