# Matterkite PAIA Manual

Prepared under section 51 of the Promotion of Access to Information Act 2 of 2000 (“PAIA”).

## 1 Introduction

1.1 Rare Matter Technologies (Pty) Ltd, registration number 2026/764117/07, trades as **Matterkite** and owns and operates HubHutch. This manual describes the records we hold and how to request access.

1.2 A **Business** is a sole proprietor, company or other organisation using HubHutch’s business service. A **Customer** is an individual using HubHutch’s free customer features for private personal use. This manual also covers records about people who do not have a HubHutch account.

1.3 PAIA allows access to a private body’s records where they are required to exercise or protect a right and the Act’s requirements are met. Listing a record here does not make it publicly available. A requester does not need a paid subscription or an active account.

## 2 Contact

**Head of the company and Information Officer:** Robert Rossouw, Director  
**Email:** hello@matterkite.com  
**Telephone:** +27 83 607 5762  
**Website:** https://matterkite.com

**Correspondence address:**  
89 George Street  
hub24.co.za  
Suite 2203  
7140 Cape Town

This is a virtual correspondence address with no walk-in service. Section 9 addresses availability and inspection of the manual.

## 3 Guide to PAIA

3.1 The Information Regulator publishes a guide explaining PAIA, the assistance available to requesters and how to challenge decisions. The guide and prescribed forms are available from its [PAIA resources page](https://inforegulator.org.za/paia/) or on request from the Regulator. Our Information Officer can help you obtain them.

**Information Regulator:** Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191  
**Telephone:** 010 023 5200  
**General enquiries:** enquiries@inforegulator.org.za  
**PAIA complaints:** PAIAComplaints@inforegulator.org.za  
**Website:** [Information Regulator](https://inforegulator.org.za/)

## 4 Records

### Publicly available records

4.1 Our published product information, Terms and Conditions, Privacy Notice and this manual are available without a formal PAIA request.

### Other record categories

4.2 We hold the following categories of records where they have been created or received:

| Subject | Records |
| --- | --- |
| Company administration | Incorporation and statutory records, company decisions, contracts and correspondence. |
| Finance and suppliers | Accounting and tax records, invoices, subscriptions, supplier agreements and payment references. |
| Accounts and payment connections | Business and Customer account details, Business profiles, permissions, payment-connection records, and any retained earlier verification records and correspondence. |
| Business work | Site details, quotations, jobs, photographs, invoices, staff time and route records, and information about people involved in the work. |
| Customer features | Personal projects, selected Business connections and account relationships. |
| Shared communications | Invitations, shared documents, responses, correspondence and attachments between Businesses and Customers. |
| Service operations | Software and technical records, support enquiries, access and security logs, incident records and provider arrangements. |
| Matterkite personnel | Employment and contractor agreements, payment records and related administration. |
| Information governance | Privacy requests, access decisions, retention and deletion records, notices and Information Officer records. |

### Records held under legislation

4.3 Records created or received under legislation include the following, where applicable:

| Records | Legislation |
| --- | --- |
| Incorporation and company statutory records | Companies Act 71 of 2008. |
| Accounting, tax and supporting transaction records | Income Tax Act 58 of 1962 and Tax Administration Act 28 of 2011. |
| Electronic agreements and transaction records | Electronic Communications and Transactions Act 25 of 2002 and Consumer Protection Act 68 of 2008. |
| Personal information and privacy administration records | Protection of Personal Information Act 4 of 2013 (“POPIA”). |

4.4 Where applicable, employment, payroll and occupational records are held under the Basic Conditions of Employment Act 75 of 1997, Labour Relations Act 66 of 1995, Employment Equity Act 55 of 1998, Unemployment Insurance legislation, Skills Development Levies Act 9 of 1999 and Compensation for Occupational Injuries and Diseases Act 130 of 1993. Access depends on the relevant legislation and PAIA.

## 5 Processing of personal information

5.1 We use personal information to administer Business and Customer accounts, manage subscriptions, verify authority to operate Business accounts, provide Customer tools, deliver support, apply fair use, protect the service and meet legal obligations. We also process work records on Businesses’ lawful instructions.

| People concerned | Information categories |
| --- | --- |
| Businesses and their representatives | Names, contact and Business details, permissions, subscription records, payment-connection information and any retained earlier verification records. |
| Authorised staff and contractors of Businesses | Identity and contact details, assignments, time records and optional workday routes. |
| Customers | Names, contact and account details, Business relationships, personal projects, shared records, correspondence, responses and usage information. |
| Other people recorded by a Business | Contact and site details, documents, photographs, correspondence, transaction information and responses. |
| Website visitors and people contacting us | Device and connection information, enquiries and support correspondence. |
| Matterkite personnel and supplier contacts | Identity, contact, contractual, payment and administration records. |

5.2 Recipients include authorised Business users and Customers within the relevant shared relationship, recipients selected by an account holder, our personnel and advisers, and providers supporting hosting, sign-in, communications and payments. A Customer’s private personal projects are not automatically shared with a Business. Information may also be disclosed to authorities where lawfully required.

5.3 Processing may take place outside South Africa. Current arrangements include Supabase in London, Firebase Authentication in the United States, and Resend email sending in Ireland with data stored in the United States. Other provider operations may involve additional countries. The [Privacy Notice](HubHutch%20Privacy%20Notice%20POPIA.md) identifies the principal providers and explains transfer safeguards.

5.4 Security measures include access permissions, protected connections, restricted administrative access and procedures for handling incidents and privacy requests. The Information Officer reviews risks and coordinates corrective action.

## 6 Access requests

6.1 Send a completed [Form 2: Request for Access to Record](https://inforegulator.org.za/wp-content/uploads/2020/07/InfoRegSA-PAIA-Form02-Reg7.pdf) to our Information Officer. Identify the record, the right you wish to exercise or protect, and why that record is needed. Include your contact details, preferred form of access, proof of identity and, if acting for another person, evidence of your authority.

6.2 We will contact you if further details are needed to identify the record or process the request. Where required, affected third parties will have an opportunity to make representations before a disclosure decision.

6.3 We will decide as soon as reasonably possible, ordinarily within 30 days after receiving the request and required particulars. PAIA permits one extension of up to 30 days on specified grounds. We will give notice within the original period, explaining the extension and how to challenge it.

6.4 A decision granting access will explain the form of access and any fee. A refusal will state the legal grounds and reasons. We will consider releasing an unprotected part of a record where the rest cannot be disclosed. If a record cannot be found or does not exist, we will provide the explanation required by PAIA.

6.5 POPIA also provides rights to ask whether we hold your personal information and to request access, correction or deletion where the law allows it. Contact the Information Officer for those requests. The [Privacy Notice](HubHutch%20Privacy%20Notice%20POPIA.md) explains those rights and the POPIA complaints channel.

## 7 Fees

7.1 The prescribed request fee for a private body is currently R140, subject to applicable exemptions. Access, copying, delivery and permitted search or preparation fees may also apply. The [Information Regulator’s fee schedule](https://inforegulator.org.za/paia-fees-structure-2/) sets out the amounts.

7.2 We will notify you of any fee and lawful deposit before payment is required. A deposit must be repaid if access is refused. Confirmation of whether we hold personal information about you is free; other charges must be permitted by law.

## 8 Complaints

8.1 You may challenge a refusal, failure to respond, extension, fee or form of access through the remedies available under PAIA. Matterkite has no internal PAIA appeal procedure.

8.2 A complaint to the Information Regulator must ordinarily be made within 180 days of the decision or event giving rise to it. Use its [eServices portal](https://eservices.inforegulator.org.za/) or submit [Form 5](https://inforegulator.org.za/wp-content/uploads/2020/07/InfoRegSA-PAIA-Form05-Reg10-1.pdf) through its published complaints channel. You may also apply to a court for relief under PAIA. Our decision notice will explain the applicable remedy and time limit.

## 9 Availability

9.1 The published manual will be available on our website and by email on request. Contact the Information Officer to arrange inspection during normal business hours. Electronic copies and inspection are free. A reasonable charge may apply to a printed copy.

9.2 Our correspondence address is 89 George Street, hub24.co.za, Suite 2203, Cape Town, 7140. It does not provide walk-in inspection. The Information Officer will confirm the inspection arrangements when contacted.

9.3 The Information Officer will review and update the manual when the information changes.