PAIA Manual – The Comfy Club

This PAIA Manual is prepared in accordance with Section 51 of the Promotion of Access to Information Act, 2000 (“PAIA”). It facilitates requests for access to records held by Comfy Club and provides information regarding the processing of personal information in accordance with the Protection of Personal Information Act, 2013 (“POPIA”). This Manual applies to AMAQHAWE SOLUTIONS (PTY) LTD, trading as Comfy Club (Reg. No. 2021/483748/07).

1. INTRODUCTION
This PAIA Manual facilitates requests for access to records held by Comfy Club and provides information regarding the processing of personal information under POPIA.

2. PURPOSE OF THIS MANUAL
2.1 Provide information regarding the records held by Comfy Club.
2.2 Explain how access to those records may be requested.
2.3 Provide details regarding the processing of personal information.
2.4 Assist members of the public in exercising their rights under PAIA and POPIA.

3. COMPANY DETAILS

Business Name AMAQHAWE SOLUTIONS (PTY) LTD Trading as Comfy Club Registration No. 2021/483748/07 Email info@thecomfyclub.co.za Website www.thecomfyclub.co.za

4. INFORMATION OFFICER
The Information Officer is responsible for ensuring compliance with PAIA and POPIA. Information Officer The Director of AMAQHAWE SOLUTIONS (PTY) LTD Email info@thecomfyclub.co.za

5. GUIDE ON HOW TO USE PAIA
A guide regarding PAIA and how to obtain access to information may be obtained from the Information Regulator: Organisation Information Regulator (South Africa) Address JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001 Website www.inforegulator.org.za Email enquiries@inforegulator.org.za

6. RECORDS HELD BY COMFY CLUB
Comfy Club may hold records relating to the following categories:

6.1 Company Records
• Registration documents
• Governance records
• Compliance records
• Corporate records

6.2 Financial Records
• Accounting records
• Invoices
• Tax records
• Banking records
• Supplier payment records

6.3 Customer Records
• Customer account information
• Order records
• Delivery information
• Returns and exchange records
• Customer communication records

6.4 Supplier Records
• Supplier agreements
• Supplier contact information
• Purchase records

6.5 Employee Records
• Employment contracts
• Payroll records
• Training records
• HR documentation

6.6 Marketing Records
• Advertising materials
• Campaign records
• Marketing analytics
• Social media records

6.7 Website Records
• Website usage records
• Website analytics
• Technical logs
• Security records

7. RECORDS AVAILABLE WITHOUT A FORMAL REQUEST

Certain information may be available without a formal PAIA request, including:
• Website content
• Published policies
• Product information
• Marketing materials
• Public company information

8. REQUESTING ACCESS TO RECORDS Requests for access to records must:
8.1 Be submitted in writing.
8.2 Provide sufficient detail to identify the requested record.
8.3 Provide the requester’s contact details.
8.4 Specify the preferred format in which the information should be provided where applicable.
8.5 Provide proof of authority where the request is made on behalf of another person.

9. GROUNDS FOR REFUSAL OF ACCESS
Comfy Club may refuse access to records where permitted under PAIA. Grounds for refusal may include:
• Protection of personal information
• Commercial confidentiality
• Protection of intellectual property
• Legal privilege
• Protection of third-party rights
• Safety and security considerations
• Requests that are manifestly unreasonable

10. FEES
Where permitted by PAIA, prescribed request fees and access fees may apply. Any applicable fees will be communicated before records are released.

11. PROCESSING OF PERSONAL INFORMATION
Comfy Club processes personal information in accordance with POPIA. Personal information may be processed for:
• Customer account administration
• Order fulfilment
• Delivery services
• Customer support
• Legal compliance
• Fraud prevention
• Marketing communications where permitted by law

12. CATEGORIES OF PERSONAL INFORMATION PROCESSED
Depending on the nature of the relationship, Comfy Club may process:
• Names and surnames
• Contact information
• Delivery information
• Payment-related information
• Order history
• Communication records
• Technical and website usage information

13. RECIPIENTS OF PERSONAL INFORMATION
Personal information may be shared with:
• Approved payment processing providers
• Approved courier and logistics providers
• Technology service providers
• Professional advisers
• Regulatory authorities where required by law

14. SECURITY MEASURES
Comfy Club implements reasonable technical and organisational measures to protect personal information, including:
• Access controls
• Secure systems
• Password protection
• Staff confidentiality obligations
• Fraud prevention measures

15. DATA SUBJECT RIGHTS
Individuals may request:
15.1 Access to personal information.
15.2 Correction of inaccurate information.
15.3 Deletion of information where legally permissible.
15.4 Restriction or objection to processing.
15.5 Withdrawal of consent where applicable.

16. COMPLAINTS
Complaints regarding access to information or the processing of personal information may be directed to Comfy Club or to the Information Regulator: Comfy Club info@thecomfyclub.co.za | Information Regulator www.inforegulator.org.za | complaints.IR@justice.gov.za

17. AVAILABILITY OF THIS MANUAL
This Manual is available:
• On the Comfy Club website
• Upon request via email
• In electronic format

18. REVIEW OF THIS MANUAL
This Manual may be updated from time to time to reflect changes in legislation, business operations or compliance requirements. The most recent version shall be published on the Comfy Club website.

19. CONTACT US
Company AMAQHAWE SOLUTIONS (PTY) LTD | Comfy Club Reg. Number 2021/483748/07 Email info@thecomfyclub.co.za Location Durban, KwaZulu-Natal, South Africa