PAIA Manual — Culltron (Pty) Ltd
Date of compilation: 14 October 2026 · Version 0.1 (draft, 13 Oct 2026)
1. Purpose
This manual helps people request access to records held by Culltron (Pty) Ltd, and describes how Culltron processes personal information.
2. Company details (s51(1)(a))
| Name | Culltron (Pty) Ltd (incorporated 9 June 2026) |
| Director | Ashveer Ramlukan (sole director) |
| Registration number | 2026/455284/07 |
| Information Officer | Ashveer Trevino Ramlukan (appointed 2026-06-09) |
| Information Regulator registration | 2026-063244 (2026-07-28) |
| Deputy Information Officer | None appointed; Ashveer Ramlukan is the Information Officer |
| support@culltron.app | |
| Postal address | 32 Lapwing Avenue, Arena Park, Chatsworth, 4092, KwaZulu-Natal, South Africa (same as physical) |
| Physical address | 32 Lapwing Avenue, Arena Park, Chatsworth, 4092, KwaZulu-Natal, South Africa |
| Website | https://culltron.app |
3. Guide by the Information Regulator (s10)
The Information Regulator has published a Guide on how to use PAIA and POPIA. It is available in all official languages from https://inforegulator.org.za, or from the Information Regulator, Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg (P.O. Box 31533, Braamfontein, 2017). A copy can also be requested from our Information Officer.
4. Records available without a request (s52)
Website content, published API documentation and listings, Terms of Use, Privacy Policy, Acceptable Use Policy, and this manual. No section 52 notice has been published yet.
5. Records available under other legislation
- Companies Act 71 of 2008
- Income Tax Act 58 of 1962
- Tax Administration Act 28 of 2011 (records kept for 5 years)
- Protection of Personal Information Act 4 of 2013
- Electronic Communications and Transactions Act 25 of 2002
6. Subjects and categories of records held
- Company secretarial: incorporation documents, share register, directors' records, minutes
- Finance and tax: financial statements, accounting records, tax returns, bank statements, invoices
- Customers and API consumers: RapidAPI usernames, plan data, support correspondence, operational logs (30-day retention)
- Suppliers and partners: contracts and correspondence
- Technology: source code, system documentation, security records
- Personnel and contractors (if any): contracts and payroll records
- Compliance: POPIA/PAIA records, Information Regulator registration
7. Processing of personal information (POPIA s51(1)(c))
Purpose: providing software and API services, billing via marketplaces, support, security and abuse prevention, statutory compliance, and supplier management.
| Data subjects | Categories of personal information |
|---|---|
| API consumers / customers | name or username, email, organisation, plan, request metadata, IP-related metadata, support messages |
| Suppliers / partners | contact names, emails, phone numbers, banking details, contracts |
| Directors / shareholders | identity details, contact details, as required by the Companies Act |
| Employees / contractors (if any) | identity, contact, banking, tax, employment records |
Recipients: Microsoft Azure (hosting), RapidAPI (marketplace and billing), Google Workspace (email), payment processors, professional advisers, and SARS, CIPC and other regulators where required.
Planned transborder flows: cloud and marketplace providers (Microsoft, RapidAPI, Google) may process data outside South Africa under contractual safeguards (POPIA s72).
Security measures: encryption in transit, managed identities, secret vaulting, least-privilege access, multi-factor authentication on admin accounts, logging with no payloads, and incident response through support@culltron.app.
8. Request procedure
- Complete Form 2 (Request for Access to Record, PAIA Regulations 2021), available from the Information Regulator website, and email it to support@culltron.app.
- Give enough detail to identify the record and the requester. State the form of access you want and, where required, the right you want to exercise or protect.
- We will respond within 30 days (extendable once by up to 30 days with notice, s57).
- Access may be refused on the grounds in Chapter 4 of Part 3 of PAIA (e.g. the privacy of third parties, commercial information, confidential information, the protection of the safety of individuals or property, and legal privilege).
- Personal information correction or deletion requests under POPIA s24 use Form 2 of the POPIA Regulations.
9. Fees
Request and access fees are as prescribed in the PAIA Regulations (Annexure B to the PAIA Regulations 2021, as amended). Personal requesters seeking their own personal information pay no request fee. The applicable fees are those in the current fee schedule published by the Information Regulator (https://inforegulator.org.za). We will tell requesters the amount payable before processing a request.
10. Remedies
There is no internal appeal for a private body. A requester may complain to the Information Regulator within 180 days, or apply to court (s78).
11. Availability and updates
The manual will be published on https://culltron.app and is available free of charge from the Information Officer. It will be reviewed at least annually.
Signed: ______________________ Ashveer Ramlukan, Information Officer · Date: ______