PAIA MANUAL

Vehicle Dealerships.co.za > PAIA MANUAL

PAIA Manual of 4SA Group Pty Ltd Trading as VehicleDealerships.co.za

Prepared in terms of the Promotion of Access to Information Act, 2000 and related South African access-to-information requirements.

1. Introduction

This PAIA Manual applies to 4SA Group Pty Ltd, registration number 2025/410641/07, trading as VehicleDealerships.co.za.

The purpose of this Manual is to help members of the public understand what records may be held by 4SA Group Pty Ltd and how to request access to those records where permitted by law.

2. Business Details

Name of Private Body: 4SA Group Pty Ltd
Trading Name: VehicleDealerships.co.za
Registration Number: 2025/410641/07
Website: www.vehicledealerships.co.za
Email: admin@vehicledealerships.co.za
WhatsApp / Phone: 079 421 8557
Address: 35 Main Road, Vereeniging, Gauteng, South Africa

3. Head of Private Body / Information Officer

Information Officer: Corne Enslin — to be registered/confirmed
Email: admin@vehicledealerships.co.za
WhatsApp / Phone: 079 421 8557

No Deputy Information Officer has been appointed at this stage unless published otherwise.

4. Description of Business

4SA Group Pty Ltd operates VehicleDealerships.co.za, an online vehicle marketing and lead-generation platform for registered vehicle dealers.

The platform allows dealers to list and market vehicles and allows public users to browse listings and contact dealers.

VehicleDealerships.co.za does not sell vehicles directly and is not a party to sales between dealers and buyers.

5. Guide on How to Use PAIA

The Information Regulator has made available a guide that explains how to use PAIA and how to exercise rights under PAIA and POPIA.

The guide may be obtained from the Information Regulator South Africa.

6. Records Available Without Formal PAIA Request

Certain information may be available on the website without a formal PAIA request, including:

  • website terms and conditions;
  • privacy policy;
  • cookie policy;
  • refund and cancellation policy;
  • dealer subscription information;
  • legal disclosure information;
  • publicly displayed dealer listings;
  • publicly displayed dealer contact details;
  • general website information; and
  • published marketing information.

7. Categories of Records Held

4SA Group Pty Ltd may hold the following categories of records:

7.1 Company Records

  • company registration documents;
  • director or officer records;
  • company resolutions;
  • statutory records;
  • tax records;
  • legal agreements;
  • business correspondence; and
  • compliance records.

7.2 Financial Records

  • invoices;
  • payment records;
  • subscription records;
  • accounting records;
  • bank records;
  • payment gateway records;
  • debtor records;
  • creditor records; and
  • tax-related records.

7.3 Dealer Records

  • dealer account details;
  • dealership contact information;
  • dealer verification information;
  • subscription package details;
  • stock data;
  • feed information;
  • authorised third-party feed login details, API credentials, tokens, endpoints, or related access information where supplied by the dealer for stock import purposes;
  • communication records;
  • support records;
  • billing records;
  • listing history;
  • suspension or cancellation records; and
  • marketing activity records.

7.4 Vehicle Listing Records

  • vehicle descriptions;
  • photos;
  • stock numbers;
  • VINs where provided;
  • prices;
  • mileage;
  • vehicle specifications;
  • availability status;
  • feed data;
  • uploaded files;
  • listing edits;
  • listing removals; and
  • listing complaints.

7.5 User and Lead Records

  • enquiry records;
  • names and contact details submitted voluntarily;
  • vehicle interest information;
  • lead routing records;
  • dealer response monitoring where available;
  • opt-in and opt-out records; and
  • complaint records.

7.6 Website and Technical Records

  • website logs;
  • security logs;
  • plugin records;
  • hosting records;
  • analytics data;
  • cookie and pixel data;
  • backup records;
  • error logs;
  • access records; and
  • system configuration records.

7.7 Marketing Records

  • social media content;
  • advertising records;
  • campaign performance records;
  • dealer marketing materials;
  • email and WhatsApp marketing records;
  • design files;
  • brand assets; and
  • opt-out records.

7.8 Human Resource Records

Where applicable:

  • staff records;
  • contractor records;
  • recruitment records;
  • agreements;
  • payment records;
  • performance records; and
  • disciplinary records.

8. Records Required by Law

4SA Group Pty Ltd may keep records required by applicable South African laws, including company, tax, accounting, labour, consumer, electronic communications, data protection, and access-to-information laws.

9. Processing of Personal Information

4SA Group Pty Ltd may process personal information for the following purposes:

  • operating the website;
  • creating dealer accounts;
  • managing subscriptions;
  • processing payments;
  • loading and updating vehicle listings;
  • connecting, correcting, uploading, importing, updating, or maintaining dealer stock feeds;
  • routing public enquiries to dealers;
  • monitoring lead activity;
  • communicating with dealers and users;
  • providing support;
  • conducting marketing;
  • maintaining security;
  • preventing fraud and abuse;
  • complying with law; and
  • resolving disputes.

10. Categories of Data Subjects

Personal information may relate to:

  • dealers;
  • dealer representatives;
  • public website users;
  • enquiry submitters;
  • subscribers;
  • service providers;
  • employees or contractors;
  • marketing contacts;
  • complainants; and
  • other persons who interact with the business.

11. Categories of Personal Information Processed

Personal information may include:

  • names;
  • business names;
  • contact numbers;
  • email addresses;
  • WhatsApp numbers;
  • account login information;
  • payment references;
  • subscription information;
  • enquiry messages;
  • dealer profile information;
  • authorised third-party feed credentials where supplied for stock import purposes;
  • marketing preferences;
  • IP addresses;
  • cookie and analytics identifiers;
  • communication records; and
  • other information provided voluntarily or required for the service.

12. Recipients of Personal Information

Personal information may be shared with:

  • relevant dealers receiving enquiries;
  • payment gateways;
  • hosting providers;
  • email and communication providers;
  • advertising platforms;
  • analytics providers;
  • IT service providers;
  • feed/import service providers;
  • authorised third-party stock, API, or advertising platforms where required to connect, verify, correct, upload, import, update, or maintain dealer stock feeds;
  • professional advisers;
  • legal advisers;
  • accountants;
  • regulators;
  • courts; and
  • authorities where required by law.

13. Planned Cross-Border Transfers

Some information may be processed outside South Africa where cloud, hosting, analytics, advertising, email, payment, or software providers are located internationally.

Where cross-border processing takes place, reasonable steps will be taken to protect personal information according to applicable legal requirements.

14. Information Security Measures

4SA Group Pty Ltd aims to protect personal information using reasonable technical and organisational measures, which may include:

  • password controls;
  • restricted access;
  • secure hosting;
  • website security tools;
  • backups;
  • anti-spam measures;
  • malware protection;
  • role-based access where possible;
  • service provider controls; and
  • monitoring of suspicious activity.

15. How to Request Access to Records

A person who wishes to request access to a record must submit a written request to:

Email: admin@vehicledealerships.co.za

The request should include:

  • the requester’s full name;
  • contact details;
  • proof of identity if required;
  • a clear description of the record requested;
  • the right the requester seeks to exercise or protect;
  • why the record is required for that right;
  • the preferred form of access; and
  • any other information required by law.

A prescribed PAIA request form may be required.

16. Request Fees

A request fee, access fee, reproduction fee, or other prescribed fee may be payable where allowed by law.

The requester will be notified if a fee is payable before the request is processed or before access is granted.

17. Grounds for Refusal

Access to records may be refused where allowed by law, including where disclosure would:

  • reveal personal information of another person;
  • reveal confidential commercial information;
  • reveal third-party login credentials or security information;
  • breach legal privilege;
  • prejudice safety or security;
  • interfere with law enforcement;
  • reveal trade secrets;
  • harm commercial interests;
  • breach confidentiality owed to a third party;
  • disclose internal working documents; or
  • otherwise fall under a lawful ground of refusal.

18. Decision on Request

VehicleDealerships.co.za will consider PAIA requests according to applicable law.

If access is granted, the requester will be informed of the form of access and any applicable fees.

If access is refused, reasons will be provided where required by law.

19. Remedies and Complaints

If a requester is dissatisfied with a decision, they may have the right to complain to the Information Regulator or approach a court with jurisdiction, depending on the circumstances and applicable law.

20. Availability of This Manual

This Manual is available on www.vehicledealerships.co.za and may also be requested by emailing:

admin@vehicledealerships.co.za

21. Updates to This Manual

This PAIA Manual may be updated from time to time. The latest version will be published on the website.

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