PAIA Manual

BrightBroom (Pty) Ltd, registration number 2020/440020/07, is a private company. It trades as ZapZuba, which connects customers with vetted drivers who deliver their vehicles (https://zapzuba.com), and as BrightBroom, a marketplace for home cleaning services (https://brightbroom.com).

This manual is published under section 51 of the Promotion of Access to Information Act, 2000 (PAIA), as amended by the Protection of Personal Information Act, 2013 (POPIA). It explains what records we keep and how you can ask for access to them. One manual covers both businesses, because the same company keeps their records. The manual is free.

Send requests to our Information Officer, Thando Somacele, who is also the head of the company for PAIA purposes, or to our Deputy Information Officer, Sharon Somacele. Our postal address is the same as our street address below.

Company

BrightBroom (Pty) Ltd, registration number 2020/440020/07

Directors

Thando Somacele, Sharon Somacele

Address

0B Cedar Avenue West, Fourways, Randburg, 2191

Email

support@zapzuba.com

Phone / WhatsApp

+27 72 225 1491

Information Officer

Thando Somacele

Deputy Information Officer

Sharon Somacele

The Information Regulator has published a guide on how to use PAIA (section 10). It explains your rights and how to ask public and private bodies for their records. It is free in every official language from the Regulator's website (https://inforegulator.org.za/paia/) and its offices.

Information Regulator: enquiries@inforegulator.org.za, 010 023 5200 or 0800 017 160, Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191.

We have not published a notice under section 52 of PAIA. These records are on our websites for anyone to read, without a request:

• Each brand's Terms of Service, Privacy Policy and cookie information.
• This manual.
• How to become a driver with ZapZuba or a cleaner or Cleaning Partner with BrightBroom.
• Prices: ZapZuba shows the price of a delivery before you book.
• Our contact details.

We have no employees, so we keep no employment records. Drivers and cleaners who find work through us are independent contractors or work for a Cleaning Partner. We are not registered for VAT.

POPIA asks us to describe here how we process personal information. Each brand's Privacy Policy has the full detail: https://zapzuba.com/privacy and https://brightbroom.com/privacy.

We use personal information to:

• provide the delivery or cleaning service that was booked: quotes, bookings, payments, assigning a driver or cleaner, and keeping customers informed;
• verify customers, drivers, cleaners and Cleaning Partners, protect vehicles and homes from fraud and theft, and confirm that people may work in South Africa;
• pay drivers and Cleaning Partners, and keep the financial records the law requires;
• handle complaints, damage claims and disputes;
• keep our websites secure, prevent abuse and improve our services (analytics only with consent);
• send marketing, only with consent or, as POPIA allows, to existing customers about similar services.

Who receives it: the driver or cleaner assigned to a booking sees what they need to do the job; customers see their driver's or cleaner's name and phone number; Cleaning Partners receive their bookings; dealers receive their enquiries; insurers receive what a claim needs; border, customs and police officials and regulators receive what the law requires; our advisers, and a buyer of the business, receive it under confidentiality. We do not sell personal information.

These providers (operators under POPIA) process personal information for us under contract:

Information goes outside South Africa only to the providers above that are based abroad. We use only providers bound by law, binding corporate rules or an agreement to protect it to a standard similar to POPIA (section 72). On a ZapZuba cross-border trip, the driver's passport and the vehicle's papers are disclosed to the other country's officials.

How we protect it:

• Information travels over encrypted connections.
• Identity documents, licences, permits, handover photos and signatures are kept in private storage and shown only after we check who is asking.
• Passwords are stored as secure hashes, never as text.
• Staff access is limited to what each role needs, and we keep backups.
• If a breach puts personal information at risk, we tell the people affected and the Information Regulator, as section 22 of POPIA requires.

• Fill in Form 2 of the PAIA Regulations (https://inforegulator.org.za/wp-content/uploads/2020/07/InfoRegSA-PAIA-Form02-Reg7.pdf) and email it to our Information Officer, or deliver it to our address (section 2).
• Include proof of your identity. If you ask for someone else, include proof that you may act for them.
• Describe the record well enough for us to find it, say how you want access (for example a copy, an electronic copy or to look at it), and how we should tell you our decision.
• Say which right you want to exercise or protect, and why you need the record for it (section 53 of PAIA).

We decide within 30 days of receiving your request. We may extend this once, by up to 30 days, and will tell you why (section 57). If we do not answer in time, the law treats your request as refused (section 58). If a record cannot be found or does not exist, we will tell you so under oath (section 55).

To ask for your own personal information, you can also simply email us at support@zapzuba.com. We may ask you to complete Form 2 so we have what we need, but you do not pay the request fee.

If you need help to make a request, contact the Information Officer.

The PAIA Regulations, 2021 set the fees. We tell you what you will owe before we do the work.

We are not registered for VAT, so no VAT is added. If we refuse access, we refund any deposit.

PAIA lets us refuse access only on the grounds in sections 63 to 69, for example to protect:

• another person's privacy (section 63);
• another company's commercial information (section 64);
• information someone gave us in confidence (section 65);
• the safety of people or property (section 66);
• records privileged from production in legal proceedings (section 67);
• our own commercial information, such as trade secrets (section 68);
• research by us or someone else (section 69).

We must still give access if the record would reveal a serious breach of the law or an imminent and serious risk to public safety or the environment, and the public interest in it clearly outweighs the harm (section 70). If we refuse, we give our reasons.

A private company has no internal appeal. If we refuse your request, or you disagree with a fee or an extension, you may, within 180 days:

• complain to the Information Regulator on Form 5 (PAIAComplaints@inforegulator.org.za); or
• apply to court.

[Attorney: confirm the remedies and time limits under sections 77A and 78 of PAIA]

This manual is published at https://zapzuba.com/paia and https://brightbroom.com/paia. You can also read it, free, at 0B Cedar Avenue West, Fourways, Randburg, 2191 during normal business hours. It is in English; if you need help in another official language, ask the Information Officer.

We update this manual whenever our details or records change. The date at the top shows the latest version.