Section 1
Introduction
This manual is published in terms of Section 51 of the Promotion of Access to Information Act, 2 of 2000 (PAIA), as amended, and is intended to provide sufficient information to enable any person to exercise their right of access to information held by SwapMate.
The right of access to information is not absolute. Access may be refused on grounds specified in PAIA, including where access would unreasonably disclose information about a third party, constitute a breach of confidence, or prejudice the commercial interests of SwapMate.
This manual is available on request and hosted publicly at swapmate.co.za/paia-manual. A copy may also be requested by emailing info@swapmate.co.za.
Section 2
Organisation Details
| Legal name | SwapMate (Pty) Ltd |
| Trading name | SwapMate |
| Registration number | 2026/130270/07 |
| Nature of business | Mobile application platform providing peer-to-peer and B2B item swapping services in South Africa |
| Physical address | 241 Le Roux Avenue, Midrand, Gauteng, 1686 |
| Postal address | 241 Le Roux Avenue, Midrand, Gauteng, 1686 |
| General email | info@swapmate.co.za |
| Website / App | SwapMate mobile application (iOS and Android) |
Section 3
Information Officer
In terms of PAIA and the Protection of Personal Information Act 4 of 2013 (POPIA), SwapMate has designated an Information Officer who is responsible for ensuring compliance with both Acts and for handling requests for access to information.
| Role | Information Officer (Head of Private Body) |
| Registered with | Information Regulator of South Africa |
| privacy@swapmate.co.za | |
| General enquiries | info@swapmate.co.za |
| Address | 241 Le Roux Avenue, Midrand, Gauteng, 1686 |
All PAIA requests must be directed to the Information Officer at privacy@swapmate.co.za. Requests sent to other addresses may be redirected and could result in processing delays.
Section 4
Records Held by SwapMate
SwapMate holds the following categories of records. Not all records are automatically accessible — access is subject to the grounds and process set out in this manual.
👤 User Records
- User profiles and account information
- Authentication and login records
- Profile photos and biographies
- Consent records
- Verification status records
🔄 Transaction Records
- Swap proposals (sent and received)
- Completed swap records
- Exchange code audit logs
- Payment records (via Paystack)
- Premium subscription records
📦 Item Records
- Item listings and descriptions
- Item photos
- Item status history
- Boost and promotion records
- Item view and analytics data
💬 Communication Records
- In-app messages and conversations
- Notification records
- Support communications
- System notifications
🏢 Company Records (B2B)
- Company profiles and details
- Team member records
- Company audit trail logs
- Company analytics data
- Role and permission records
⚖️ Compliance Records
- POPIA consent logs
- Data export requests
- Deletion request logs
- Report and moderation records
- PAIA request logs
Location of Records
All records are stored electronically. SwapMate uses Google Firebase (Firestore database and Cloud Storage) with servers located in the United States (us-central1 region). SwapMate does not maintain physical paper-based records.
Records Available Without a Formal Request
The following are available to users without a formal PAIA request, directly through the app:
- Your own profile information (via Profile screen)
- Your own item listings (via My Items screen)
- Your own swap proposals (via My Swaps screen)
- Your own data export (via Settings → Export My Data)
- This PAIA Manual
- Our Privacy Policy and Terms of Service
Section 5
How to Submit a PAIA Request
Any person wishing to access records held by SwapMate must submit a request using the prescribed Form C (available from the South African Human Rights Commission at sahrc.org.za or by emailing our Information Officer).
Download Form C
Obtain the prescribed PAIA request form (Form C) from the SAHRC website or by requesting it from privacy@swapmate.co.za.
Complete the form
Provide your full name, contact details, a description of the records you are requesting, and the form in which you require access (copy, inspection, etc.).
Submit to the Information Officer
Email the completed form to privacy@swapmate.co.za. You may also post it to our Johannesburg address.
Pay the request fee
A request fee of R140 is payable upon submission. Payment details will be provided on receipt of your request. The fee may be waived at the Information Officer's discretion.
Receive a decision
SwapMate will respond within 30 days of receiving the request. This period may be extended by a further 30 days in complex cases, with notification to the requester.
Note for SwapMate users: If you are requesting access to your own personal information, you may do so directly through the app at no charge (Settings → Export My Data). A formal PAIA request is generally needed for records about third parties or records not available through the app.
Section 6
Fee Schedule
The following fees are prescribed by the PAIA Regulations and apply to requests by private persons. Fees are subject to change in accordance with government regulations.
| Item | Fee |
|---|---|
| Request fee (payable on submission) | R140.00 |
| Reproduction — per A4 page (photocopy) | R2.00 |
| Reproduction — per A4 page (printed) | R2.00 |
| Reproduction — electronic (USB/email) | R40.00 |
| Inspection of records (per hour) | R145.00 |
| Deposit (if reproduction exceeds 2 hours) | One third of total estimated fee |
| Request for own personal information | No request fee |
| Requests in the public interest | Fee may be waived at IO discretion |
All fees are in South African Rand (ZAR). Payment must be made before records are released.
Section 7
Grounds for Refusal
SwapMate may refuse access to records on the following grounds, as provided in PAIA:
- Disclosure would unreasonably disclose personal information of a third party
- Disclosure would constitute a breach of a duty of confidentiality
- Disclosure would prejudice SwapMate's commercial interests or trade secrets
- The request is manifestly frivolous or vexatious
- Disclosure would be in contempt of court
- The records are protected by legal professional privilege
- Disclosure could endanger the safety of an individual
In cases of partial access, SwapMate will disclose the portions of the record to which access can lawfully be granted.
Section 8
Remedies on Refusal
If SwapMate refuses a request for access, the requester has the following remedies:
- Internal appeal: The requester may submit a written appeal to the Information Officer within 60 days of the refusal decision
- Complaint to the Information Regulator: A complaint may be lodged with the Information Regulator of South Africa at inforegulator.org.za
- Court application: The requester may apply to the High Court for relief in terms of Section 82 of PAIA
Information Regulator contact: enquiries@inforegulator.org.za | 010 023 5200 | inforegulator.org.za
Section 9
Services Available
SwapMate provides the following services through its mobile application:
- Item listings: Users can create, browse, and manage swap listings
- Peer-to-peer swapping: Users can propose and complete item exchanges
- In-app messaging: Secure messaging between parties to a swap
- Swap Meets: Private community trading groups
- Groups: Open community groups for discussion
- Premium subscriptions: Enhanced features for individual and business users
- Item boosts: Paid promotion of listings in search results
- B2B marketplace: Dedicated business-to-business trading environment
- Data export: Users can export their personal data at any time
- Account deletion: Users can permanently delete their account and data
All services are governed by SwapMate's Terms of Service and Privacy Policy, available within the app and at the links below.
Section 10
Contact Details
For PAIA requests, queries about this manual, or any information access enquiries:
| Information Officer | privacy@swapmate.co.za |
| General enquiries | info@swapmate.co.za |
| Address | 241 Le Roux Avenue, Midrand, Gauteng, 1686 |
| Privacy Policy | swapmate.co.za/privacy |
| Terms of Service | swapmate.co.za/terms |
Information Regulator of South Africa
| Website | inforegulator.org.za |
| enquiries@inforegulator.org.za | |
| Phone | 010 023 5200 |
South African Human Rights Commission (PAIA)
| Website | sahrc.org.za |
| PAIA Helpline | 011 877 3600 |
This manual is reviewed annually. The next review is due April 2027. Any material changes will be published at this address and communicated via in-app notification.