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PAIA and POPIA Manual - Envy Fincorp (Pty) Ltd t/a Indawo AI

Prepared under section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA), as amended by the Protection of Personal Information Act 4 of 2013 (POPIA) · Version 1.0 · Date: 21 October 2026

1. About this manual

This manual tells you what records Envy Fincorp (Pty) Ltd t/a Indawo AI (“Indawo”, “we”) holds, how to ask for access to them under PAIA, and how we process personal information under POPIA. Indawo is a private body under PAIA.

The manual is available free of charge:

If you ask for a printed copy, we may charge a reasonable fee for printing (PAIA Regulations, Annexure B: R2 per A4 page).

2. Our details

Name Envy Fincorp (Pty) Ltd, trading as Indawo AI
Registration number 2021/756475/07
Type of body Private company (private body under PAIA)
Address (and address for legal notices) 102 Churchill Street, Wendywood, 2090
Postal address to be published
Phone to be published
Email privacy@indawoai.co.za
Website indawoai.co.za
Business Software-as-a-service booking, guest communication and operations platform for South African accommodation businesses

3. Head of the body and Information Officer

Head of the private body Director: Mr D Mhlaba
Information Officer Mr D Mhlaba
Deputy Information Officer to be published
Email for requests privacy@indawoai.co.za
Address 102 Churchill Street, Wendywood, 2090
Information Regulator registration number to be published

4. The Information Regulator’s PAIA Guide

The Information Regulator has published a Guide on how to use PAIA and POPIA (PAIA section 10). It explains your rights, how to make a request, fees and how to complain. You can get it:

You may also inspect a copy of the Guide at our office during normal business hours.

5. Records available without a request (PAIA section 52)

We have not published a notice under section 52(2). The following are available on our website without a PAIA request: our Subscription Agreement, Operator Agreement, Privacy Notice, Acceptable Use Policy, Launch Offer Terms, this manual, and product and pricing information.

6. Records available under other laws

We keep records as required by, among others:

Some of these records may be available to the public or to specific people under those laws (for example company records at CIPC). This list is not complete.

7. Subjects and categories of records we hold

A record listed here is not necessarily available: access is subject to the grounds of refusal in PAIA (section 9).

Subject Categories of records
Company and statutory Memorandum of Incorporation; CIPC registration documents; registers of directors and shareholders; minutes and resolutions; statutory returns
Finance and tax Annual financial statements; accounting records; bank statements; invoices; tax returns and SARS correspondence
Clients Subscription and order forms; operator agreements; client account, billing and contact records; authorised signatory and proof-of-address records; support tickets; correspondence; collections records
Client property data (held as operator) Booking, guest, message, review and check-in records processed for client properties. These belong to the client property as responsible party. Requests for them should be sent to the property; we will forward requests we receive.
Sales and marketing Enquiries, demo requests, Ask Indi lead form records, business prospect records, consent and opt-out records, marketing material
Product and technology Software source code, system design and security documents, audit and server logs, backup records
Suppliers and operators Supplier and operator contracts, invoices and correspondence
Staff Employment and contractor contracts, payroll and tax records, leave records, training and confidentiality undertakings, disciplinary records
Legal and compliance Contracts, legal opinions, litigation records, POPIA and PAIA records (requests, incident register, processing records), Information Regulator correspondence
Intellectual property Trade mark, domain and licence records

8. Processing of personal information (POPIA, PAIA section 51(1)(c))

8.1 Purposes of processing

We process personal information to: run our website, Ask Indi help chat and sign-up; answer enquiries and arrange demos; send one single consent request to business prospects and marketing only with consent or to existing clients (POPIA s69); open, run, bill and support client accounts; verify authority and business addresses and prevent fraud; keep our systems secure; meet our legal, tax and accounting duties; employ and pay staff and contractors; buy from suppliers; and, as operator, provide the Indawo AI services to client properties on their instructions.

8.2 Categories of data subjects and information

Data subjects Categories of personal information
Website and Ask Indi users Typed questions (contact details stripped from logged unanswered questions); server log data (IP address, browser, pages, time)
Enquirers, demo requesters and Ask Indi lead form users Name, property or business name, role, email, phone, questions, conversation notes, consent records
Business prospects Business name, published role email and phone, website, region, public notes, source and date
People signing up or signing in Email, one-time code (hashed), send and delivery data, attempts, IP address, device type
Clients and their users Business and billing details; authorised signatory details including ID/passport number; user names, emails, cell numbers, roles; login and audit records; support tickets; bank details; proof of business address
Marketing contacts Name, email, phone, preferences, opt-in and opt-out records
Guests, bookers and other people whose information we process for client properties (as operator) Names, contact details, nationality, booking details, payment status, check-in details the property collects (for example ID/passport number), messages, reviews, loyalty status, debtor balances
Suppliers and service providers Contact persons, contact details, bank details, invoices, contracts
Staff and contractors Names, ID numbers, contact details, bank and tax details, employment records
Juristic persons (clients, prospects, suppliers) Company names, registration numbers, addresses, contact details, financial and billing information

We do not process special personal information by default. Dietary or accessibility notes that client properties enter for guests may reveal health information; properties are asked to keep these to what is necessary.

8.3 Recipients of personal information

We do not sell personal information.

8.4 Planned transfers outside South Africa

Our main servers are in South Africa. Some providers process information elsewhere: Channex.io (European Union and United Kingdom, only for properties that use live OTA sync); Meta/WhatsApp (USA, EU and other countries, only when WhatsApp is used); YouTube/Google (USA and others, only if a website visitor plays a demo video); and our email delivery provider (South Africa). We transfer information only where POPIA section 72 allows, for example where the recipient is bound by laws or agreements giving adequate protection, or the transfer is needed to perform a contract with or in the interest of the data subject.

8.5 Security measures

We use appropriate, reasonable technical and organisational measures, including: hosting in South Africa with a firewall and automatic security updates; HTTPS/TLS encryption; encryption at rest, with field-level encryption for ID/passport numbers and bank details; role-based access and least privilege; two-factor authentication for administrators and staff; audit logs; encrypted daily backups stored in South Africa and tested restores; written operator contracts; staff confidentiality undertakings and POPIA training; and a security compromise response procedure, including notice to the Information Regulator and affected people under POPIA section 22.

9. How to request access to a record

  1. Complete Form 2 (Request for Access to Record) of the PAIA Regulations, 2021. It is on the Information Regulator’s website, or we will send it to you on request.
  2. Send it to the Information Officer at privacy@indawoai.co.za or 102 Churchill Street, Wendywood, 2090.
  3. Give enough detail for us to identify the record, say how you want access (copy, inspection, electronic), and give your contact details.
  4. Show the right you want to exercise or protect and why the record is needed for it (PAIA section 53(2)(d)).
  5. If you ask on behalf of someone else, attach proof of your authority.
  6. If you cannot read or write or have a disability, you may ask orally; we will complete the form for you and give you a copy.

To ask for your own personal information, to correct or delete it, or to object to its processing, you may also simply email privacy@indawoai.co.za (POPIA sections 23 to 25 and 11(3); POPIA Forms 1 and 2). Confirming whether we hold your information is free.

We will decide within 30 days and tell you in writing. We may extend this once by up to 30 days, with reasons (PAIA section 57). If we do not answer within the time, the request is regarded as refused.

10. Fees

Fees are set in Annexure B of the PAIA Regulations, 2021 (private bodies):

Item Fee
Request fee (not payable if you ask for your own personal information) R140.00
Photocopy or printed copy, per A4 page R2.00
Copy on flash drive (you provide) R40.00
Copy on compact disc (you provide / we provide) R40.00 / R60.00
Transcription of an audio record, per A4 page R24.00
Search and preparation, per hour or part, after the first hour R145.00 (maximum R435.00)
Deposit if search and preparation take more than 6 hours Up to one third of the access fee
Postage, email or electronic transfer Actual cost, if any

We will tell you the fees in writing before we do the work. Fees may change when the Regulations change.

11. Grounds for refusal

We may or must refuse access in the cases set out in PAIA Chapter 4 of Part 3, including to protect: the privacy of other people (s63); commercial information of third parties (s64) and of Indawo (s68); confidential information of third parties (s65); the safety of people and property (s66); records privileged from production in legal proceedings (s67); and research information (s69). We will give reasons for any refusal. We must grant access if the public-interest override in section 70 applies.

12. Remedies

There is no internal appeal for private bodies. If you are not satisfied with our decision, you may, within 180 days:

Complaints about how we process your personal information may be sent to the Information Regulator at POPIAComplaints@inforegulator.org.za or on the eServices portal.

13. Updates

We review this manual at least once a year and update it when our details or processing change.

Issued by the head of the private body: Mr D Mhlaba, Director · Date: 21 October 2026

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