PAIA Manual

1. Company Details

Name: Rubynet (Pty) Ltd
Registration Number: 2026/345895/07

Head of the private body / Information Officer: Reinhardt Roberts
Rubynet (Pty) Ltd
Postal and street address: 4 Flack Place, Durban North, KwaZulu-Natal, 4051, South Africa
Telephone: +27 87 802 6041
Email: [email protected]

Reinhardt Roberts is the registered Information Officer of Rubynet (Pty) Ltd, registered with the Information Regulator (South Africa) on 21 June 2026 under registration number 2026-033955. This registration can be verified on the Regulator's eServices Portal at https://eservices.inforegulator.org.za.

2. Description of Business

Rubynet (Pty) Ltd is a software development company specialising in property technology and compliance solutions. Our products include RubyFICA (digital FICA compliance), PropSpec (property inspections), Rubyprop (property management), and Ruby Social Hub (social media management for real estate).

3. Guide on How to Use PAIA (Section 10)

The Information Regulator has, under section 10(1) of PAIA, compiled a Guide on how to use PAIA, available in each official language on the Regulator's website (https://inforegulator.org.za). The Guide explains the objects of PAIA and POPIA, how to make a request for access, the assistance available from the Information Officer and from the Regulator, and the remedies available — an internal appeal, a complaint to the Regulator, or an application to court. A requester who needs assistance may contact our Information Officer at the details above.

4. Subjects and Categories of Records Held

Rubynet (Pty) Ltd holds records on the following subjects, in the categories listed under each:

• Company and statutory records — memorandum of incorporation, registration documents, resolutions
• Financial and tax records — accounting records, invoices, statements, tax submissions
• Customer and subscription records — account details, subscriptions, billing and support correspondence
• FICA/KYC records — client due-diligence and screening records processed on behalf of customers (held as operator for the responsible party)
• Supplier and contractor records — service-provider agreements and related correspondence
• Employee records — personnel and payroll records, where applicable
• Product, infrastructure and security records — software, system, audit-log and security records

5. Records Available Without Request

The following categories of records are freely available on our website without the need for a PAIA request:

• Product information and feature descriptions
• Pricing and subscription plans
• Terms of Service, Privacy Policy, and POPIA Statement
• General contact information

6. Records Available on Request

Subject to the grounds for refusal set out in this manual, the following categories of records may be available on request:

• Personal information held about the requester (subject to FICA retention requirements under the FIC Act)
• FICA submission records where the requester is the data subject
• Screening results pertaining to the requester

Note: FICA records are subject to a mandatory 5-year retention period under the Financial Intelligence Centre Act. Records cannot be deleted during this period even upon request.

7. Request Procedure (Section 53)

A requester must complete the prescribed request form (Form 2 of the PAIA Regulations) and submit it to the Head of the private body at the address above, with the prescribed request and access fees (as prescribed under the Regulations to PAIA, as amended). The request must give sufficient particulars to identify the record and the requester, the form of access required, and the right the requester seeks to exercise or protect, with an explanation of why the record is required for that purpose.

8. Fees

Fees applicable to requests for access to records are those prescribed under the Regulations to PAIA, as amended from time to time. A request fee and an access fee may be payable. The Information Officer will notify you of any applicable fees before processing your request.

9. Grounds for Refusal

Access to records may be refused on the following grounds:

• Personal information of third parties (Section 63) — we may not disclose personal information of other data subjects
• Commercial information (Section 64) — trade secrets, proprietary software code, financial information that could harm the company
• Safety of individuals (Section 66) — where disclosure could endanger the safety of any person
• Legal privilege (Section 67) — records subject to legal professional privilege
• Research information (Section 65) — information that would expose research methodology

10. Records Held in Terms of Other Legislation

Records are kept in accordance with, and access to records may be governed or restricted by, the following legislation, among others: Companies Act 71 of 2008; Income Tax Act 58 of 1962; Tax Administration Act 28 of 2011; Value-Added Tax Act 89 of 1991; Protection of Personal Information Act 4 of 2013; Promotion of Access to Information Act 2 of 2000; Financial Intelligence Centre Act 38 of 2001; Electronic Communications and Transactions Act 25 of 2002; Consumer Protection Act 68 of 2008; National Credit Act 34 of 2005; Property Practitioners Act 22 of 2019; Rental Housing Act 50 of 1999; Basic Conditions of Employment Act 75 of 1997; Labour Relations Act 66 of 1995; Unemployment Insurance Act 63 of 2001; Compensation for Occupational Injuries and Diseases Act 130 of 1993.

11. Processing of Personal Information (POPIA Section 51(1)(c))

In line with section 51(1)(c) of POPIA: the categories of data subjects whose personal information is processed include the body's customers and their related FICA subjects, suppliers and any employees; the categories of personal information processed include identity, contact, financial and FICA/KYC information; recipients include screening, hosting and payment-processing service providers; planned cross-border transfers are to hosting and email-delivery providers as set out in our Privacy Policy; and security measures are maintained as contemplated in section 19 of POPIA. Further detail appears in our Privacy Policy at https://rubyfica.co.za/privacy.

12. Availability of this Manual

This Manual is available on our website at https://rubyfica.co.za/paia, and a copy may be requested from the Information Officer. It is available to the Information Regulator on request. The Manual is updated regularly.

13. Remedies

If your request for access is refused, you may apply to the Information Regulator or a court for appropriate relief. The Information Regulator can be contacted at:

The Information Regulator (South Africa)
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
P.O. Box 31533, Braamfontein, 2017
Telephone: 010 023 5200
Toll-free: 080 001 7160
General enquiries: [email protected]
POPIA complaints: [email protected]
PAIA complaints: [email protected]
Website: inforegulator.org.za

Document version 1.0 · Effective date: 21 June 2026 · Next review: 21 June 2027