PAIA Manual

This manual is published in terms of section 51 of the Promotion of Access to Information Act, 2000 (PAIA), by Municipex (Pty) Ltd, trading as NanoCrew (“NanoCrew”, “we”, “us” or “our”), the operator of the KlikSend secure file-transfer service (“KlikSend” or the “Service”). KlikSend lets users upload files and share them through secure, optionally password-protected, expiring links. This manual describes the records we hold in connection with that Service and explains how to request access to them. It is also aligned, where relevant, with the Protection of Personal Information Act, 2013 (POPIA).

This document is a professional template and does not constitute legal advice. The operator should have it reviewed and adapted by qualified legal counsel before relying on it, and should ensure the practices described here accurately reflect how the Service actually operates.

1 / Particulars of the body

The private body to which this manual relates is:

• Name — Municipex (Pty) Ltd, trading as NanoCrew.
• Service operated — KlikSend, a secure file-transfer portal for uploading files and sharing them via secure, expiring, optionally password-protected links.
• Address for requests — correspondence and access requests may be directed to the Information Officer at info@nanocrew.ai.
• Coverage — South Africa · Africa · International.

2 / Information Officer

The Information Officer is responsible for the duties imposed by PAIA and POPIA, including receiving and deciding on requests for access to records held in connection with the KlikSend Service. All requests, queries and complaints relating to this manual or to access requests should be addressed to the Information Officer at info@nanocrew.ai. The Information Officer may designate one or more deputies to assist in the performance of these duties.

3 / The Information Regulator’s PAIA guide

A guide on how to use PAIA has been compiled by the Information Regulator (South Africa) in terms of section 10 of PAIA. The guide contains practical information to assist a person who wishes to exercise a right under PAIA or POPIA. It is available, free of charge, from the Information Regulator. The Regulator’s contact details and a copy of the guide can be obtained from the Regulator’s official website, or by contacting the Regulator directly. The Information Officer can also direct you to the current version of the guide on request.

4 / Categories of records held

The records held by NanoCrew in connection with the KlikSend Service fall into the following categories. Some records are automatically available and others may be requested through the PAIA process described below.

• KlikSend user-account records — information relating to a user’s KlikSend login account, including the email address, name (if provided), a securely hashed password, and email-verification status.
• Uploaded-file metadata — information describing files users upload to and share through KlikSend, such as filenames, file sizes, generated link identifiers, creation and expiry timestamps, whether a transfer is password-protected, and the recipient addresses and optional message used when sharing a transfer. The contents of uploaded files are held in object storage to operate the Service and are not inspected by us beyond what is necessary to provide the file-transfer functionality.
• Operational and security logs — server logs, access and download events, and audit trails generated when the Service is used, kept to operate, secure and troubleshoot KlikSend.
• Billing and operational records — subscription, invoicing, payment and related administrative records arising from the provision of the Service.
• Statutory and corporate records — records NanoCrew is required to keep under legislation such as the Companies Act, tax legislation, and POPIA compliance documentation, to the extent they relate to the operation of the Service.

5 / How to submit a request

A request for access to a record must be made on the prescribed form (Form 2 of the Regulations relating to PAIA) and submitted to the Information Officer at info@nanocrew.ai. The request must:

• provide sufficient particulars to enable the Information Officer to identify the record and the requester;
• indicate the form of access required;
• specify a postal or electronic address in the Republic at which to be informed of the decision;
• identify the right the requester is seeking to exercise or protect, with an explanation of why the requested record is required for that purpose (where the request is made for the protection of a right); and
• if made on behalf of another person, include proof of the capacity in which the requester is acting.

A requester may also exercise POPIA data-subject rights — such as requesting access to, correction of, or deletion of their personal information held in their KlikSend user-account records or uploaded-file metadata — by contacting the Information Officer. We may need to verify the requester’s identity before acting on any request.

6 / Fees

The fees payable for requests are those prescribed under PAIA and its regulations. A request fee may be payable before a request is processed (other than a request for a requester’s own personal information). In addition, an access fee may be payable to cover the cost of reproduction, preparation, search and, where applicable, postage. The Information Officer will notify the requester of any fees payable and may withhold a record until the applicable fees have been paid. Current prescribed amounts can be confirmed with the Information Officer.

7 / Grounds for refusal

The Information Officer may refuse a request for access to a record on any of the grounds permitted under Chapter 4 of Part 3 of PAIA. These include, among others:

• mandatory protection of the privacy of a third party who is a natural person;
• mandatory protection of the commercial information of a third party, such as trade secrets or confidential commercial information;
• mandatory protection of certain information supplied to us in confidence;
• protection of the safety of individuals and the security of property and systems, including the security of the Service and the files users upload;
• information privileged from production in legal proceedings;
• protection of our own commercial information, including research, computer programs and the secure operation of KlikSend; and
• requests that are manifestly frivolous or vexatious, or that would involve an unreasonable diversion of resources.

Where a ground for refusal applies only to part of a record, access will be granted to the remainder of that record to the extent reasonably severable. If a request is refused, the Information Officer will provide reasons and inform the requester of the available remedies, including the right to lodge a complaint with the Information Regulator or to approach a competent court.

8 / Availability and updates

This manual is available from the Information Officer on request and is published on the KlikSend website. We may update it from time to time to reflect changes in our practices or in the law, and will revise the “Last updated” date below accordingly.

Last updated: June 2026 · Municipex (Pty) Ltd t/a NanoCrew · info@nanocrew.ai