PAIA & POPIA Manual
Manual in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA), read with the Protection of Personal Information Act 4 of 2013 (POPIA) · Effective 6 August 2026 · Version 1.1
1. The company and its Information Officer
Kliksight (Pty) Ltd, registration number 2026/622670/07, a private body as defined in PAIA. Registered and street address: Stanley and Dock Road, Cape Town, Western Cape, 8001, South Africa; postal address the same.
Information Officer: Michael De Sousa, Director, registered with the Information Regulator under number 2026-063800 (appointed 5 August 2026) · privacy@kliksight.com · postal and hand-delivered requests to the address above, marked for the attention of the Information Officer. The registration is verifiable on the Regulator’s eServices portal.
Kliksight measures invalid traffic in online advertising for marketing agencies and advertisers. A full description of the personal information we process, why, for how long, and the rights of data subjects is set out in our Privacy Policy, which forms part of this manual by reference.
2. The Regulator's guide to PAIA
The Information Regulator has published a Guide in terms of section 10 of PAIA on how to use the Act, in all official languages. It is available from the Information Regulator (South Africa): inforegulator.org.za · JD House, 27 Stiemens Street, Braamfontein, Johannesburg · enquiries via the contact details published on the Regulator’s website. A copy can also be requested from our Information Officer.
3. Records held by Kliksight
| Category | Examples |
|---|---|
| Company and statutory records | Incorporation documents, statutory registers, resolutions |
| Financial and tax records | Accounting records, invoices, bank records, tax filings |
| Contracts and legal | Customer agreements and data processing agreements, supplier contracts, correspondence with advisers |
| Customer and service records | Dashboard account records, support correspondence, billing confirmations from our merchant of record |
| Measurement service data | The data classes described in section 6 of the Privacy Policy (raw event data, statistical aggregates, evidence records, security logs), held for the periods stated there |
| Operational and technical records | System configuration, verification and audit reports, security logs |
| Personnel records | Records relating to directors and any staff or contractors, as required by law |
Records available in terms of other legislation (including the Companies Act, tax legislation, and, where applicable, employment legislation) are held and available as those laws provide. No notice in terms of section 52(2) of PAIA (records automatically available) has been published at this time, save that the Privacy Policy and this manual are freely available on this website.
4. How to request access to a record (PAIA)
Complete the prescribed request form (Form 2 of the PAIA Regulations, available from the Information Regulator’s website or from our Information Officer) and submit it to the Information Officer at the contact details in section 1, together with the prescribed request fee where applicable. Your request must identify the record, the right you seek to exercise or protect if the record is not your own personal information, and the form of access you require. We respond within 30 days as PAIA provides, and may extend once by up to 30 days where the Act permits. Fees for requests, search, preparation and reproduction are those prescribed in Annexure B to the PAIA Regulations, payable as directed by the Information Officer. The prescribed request fee is currently R140.00, payable by a requester other than a personal requester; a personal requester (a person requesting their own personal information) pays no request fee. Where the search for and preparation of a record will exceed the prescribed hours, a deposit of one third of the estimated access fee may be required before the request is processed. If you are unable to complete Form 2 because of illiteracy or disability, you may make your request orally to the Information Officer, who will reduce it to writing and provide you with a copy. Where a requested record contains information about a third party, that third party will be notified and given an opportunity to make representations before a decision on your request is made. If your request is refused, the grounds will be stated with reference to the Act, and you may lodge a complaint with the Information Regulator or apply to court.
5. How to exercise rights over personal information (POPIA)
Data subject rights (access, correction, deletion, and objection) and how requests are routed (including for measurement data, which we process on behalf of the businesses whose advertising is measured) are described in section 14 of the Privacy Policy. Objections are made on Form 1, and correction or deletion requests on Form 2, of the POPIA Regulations, available from the Regulator’s website or from our Information Officer, though we accept plain-language requests to privacy@kliksight.com and will not insist on the form where we can act without it.
6. Processing of personal information (POPIA section 51(1)(c) read with section 17)
The purposes of processing, the categories of data subjects and of personal information, the recipients, planned trans-border flows, and the general description of security measures are set out in the Privacy Policy: purposes and categories in sections 2 to 10; recipients and operators in section 11; trans-border flows and safeguards in section 12; security measures in section 16. In summary: Kliksight processes advertising-measurement event data on behalf of its customers to detect invalid advertising traffic; account, billing and correspondence data for its own customers; and website logs for security, with processing in the United States under contractual safeguards, and security measures including encryption, least-privilege access, multi-factor authentication and automated retention enforcement.
7. Availability of this manual
This manual is published at kliksight.com and is available free of charge from the Information Officer on request, and for inspection at our registered address by arrangement. It will be updated whenever the information in it changes materially.