Prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 (as amended)
Date of compilation: 25/06/2025. Date of revision: 25/06/2026.
Download the PAIA Manual (PDF)
1. List of acronyms and abbreviations
Term | Meaning |
|---|---|
CEO | Chief Executive Officer |
DIO | Deputy Information Officer |
IO | Information Officer |
Minister | Minister of Justice and Correctional Services |
Moment | Moment Payco (Pty) Ltd |
PAIA | Promotion of Access to Information Act No. 2 of 2000 (as Amended) |
POPIA | Protection of Personal Information Act No. 4 of 2013 |
Regulator | Information Regulator |
Republic | Republic of South Africa |
2. Purpose of the PAIA manual
This PAIA Manual is useful for the public to:
2.1. check the categories of records held by Moment which are available without a person having to submit a formal PAIA request;
2.2. have a sufficient understanding of how to make a request for access to a record of Moment, by providing a description of the subjects on which Moment holds records and the categories of records held on each subject;
2.3. know the description of the records of Moment which are available in accordance with any other legislation;
2.4. access all the relevant contact details of the Information Officer and Deputy Information Officer who will assist the public with the records they intend to access;
2.5. know the description of the guide on how to use PAIA, as updated by the Regulator and how to obtain access to it;
2.6. know if Moment will process personal information, the purpose of processing of personal information and the description of the categories of data subjects and of the information or categories of information relating thereto;
2.7. know the description of the categories of data subjects and of the information or categories of information relating thereto;
2.8. know the recipients or categories of recipients to whom the personal information may be supplied;
2.9. know if Moment has planned to transfer or process personal information outside the Republic of South Africa and the recipients or categories of recipients to whom the personal information may be supplied; and
2.10. know whether Moment has appropriate security measures to ensure the confidentiality, integrity and availability of the personal information which is to be processed.
3. Key contact details for access to information
3.1. Chief Information Officer
Name: Rael Sarembock
Email: dpo_sa@momentco.net
3.2. Deputy Information Officer
Name: Magallene Budhram
Email: dpo_sa@momentco.net
3.3. Access to information general contacts
Email: paiarequest@momentco.net
3.4. Head Office
Postal Address: Moment Payco Pty Ltd, 4th Floor, The Hudson, 30 Hudson Street, De Waterkant, Cape Town, 8001
Physical Address: Moment Payco Pty Ltd, 4th Floor, The Hudson, 30 Hudson Street, De Waterkant, Cape Town, 8001
Email: info@momentco.net
Website: https://www.momentco.net/
4. Guide on how to use PAIA and how to obtain access to the guide
4.1. The Regulator has, in terms of section 10(1) of PAIA, as amended, updated and made available the revised Guide on how to use PAIA (“Guide”), in an easily comprehensible form and manner, as may reasonably be required by a person who wishes to exercise any right contemplated in PAIA and POPIA.
4.2. The Guide is available in each of the official languages and in braille.
4.3. The aforesaid Guide contains the description of
4.3.1. the objects of PAIA and POPIA;
4.3.2. the postal and street address, phone and fax number and, if available, electronic mail address of
4.3.2.1. the Information Officer of every public body, and
4.3.2.2. every Deputy Information Officer of every public and private body designated in terms of section 17(1) of PAIA and section 56 of POPIA;
4.3.3. the manner and form of a request for
4.3.3.1. access to a record of a public body contemplated in section 11; and
4.3.3.2. access to a record of a private body contemplated in section 50;
4.3.3.3. the assistance available from the IO of a public body in terms of PAIA and POPIA;
4.3.3.4. the assistance available from the Regulator in terms of PAIA and POPIA;
4.3.4. all remedies in law available regarding an act or failure to act in respect of a right or duty conferred or imposed by PAIA and POPIA, including the manner of lodging
4.3.4.1. an internal appeal;
4.3.4.2. a complaint to the Regulator; and
4.3.4.3. an application with a court against a decision by the information officer of a public body, a decision on internal appeal or a decision by the Regulator or a decision of the head of a private body;
4.3.5. the provisions of sections 14 and 51 requiring a public body and private body, respectively, to compile a manual, and how to obtain access to a manual;
4.3.6. the provisions of sections 15 and 52 providing for the voluntary disclosure of categories of records by a public body and private body, respectively;
4.3.7. the notices issued in terms of sections 22 and 54 regarding fees to be paid in relation to requests for access; and
4.3.8. the regulations made in terms of section 92.
4.4. Members of the public can inspect or make copies of the Guide from the offices of the public and private bodies, including the office of the Regulator, during normal working hours.
4.5. The Guide can also be obtained
4.5.1. upon request to the Information Officer;
4.5.2. from the website of the Regulator (https://www.justice.gov.za/inforeg/).
4.6. A copy of the Guide is also available in the following two official languages, for public inspection during normal office hours.
6. The following records are available in accordance with other legislation
Category of Records | Applicable Legislation |
|---|---|
Memorandum of incorporation | Companies Act 71 of 2008 |
PAIA Manual | Promotion of Access to Information Act 2 of 2000 |
7. Schedule of records
We hold the following records:
Department | Record type | Format type |
|---|---|---|
Finance | Invoices, bank statements, reports | Hard copy or electronic format |
Compliance, Operations | KYB documents | Hard copy or electronic format |
Business development | Monthly reports and materials, product and service records | Hard copy or electronic format |
IT | Transaction data, transaction reports, datasets, databases, Information technology | Hard copy or electronic format |
Compliance | Regulatory information, internal policies and procedures, statutory reports | Hard copy or electronic format |
Legal | Agreements and commercial contracts | Hard copy or electronic format |
8. Processing of personal information
8.1. We process the following information
Purpose/Activity | Type of data | Lawful basis for processing |
|---|---|---|
To allow us to contact you | (a) Identity (b) Contact | Necessary for our legitimate interests |
To manage our relationship with you which will include notifying you about changes to our terms or policies | (a) Identity (b) Contact (c) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation |
To authenticate the identity of Clients or End Users and to allow them access to the Moment Platform | (a) Identity (b) Contact (c) KYC and KYB | (a) Necessary for our legitimate interests (b) Performance of a contract with you |
To comply with applicable laws and regulations, including by performing compliance checks, and to respond to valid legal processes from regulatory, judicial or supervisory authorities | (a) Identity (b) Contact (c) KYC and KYB | (a) Necessary to comply with a legal obligation |
To administer and protect our business and the Moment Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting, monitoring, regulatory and risk management obligations and hosting of data) | (a) Identity (b) Contact (c) Usage (d) Payment Data (e) KYC and KYB | (a) Necessary for our legitimate interests (b) Necessary to comply with a legal obligation |
To evaluate and develop new features, services, or improvements to the Moment Platform | (a) Identity (b) Usage (c) Payment Data | Necessary for our legitimate interests |
To comply with rules imposed by payment networks or our payment partners and to enforce our contractual rights | (a) KYC and KYB (b) Usage (c) Payment data | Necessary for our legitimate interests |
To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Usage (d) Marketing and Communications | Necessary for our legitimate interests |
To use data analytics to improve our platforms, customer relationships and experiences | (a) Identity (b) Usage (c) Payment Data | Necessary for our legitimate interests |
8.2. Description of our data subjects and the categories of personal information we may process
Categories of Data Subjects | Personal Information that may be processed |
|---|---|
Customers / Clients / Merchants | name, address, registration numbers or identity numbers, bank details |
Service Providers | names, registration number, vat numbers, address, and bank details |
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal and or a regulatory obligation.
Where required by public interest and legitimate interest.
8.3. The recipients or categories of recipients to whom the personal information may be supplied
We may share your personal data with the parties set out below for the purposes set out in the table Purposes for processing personal information above.
External Third Parties
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
8.4. Planned transborder flows of personal information
We share your personal data within the Moment Group. This may involve transferring your data outside your country of residence.
Many of our external third parties may be based outside your country of residence so their processing of your personal data will also involve a transfer of data outside the UK or your country of residence.
Whenever we transfer your personal data out of your country of residence, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Where we use certain service providers, we may use specific contracts approved for use in South Africa or your country of residence which give personal data the same protection it has in South Africa or your country of residence. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out South Africa or your country of residence.
8.5. Security measures we have implemented to ensure the confidentiality, integrity and availability of the information
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, altered, disclosed or accessed in an unauthorised way. In addition to having a PCI DSS compliant environment, Moment employs various security, and access management tools to ensure maximum security of data whether at rest or in motion. Sensitive payment card details are stored in secured vaults and encrypted or tokenized to replace these sensitive data, reducing the risk of data breaches.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. Availability of the manual
9.1 A copy of the Manual is available
9.1.1 on https://www.momentco.net/, if any;
9.1.3 to any person upon request and upon the payment of a reasonable prescribed fee; and
9.1.4 to the Information Regulator upon request.
9.2 A fee for a copy of the Manual, as contemplated in annexure B of the Regulations, shall be payable per each A4-size photocopy made.
10. Updating of the manual
Moment will on a regular basis update this manual, as and when required.
