KOTEI DESIGNS

PAIA MANUAL

Prepared in terms of Section 51 of the Promotion of Access to Information Act 2 of 2000 (as amended)

Private Body: Kotei Designs
Registration Number: K2025637887
Version: 1.0
Date of Compilation: 31 August 2026
Date of Revision: 31 August 2026

1. INTRODUCTION

This PAIA Manual has been prepared in terms of Section 51 of the Promotion of Access to Information Act 2 of 2000, as amended ("PAIA").

Kotei Designs is a private body for purposes of PAIA.

The purpose of this Manual is to assist members of the public and other requesters by providing information regarding:

• The records held by Kotei Designs;

• The categories of records that may be available;

• Records that may be accessed without submitting a formal PAIA request;

• The procedure for requesting access to records;

• The Information Officer responsible for dealing with requests;

• The processing of personal information by Kotei Designs;

• The categories of personal information processed by Kotei Designs;

• The categories of persons to whom personal information may relate;

• The categories of recipients to whom information may be supplied;

• The security measures applied to personal information; and

• The remedies available where a requester is dissatisfied with a decision concerning access to information.

This Manual should be read together with the applicable provisions of PAIA, the Protection of Personal Information Act 4 of 2013 ("POPIA"), and other applicable South African legislation.

The existence of a record described in this Manual does not automatically mean that the record will be disclosed. Requests for access will be considered in accordance with PAIA, POPIA and other applicable law.

2. PARTICULARS OF THE PRIVATE BODY

2.1 Name of Private Body

Kotei Designs

2.2 Legal Status

Kotei Designs is registered as a Private Company in the Republic of South Africa.

2.3 Registration Number

K2025637887

2.4 Registered and Physical Address

20337 Bofase Street
Rethabile Gardens
Polokwane
Limpopo
0700
South Africa

2.5 Postal Address

The postal address of Kotei Designs is the same as its registered address unless otherwise communicated by Kotei Designs.

2.6 Telephone

+27 78 923 6459

2.7 Email

info@koteidesigns.site

2.8 Website

koteidesigns.site

3. INFORMATION OFFICER

The Information Officer responsible for PAIA and applicable POPIA-related responsibilities is:

Full Name: Nkosana Prince Shabangu
Position: Information Officer
Private Body: Kotei Designs
Email Address: info@koteidesigns.site
Telephone: +27 78 923 6459

The Information Officer is responsible for, among other things:

• Receiving and considering requests for access to records;

• Assisting with the administration of PAIA requests;

• Facilitating compliance with applicable POPIA obligations;

• Managing relevant personal-information requests;

• Maintaining appropriate records relating to requests;

• Managing or overseeing applicable privacy and information-access processes; and

• Performing other responsibilities assigned by applicable law.

Where required, Kotei Designs may designate Deputy Information Officers or other authorised persons to assist with these responsibilities.

4. THE INFORMATION REGULATOR'S GUIDE

The Information Regulator is required to compile and make available a guide to assist members of the public in understanding and exercising their rights under PAIA and POPIA.

The Guide contains information regarding, among other things:

• The objects of PAIA and POPIA;

• How to request access to records;

• The assistance available from Information Officers;

• The assistance available from the Information Regulator;

• The remedies available where access to information is refused;

• How to lodge complaints; and

• Other rights and procedures available under PAIA and POPIA.

The Guide may be obtained from or accessed through the Information Regulator.

Information Regulator Website:
inforegulator.org.za

5. RECORDS AUTOMATICALLY AVAILABLE

Certain records may be available from Kotei Designs without a person having to submit a formal PAIA request, where appropriate and where the records are publicly available.

These may include:

• Information publicly available on the Kotei Designs website;

• Information regarding Kotei Designs' services;

• Publicly available product information;

• Publicly available portfolio information;

• Public marketing materials;

• Public social-media content;

• Terms and Conditions;

• Refund and Cancellation Policy;

• Privacy Policy;

• Cookie Policy, where applicable;

• Public contact information; and

• Other records that Kotei Designs elects to make publicly available.

The availability of a category of records does not require Kotei Designs to disclose confidential, personal, commercially sensitive or otherwise protected information contained within that category.

Kotei Designs may update the categories of automatically available records from time to time.

6. RECORDS AVAILABLE IN TERMS OF OTHER LEGISLATION

Kotei Designs may hold records in accordance with, or subject to, applicable South African legislation.

Depending on the nature of the record and the activities of the company, this may include legislation such as:

• The Companies Act 71 of 2008;

• The Promotion of Access to Information Act 2 of 2000;

• The Protection of Personal Information Act 4 of 2013;

• The Consumer Protection Act 68 of 2008;

• The Electronic Communications and Transactions Act 25 of 2002;

• Applicable tax legislation;

• Applicable employment and labour legislation;

• The Copyright Act 98 of 1978;

• The Financial Intelligence Centre Act 38 of 2001, where applicable;

• The National Credit Act 34 of 2005, where applicable; and

• Other legislation applicable to the activities and records of Kotei Designs.

This section does not constitute a complete list of all legislation that may apply to Kotei Designs.

7. CATEGORIES OF RECORDS HELD BY KOTEI DESIGNS

Kotei Designs may hold records relating to the following subjects.

7.1 Company and Corporate Records

These may include:

• Company registration documents;

• Incorporation documents;

• Memorandum of Incorporation;

• CIPC records;

• Company resolutions;

• Director-related records;

• Corporate correspondence;

• Regulatory records;

• Business licences or registrations, where applicable;

• Insurance records, where applicable; and

• Other corporate or administrative records.

7.2 Financial and Accounting Records

These may include:

• Quotations;

• Invoices;

• Payment records;

• Payment confirmations;

• Bank-related business records;

• Accounting records;

• Financial statements;

• Tax records;

• Expense records;

• Supplier invoices;

• Contractor payment records; and

• Other records reasonably necessary for accounting and financial administration.

Kotei Designs is not currently registered for VAT. This Manual will be updated if that position changes where appropriate.

7.3 Client and Customer Records

These may include:

• Client names;

• Business or company names;

• Contact details;

• Email addresses;

• Telephone and WhatsApp numbers;

• Business addresses;

• Tax-related information, where supplied;

• Client contracts;

• Signed agreements;

• Quotations and proposals;

• Project briefs;

• Client instructions;

• Client approvals;

• Feedback;

• Revision records;

• Correspondence;

• Service records;

• Invoices;

• Payment confirmations; and

• Other information reasonably necessary to provide or record services.

7.4 Project and Creative Records

These may include:

• Brand strategy documents;

• Brand identity information;

• Project briefs;

• Research materials;

• Design concepts;

• Drafts;

• Working files;

• Revision records;

• Logos;

• Brand guidelines;

• Graphic designs;

• Website designs;

• Website-related project information;

• Marketing materials;

• Packaging designs;

• Print designs;

• Flyers;

• Banners;

• Sticker designs;

• Uniform designs;

• Other physical-product designs;

• Final deliverables; and

• Other creative or project-related records.

Certain records in this category may contain confidential information, intellectual property, trade information or personal information and may therefore not automatically be available for disclosure.

7.5 Communication Records

These may include:

• Emails;

• Gmail and Google Workspace communications;

• Microsoft Outlook communications;

• WhatsApp Business communications;

• Written project communications;

• Written approvals;

• Notices;

• Cancellation communications;

• Refund communications;

• Payment communications;

• Complaint records; and

• Other communications relevant to Kotei Designs' business activities.

7.6 Website and Technology Records

These may include:

• Website contact-form submissions;

• Website enquiries;

• Website analytics;

• Cookie and tracking information;

• Website administration records;

• Hosting-related records;

• Website project records;

• Access records, where applicable;

• Technical records;

• Security-related records; and

• Other records relating to the operation or management of Kotei Designs' digital services.

Certain cybersecurity, system-security or access-control records may be restricted from disclosure where disclosure could reasonably compromise security.

7.7 Marketing and Newsletter Records

These may include:

• Newsletter subscriber records;

• Email marketing records;

• Marketing consent records;

• Marketing preferences;

• Objection and unsubscribe records;

• Campaign records;

• Testimonials;

• Portfolio records;

• Social-media records;

• Promotional content; and

• Other marketing-related records.

7.8 Supplier and Service Provider Records

These may include:

• Supplier contact information;

• Supplier agreements;

• Quotations;

• Invoices;

• Payment records;

• Service-provider contracts;

• Correspondence; and

• Other records reasonably necessary to manage supplier relationships.

7.9 Freelancer and Contractor Records

Kotei Designs may engage freelance designers or other contractors where required for specific projects.

Records may include:

• Contractor contact information;

• Freelancer agreements;

• Confidentiality agreements;

• Project allocations;

• Work records;

• Payment records;

• Correspondence; and

• Other records reasonably required for the working relationship.

8. RECORDS THAT MAY BE RESTRICTED OR REFUSED

The fact that a record is listed in this Manual does not mean that it will necessarily be provided to a requester.

Access may be refused, restricted or limited where PAIA or another applicable law permits or requires this.

Records that may be protected include, where applicable:

• Personal information belonging to clients, employees, contractors or other third parties;

• Confidential information supplied by clients;

• Trade secrets;

• Commercially sensitive information;

• Financial information;

• Information that could cause harm to the commercial interests of another person;

• Confidential communications;

• Intellectual property that is not owned by the requester;

• Unused or preliminary design concepts;

• Internal design processes and methods;

• Internal pricing structures or methodologies;

• Passwords and login credentials;

• Cybersecurity information;

• System-security information;

• Information protected by legal professional privilege;

• Records relating to ongoing legal proceedings, where protected;

• Information supplied to Kotei Designs in confidence; and

• Other information protected from disclosure by PAIA or other applicable law.

Each request will be considered on its own facts and in accordance with applicable law.

9. PROCESSING OF PERSONAL INFORMATION IN TERMS OF POPIA

Kotei Designs processes personal information where reasonably necessary for the operation of its business and the provision of its services.

The processing of personal information may include collection, recording, storage, organisation, use, consultation, communication, transfer, retention, deletion or destruction of personal information.

Kotei Designs processes personal information in accordance with its Privacy Policy and applicable law.

9.1 Purposes for Processing Personal Information

Personal information may be processed for purposes including:

• Responding to enquiries;

• Communicating with prospective clients;

• Preparing quotations and proposals;

• Entering into and administering contracts;

• Providing branding, design, website, printing and related services;

• Managing projects;

• Processing payments;

• Issuing invoices;

• Maintaining financial and business records;

• Managing recurring or ongoing services;

• Managing client communication;

• Managing revisions and approvals;

• Providing customer support;

• Maintaining records of services rendered;

• Complying with legal and regulatory obligations;

• Managing marketing communications;

• Managing newsletter subscriptions;

• Maintaining portfolio records;

• Promoting Kotei Designs and its services where permitted;

• Managing website functionality;

• Analysing website performance;

• Improving services and customer experience;

• Protecting legal rights;

• Resolving disputes;

• Preventing fraud or unauthorised activity; and

• Performing other legitimate and lawful business activities.

10. CATEGORIES OF DATA SUBJECTS AND PERSONAL INFORMATION

Kotei Designs may process personal information relating to the following categories of data subjects.

10.1 Clients and Prospective Clients

Information may include:

• Full names;

• Company names;

• Email addresses;

• Telephone numbers;

• WhatsApp numbers;

• Business addresses;

• Tax or business information where relevant;

• Social-media usernames and links;

• Website information;

• Project information;

• Brand information;

• Payment-related administrative information;

• Contracts;

• Correspondence; and

• Other information reasonably necessary to provide services.

10.2 Newsletter Subscribers and Marketing Contacts

Information may include:

• Names;

• Email addresses;

• Marketing preferences;

• Consent records;

• Objection or unsubscribe records; and

• Other information voluntarily provided.

10.3 Website Visitors and Enquirers

Information may include:

• Names;

• Email addresses;

• Contact details;

• Enquiry information;

• Website interaction information;

• Analytics information;

• Cookie information; and

• Other information submitted through website forms.

10.4 Freelancers and Contractors

Information may include:

• Names;

• Contact details;

• Business information;

• Agreements;

• Payment-related records;

• Work records;

• Correspondence; and

• Other information reasonably necessary to manage the relationship.

10.5 Suppliers and Service Providers

Information may include:

• Contact details;

• Company information;

• Agreements;

• Quotations;

• Invoices;

• Payment records;

• Correspondence; and

• Other information necessary for the business relationship.

11. RECIPIENTS OR CATEGORIES OF RECIPIENTS

Personal information may be supplied or made available to third parties where reasonably necessary and lawful.

Recipients may include:

• Authorised Kotei Designs personnel;

• Freelance designers assigned to relevant projects;

• Contractors;

• Payment service providers;

• Banks or financial institutions;

• Accounting professionals;

• Legal professionals;

• Website hosting providers;

• Domain providers;

• Technology service providers;

• Cloud-storage providers;

• Email and communication providers;

• Project-management platforms;

• Printing or production suppliers where necessary;

• Government or regulatory authorities where disclosure is required;

• Lawful debt-recovery or legal service providers where necessary and lawful; and

• Other service providers reasonably required to operate the business or provide the agreed services.

Personal information will not be disclosed merely because a third party requests it. Disclosure will be subject to applicable law, contractual obligations and the purpose for which the information is required.

12. TRANS-BORDER FLOWS OF PERSONAL INFORMATION

Kotei Designs uses technology, communication, cloud, payment, analytics and other service providers that may process or store information outside the Republic of South Africa.

Where personal information is transferred outside South Africa or processed by an international service provider, Kotei Designs will take reasonable steps to ensure that such processing or transfer is carried out in accordance with applicable legal requirements.

The categories of international service providers may include:

• Cloud-service providers;

• Email-service providers;

• Website and hosting platforms;

• Analytics providers;

• Project-management platforms;

• Communication platforms;

• Design and creative software providers; and

• Other technology service providers.

13. INFORMATION SECURITY MEASURES

Kotei Designs takes reasonable organisational and technical measures intended to protect personal information and business records.

Such measures may include:

• Password protection;

• Access controls;

• Limiting access to information on a need-to-know basis;

• Account authentication;

• Secure communication and cloud platforms;

• Appropriate device and software security;

• Restricting freelancer access to information required for assigned projects;

• Maintaining relevant records;

• Secure deletion or destruction of information where appropriate; and

• Taking reasonable steps to manage security incidents.

No electronic system can be guaranteed to be completely secure.

Kotei Designs will nevertheless take reasonable steps to protect the confidentiality, integrity and availability of information under its control.

14. PROCEDURE FOR REQUESTING ACCESS TO RECORDS

A requester seeking access to a record held by Kotei Designs must follow the applicable PAIA procedure.

The requester should:

1. Identify the record being requested with sufficient detail to enable Kotei Designs to locate it;

2. Complete the prescribed request form applicable to requests for access to records held by a private body;

3. Provide sufficient information to allow the requester to be identified;

4. Provide contact details;

5. Explain the right that the requester seeks to exercise or protect where this is required for a request to a private body;

6. Explain why the requested record is required for the exercise or protection of that right;

7. Specify the preferred form of access, where applicable; and

8. Submit the request to the Information Officer using the contact details contained in this Manual.

Requests should be submitted in writing to:

Information Officer
Kotei Designs
Email: info@koteidesigns.site

A requester may be required to provide additional information reasonably necessary to process the request.

15. FEES

A requester may be required to pay fees prescribed under PAIA and the applicable regulations.

Depending on the nature of the request, this may include:

• A prescribed request fee, where applicable; and

• An access fee relating to the time, reproduction or other costs associated with providing access.

Where a fee is payable, Kotei Designs will notify the requester in accordance with the applicable PAIA process.

Access to a record may be withheld until applicable fees have been paid where PAIA permits this.

The fees applicable at the time of the request will be determined in accordance with the applicable legislation and regulations.

16. DECISION ON REQUESTS

The Information Officer will consider requests in accordance with PAIA and applicable law.

Kotei Designs may:

• Grant access;

• Grant partial access;

• Refuse access;

• Request additional information;

• Notify the requester of applicable fees; or

• Take another action permitted by applicable law.

Where access is refused, restricted or only partially granted, Kotei Designs will provide reasons where required by law.

A decision will be communicated through the appropriate PAIA process.

17. GROUNDS FOR REFUSAL

Kotei Designs may refuse access to records where a ground for refusal applies under PAIA or another applicable law.

Depending on the circumstances, grounds may include protection of:

• Personal privacy;

• Confidential third-party information;

• Trade secrets;

• Commercial information;

• Financial information;

• Confidential contractual information;

• Safety or security;

• Intellectual property;

• Privileged legal communications; or

• Other information protected by law.

Kotei Designs will not refuse a request arbitrarily and will consider each request in accordance with applicable law.

18. REMEDIES AVAILABLE TO REQUESTERS

If a requester is dissatisfied with the manner in which a PAIA request has been handled, the requester may have remedies available under PAIA and other applicable law.

Depending on the circumstances, a requester may:

• Seek clarification from the Information Officer;

• Submit a complaint to the Information Regulator where applicable;

• Seek appropriate dispute resolution; or

• Exercise any other remedy available under applicable South African law.

A requester may also seek legal advice regarding their rights.

19. COMPLAINTS RELATING TO PERSONAL INFORMATION

A person who believes that their personal information has been processed in a manner inconsistent with applicable law may first contact Kotei Designs so that the matter can be investigated.

Privacy-related complaints may be submitted to:

Information Officer
Kotei Designs
Email: info@koteidesigns.site

Nothing in this Manual prevents a person from exercising any right to lodge a complaint with the Information Regulator or pursue another lawful remedy.

20. AVAILABILITY OF THIS MANUAL

This PAIA Manual will be made available by Kotei Designs through appropriate channels.

The Manual may be made available:

• On the Kotei Designs website;

• Upon written request to the Information Officer;

• At the offices of Kotei Designs where applicable; and

• Through other channels required by applicable law or the Information Regulator.

The Information Regulator's eServices platform provides a facility for private bodies to upload PAIA manuals and manage PAIA-related compliance records.

21. UPDATES TO THIS MANUAL

Kotei Designs may update or revise this Manual when:

• Company information changes;

• The Information Officer changes;

• Material categories of records change;

• Personal-information processing activities change;

• Applicable legislation changes;

• Regulatory requirements change; or

• Another revision is reasonably necessary.

The most current applicable version should be used when making a request.

22. IMPORTANT NOTICE REGARDING ACCESS

The purpose of this Manual is to assist requesters in identifying records held by Kotei Designs and understanding how to request access to those records.

This Manual does not:

• Guarantee access to every record requested;

• Override confidentiality obligations;

• Require disclosure of personal information unlawfully;

• Require disclosure of trade secrets or protected commercial information;

• Require Kotei Designs to create records that do not exist; or

• Override any lawful ground for refusal contained in PAIA or another applicable law.

Each request will be considered on its own facts and in accordance with applicable law.

23. APPROVAL

This PAIA Manual has been prepared for Kotei Designs in terms of Section 51 of the Promotion of Access to Information Act 2 of 2000 (as amended).

Approved by:

Nkosana Prince Shabangu
Information Officer
Kotei Designs

Date: 31 August 2026

KOTEI DESIGNS
Registration Number: K2025637887
Website: koteidesigns.site
Email: info@koteidesigns.site
Telephone: +27 78 923 6459