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SWAYPHICS · LEGAL

PAIA
Manual.

This manual explains what records Swayphics may hold, how access to information can be requested and how access requests are handled under applicable law.

Last updated: 1 October 2026
On this page
01 · Purpose 02 · Information Officer contact 03 · Records held 04 · Personal information 05 · Third parties & cross-border processing 06 · Public InnerMe records 07 · Automatically available records 08 · How to request access 08 · Grounds for refusal 09 · Fees 10 · Remedies & complaints 11 · Security 12 · Manual availability 13 · Updates

01 · Purpose

This PAIA Manual is made available to help people understand what information and records may be held by Swayphics and how access requests can be made under the Promotion of Access to Information Act 2 of 2000 (PAIA), as amended.

This manual should be read together with the Swayphics Privacy Policy and Terms & Conditions.

02 · Information Officer contact

Information Officer: Head of Swayphics

Email: info@swayphics.co.za

Requests, notices and questions concerning access to information may be sent to the contact above. Swayphics will process access requests in accordance with PAIA and applicable privacy law.

03 · Records held

Depending on the nature of Swayphics’ operations and the relevant client relationship, records may include:

  • Quotations, proposals, project briefs and accepted project agreements.
  • Invoices, payment records and other business transaction records.
  • Client and prospective-client correspondence, including project enquiries.
  • Design and project-delivery records, including approved deliverables and relevant communications.
  • Website, domain, hosting and technical administration records.
  • Marketing and communications records, including opt-out or suppression records where applicable.
  • Testimonial records and consent or approval information where a testimonial is published.
  • Supplier, contractor or service-provider records, where applicable.

Not every category is necessarily held at all times. Access is subject to PAIA, POPIA, confidentiality duties, third-party rights and other applicable law.

04 · Personal information

Personal information may relate to clients, prospective clients, website visitors, suppliers, contractors, authorised representatives and other people who communicate with Swayphics.

Categories may include names, contact details, project information, communication records, billing information, identification information where lawfully required for a service, testimonial information and technical or website-usage information.

Swayphics aims to process only information that is reasonably necessary for the relevant purpose. The Swayphics Privacy Policy explains the personal-information processing practices in more detail.

05 · Third parties & cross-border processing

Records or personal information may be processed using third-party service providers where reasonably necessary for website operation, hosting, databases, email, analytics, payments, domains or other business services.

The Swayphics website currently uses Supabase for certain database and backend functions and Google Gemini API technology for the public InnerMe AI assistant. Depending on the service and configuration, third-party providers may process or store information outside South Africa. Where applicable, Swayphics will take reasonable steps to meet the requirements of POPIA concerning operators and cross-border transfers.

06 · Public InnerMe records

The public InnerMe service does not ordinarily create a full chat transcript in Swayphics’ own business database merely because a visitor uses the public chat. The conversation context is held in the website session and is processed through the Swayphics backend and Google Gemini API to generate responses.

Swayphics may hold limited technical records associated with operation and abuse prevention, including hashed session or network identifiers and rate-limit information. Where optional website analytics has been accepted, InnerMe may also generate non-content usage events such as conversation starts, message counts, recommendations, enquiry-readiness signals, handoffs, resets and errors.

If a visitor chooses to hand the conversation to Swayphics and submits the resulting enquiry, the information included in that submission may be held as an ordinary enquiry or communication record and may then be accessed subject to PAIA, POPIA, confidentiality duties, third-party rights and other applicable law.

07 · Automatically available records

The following information is generally available without a PAIA request, subject to the content being current:

  • Public website content and service descriptions.
  • Published Privacy Policy, Terms & Conditions and this PAIA Manual.
  • Public portfolio and approved public testimonials.
  • Public social-media profiles linked from the website.

08 · How to request access

A person seeking access to a record should make the request in the manner prescribed by PAIA and provide enough detail to identify the requested record and enable Swayphics to process the request.

Requests should be sent to info@swayphics.co.za. Where a prescribed PAIA form or supporting information is applicable, Swayphics will deal with the request according to the relevant legislation and procedures.

Where a request is for the requester’s own personal information, the request may also be considered under the access rights provided by POPIA.

Swayphics may verify the identity and authority of a requester where reasonably necessary, particularly where the requested record contains personal or confidential information.

09 · Grounds for refusal

Access is not automatic. A request may be refused, deferred or limited where PAIA or another applicable law permits or requires this, including where disclosure would involve the personal information or confidentiality of another person, privileged information, commercially sensitive information, or another protected interest.

Where permitted by law, Swayphics will consider whether partial access can be provided instead of refusing an entire record.

10 · Fees

Any applicable PAIA request, access, search, reproduction or related fees will be dealt with in accordance with the applicable legislation and prescribed fee framework. Swayphics will communicate applicable fees and payment requirements where required before incurring chargeable steps.

11 · Remedies & complaints

Where a requester is dissatisfied with the handling of an access request, the requester may use any internal remedy available under applicable law or approach the Information Regulator or another competent authority/court as provided by law.

Information Regulator: enquiries@inforegulator.org.za · Tel: 010 023 5200

Official PAIA guidance, forms and eServices are available from the Information Regulator.

12 · Security

Swayphics applies reasonable technical and organisational measures to protect records and personal information against unauthorised access, loss, misuse, alteration or disclosure. Security measures are reviewed as the website, services and technology change.

13 · Manual availability

This manual is made available electronically through the Swayphics website. A copy may also be requested by contacting Swayphics at info@swayphics.co.za.

14 · Updates

This manual may be updated when Swayphics’ information holdings, services, contact arrangements or legal obligations change. The latest version will be published on this page.

Last updated: 1 October 2026

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