PAIA manual
Version 1 · 12 October 2026
This is the manual of Shelveo Spatial Intelligence (Pty) Ltd under section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA). The Act gives effect to the constitutional right of access to information that is held by a private body and is needed to exercise or protect a right. This manual says what records Shelveo holds and how to ask for them.
1. The company and its Information Officer
| Company | Shelveo Spatial Intelligence (Pty) Ltd, a private company |
| Registration number | 2026/587671/07 |
| Based in | Langebaan, Western Cape, South Africa |
| Head of the company and Information Officer | André Oberholzer |
| admin@shelveo.co.za | |
| Website | shelveo.co.za |
Shelveo surveys retail stores with 360° photographs, turns them into floor plans at true scale and provides the platform on which a retailer's staff view and edit those plans.
2. The Information Regulator's guide to PAIA
The Information Regulator publishes a guide, under section 10 of the Act, for anyone who wants to use a right the Act gives. It explains what the Act is for, how to make a request, what help is available and what you can do if a request is refused. The guide is available in the official languages, free of charge, on the Regulator's website (inforegulator.org.za) and from its office:
- Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191
- 010 023 5200 · toll free 0800 017 160
- enquiries@inforegulator.org.za
3. Records available without a request
These are open to anyone, on this website, without a request under the Act:
- what Shelveo does and how to contact us (home page);
- the privacy policy and the POPIA page;
- this manual;
- the open-source notices for the software in the platform.
Shelveo has not published a notice under section 52(2) of the Act.
4. Records kept under other laws
Shelveo keeps records as required by the laws that apply to it, which include, where they apply:
- Companies Act 71 of 2008;
- Income Tax Act 58 of 1962, Tax Administration Act 28 of 2011 and Value-Added Tax Act 89 of 1991;
- Basic Conditions of Employment Act 75 of 1997, Labour Relations Act 66 of 1995, Unemployment Insurance Act 63 of 2001 and Compensation for Occupational Injuries and Diseases Act 130 of 1993;
- Electronic Communications and Transactions Act 25 of 2002;
- Consumer Protection Act 68 of 2008;
- Protection of Personal Information Act 4 of 2013 and Promotion of Access to Information Act 2 of 2000.
A record kept under one of these laws is not for that reason open to everyone: where the law itself gives access, it is given as that law says; otherwise a request is made under PAIA as set out below.
5. Subjects and categories of records Shelveo holds
These records exist; a request for any of them is considered under the Act and may be refused on the grounds in section 9 of this manual.
| Subject | Categories of records |
|---|---|
| Company | Registration documents, memorandum of incorporation, registers of directors and shareholders, resolutions and minutes. |
| Finance and tax | Accounting records, financial statements, invoices, banking records, tax returns and correspondence with the revenue service. |
| People who work for Shelveo | Contracts, payment and tax records, leave and training records, and the accounts through which they use Shelveo's systems. |
| Customers and suppliers | Agreements, quotations, correspondence, billing records and the cost of work done per store. |
| Store surveys done for customers | The 360° photographs of each store, the floor plans, mapping and reports made from them, the customer's product category lists and store planning drawings. Held on the customer's behalf. |
| Accounts and activity on the platform and the Capture app | User and field operator accounts, the record of field work (what was captured, when, where and by whom), the audit trail of changes to access and data, and the time spent mapping each store. |
| Technology | Software source code and documentation, system configuration, security records and backups. |
| Intellectual property and marketing | Trade marks, designs, licences, the website and marketing material. |
6. Personal information Shelveo processes
POPIA requires this manual to describe how Shelveo processes personal information. The detail is in the privacy policy and on the POPIA page; in summary:
| Purpose | To survey stores and provide the platform: signing people in, producing and showing store plans, accounting for field and mapping work, keeping the service secure, and meeting legal duties. |
| Whose information | Field operators; users of the platform (staff of Shelveo and of its customers); customers' and suppliers' contact people; people who happen to be in a store when it is photographed. |
| What information | Names, usernames, email addresses, roles and employer; the location of an operator's phone during a capture and details of the phone; records of actions taken; images in which people may appear. |
| Who receives it | The customer whose store it is and, for an operator, their employer; Shelveo's service providers (Google for sign-in, databases, processing and artificial intelligence; Cloudflare for image storage and delivery); authorities where the law requires. |
| Transfers outside South Africa | The service providers' systems are outside South Africa, mainly in the United States. |
| Security | Individual accounts with a second sign-in step for people who can change a customer's data; each customer's data kept apart; encrypted connections; store images open only to people with access to that store; encryption of the Capture app's working data on the phone; a record of actions that change access or remove data. |
7. How to request access to a record
- Complete Form 2 (Request for access to record) from the PAIA regulations, available at inforegulator.org.za/paia-forms.
- Say enough for us to act on it: who you are, which record you want, the form in which you want it, how to reach you, and which right you want to exercise or protect and why the record is needed for it. If you ask on someone else's behalf, include proof that you may.
- Send it to the Information Officer at admin@shelveo.co.za, with proof of your identity.
- We answer within 30 days, in writing, saying whether access is given and what it costs. The Act allows this to be extended once by up to 30 days, for example where the request covers many records; we will tell you if so.
If the record is about another person or company, the Act may require us to ask them first.
If you only want to see, correct or delete your own personal information, you do not need this process: see Your requests on the POPIA page.
8. Fees
The fees are those prescribed in the PAIA regulations for private bodies. The main ones are:
| Request fee | R140, payable before the request is processed. Not payable when you ask for your own personal information. |
| Copies | R2 for each A4 page, photocopied or printed. |
| Search and preparation | R145 for each hour or part of an hour after the first. If this is expected to take more than six hours, a deposit of one third of the expected fee may be asked. |
The full schedule is published by the Information Regulator with the PAIA forms. We will tell you the fee before you are asked to pay anything beyond the request fee.
9. When a request may be refused
The Act requires or allows a private body to refuse access in the cases set out in sections 63 to 69, which include:
- unreasonable disclosure of personal information about another person;
- trade secrets or commercial information of another party, or information given to us in confidence;
- a risk to the safety of a person or the security of property or of a computer system;
- records protected by legal privilege;
- Shelveo's own trade secrets and commercial information, such as source code;
- research in progress.
A record must nevertheless be given where it would reveal a serious breach of the law or a serious risk to public safety or the environment, and the public interest clearly outweighs the harm (section 70). If we refuse, we will give the reasons and the section of the Act relied on.
10. If you are not satisfied
Shelveo has no internal appeal. If your request is refused, or you disagree with a fee or an extension, you may within 180 days:
- lodge a complaint with the Information Regulator, at the address in section 2; or
- apply to a court with jurisdiction.
11. Availability and updates
This manual is published on this page and is available on request from the Information Officer and to the Information Regulator. It is reviewed and updated when Shelveo's records or the way it handles them change.