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The Studio Hub · PAIA

PAIA manual

Our manual under section 51 of the Promotion of Access to Information Act (PAIA). It tells you what records we hold, how to ask for them, and how we process personal information under POPIA.

Version 1.0. Updated 4 November 2026. The Studio Hub Systems (Pty) Ltd, trading as The Studio Hub.

1. Acronyms used

TermMeaning
"We", "the Company"The Studio Hub Systems (Pty) Ltd
CEOChief Executive Officer
DIODeputy Information Officer
IOInformation Officer
MinisterMinister of Justice and Constitutional Development
PAIAPromotion of Access to Information Act 2 of 2000
POPIAProtection of Personal Information Act 4 of 2013
RegulatorInformation Regulator (South Africa)
ClubA gym, martial arts school, dance or gymnastics studio, or personal trainer that uses our software
HubOur member management software (Dojo Hub, PT Hub, and later Dance Hub and Gymnastics Hub)

2. Purpose of this manual

This manual helps you to:

3. About us

The Studio Hub Systems (Pty) Ltd (registration 2026/813997/07), trading as The Studio Hub, is a South African software company based in Centurion. We sell member management software to clubs. Our products are the Dojo Hub (martial arts) and the PT Hub (personal trainers). The Dance Hub and Gymnastics Hub are coming.

Important for club members. When you are a member of a club that uses our Hub, the club decides what is done with your data. The club is the responsible party. We process that data on the club's behalf as its operator (POPIA section 21). If you want access to your membership records, ask your club first, or use "Download my data" in your club's member app. We will help the club answer.

If you send us a PAIA request for records we hold only for a club, we tell you that within the normal time limits. With your agreement, we pass the request to the club, because the club decides about its own members' records. If you want us to decide it ourselves, we will. We then treat the club as a third party and consult it before we decide (PAIA section 71).

4. Key contact details

Information Officer: Brett Clarke, Director
Email: [email protected]
Phone and WhatsApp: 082 226 0215 (+27 82 226 0215)

Deputy Information Officer: none designated.

Head of the Company: Brett Clarke, Director

Information Regulator registration number of our Information Officer: pending.

Street and postal address: 120 Edison Crescent, Hennopspark, Centurion, 0172, South Africa
Phone: 082 226 0215
Email: [email protected]
Websites: thestudiohub.co.za, dojohub.co.za and pthub.co.za

5. The Regulator's Guide on how to use PAIA

The Regulator has updated and made available the revised Guide on how to use PAIA (the "Guide"), in an easily understandable form, as section 10 of PAIA requires. The Guide is meant to help anyone who wants to exercise a right under PAIA and POPIA.

The Guide explains, among other things:

You can inspect or copy the Guide at our offices during normal working hours, or get a copy from the Regulator. You can also ask our Information Officer for a copy (PAIA Form 1, request for a copy of the Guide from an Information Officer).

The Guide is on the Regulator's website in English and the other official languages, at inforegulator.org.za/paia-guidelines. Direct link to the English version: PAIA Guide (English, PDF).

Information Regulator contact details (as at 4 November 2026):

6. Records you can get without asking (section 52)

We have not published a notice under section 52(2) of PAIA. These are available without a formal request, free of charge:

RecordWhere
This PAIA manualthestudiohub.co.za/paia and dojohub.co.za/paia, and at our office
Privacy policy for our own websites and salesPrivacy policy
List of our sub-processors (suppliers that process data for us)Sub-processors
Product information, prices and terms of service for clubsthestudiohub.co.za, dojohub.co.za, pthub.co.za
Each club's own privacy noticethe club's hub address followed by /#privacy (published by the club through the Hub)

7. Records held under other laws

We keep records as required by the laws below, where they apply to us. This is not a complete list. Where a law gives a right of access, you can use it.

LawExamples of records
Basic Conditions of Employment Act 75 of 1997staff records, pay, hours, leave, where we employ staff
Broad-Based Black Economic Empowerment Act 53 of 2003B-BBEE affidavit or certificate, where we have one
Companies Act 71 of 2008memorandum of incorporation, director records, minutes, resolutions, annual financial statements, securities register
Compensation for Occupational Injuries and Diseases Act 130 of 1993registration and claims records, where we employ staff
Consumer Protection Act 68 of 2008customer agreements and notices. The Act may apply to small clubs below the juristic person threshold (asset value or annual turnover under R2 million), and our club terms are written to be fair to them.
Electronic Communications and Transactions Act 25 of 2002records of electronic transactions and website information, including clubs' online acceptance of our terms and Data Processing Agreement
Employment Equity Act 55 of 1998employment equity records, if we become a designated employer
Income Tax Act 58 of 1962tax returns, PAYE records
Labour Relations Act 66 of 1995disciplinary records, agreements, where we employ staff
Occupational Health and Safety Act 85 of 1993incident records
Promotion of Access to Information Act 2 of 2000this manual, request records, PAIA reports
Protection of Personal Information Act 4 of 2013consent records, operator agreements, breach records, Information Officer registration
Skills Development Levies Act 9 of 1999levy records, where they apply to us
Tax Administration Act 28 of 2011records that support tax returns
Unemployment Insurance Act 63 of 2001UIF records, where we employ staff
Value-Added Tax Act 89 of 1991VAT invoices and records, if and while we are registered for VAT

8. Records we hold

SubjectCategories of records
Company secretarialregistration documents, memorandum of incorporation, director and share records, minutes, resolutions
Finance and taxfinancial statements, management accounts, invoices to clubs, payment records, bank statements, tax records (and VAT records if we are VAT registered), supplier invoices
Clubs (our customers)sign-up records, club profile, agreements and terms accepted, Data Processing Agreements (with the version accepted and when), billing, support tickets and emails, onboarding records
Sales and marketingleads from our websites and forms, demo requests, marketing consent records, campaign records, Meta Conversions API logs (only for visitors who agreed to marketing cookies)
Websiteswebsite visit logs, cookie consent choices, form submissions
Technology and securitysystem documentation, source code, security check results, backup logs, incident and breach register
Supplierssupplier agreements, data processing agreements, invoices
Personnelstaff and contractor agreements, payroll, leave and training records, for anyone we employ or contract
Legal and compliancecontracts, legal advice, POPIA and PAIA records, records of processing, retention schedule, breach response plan
Data processed for clubs (as operator)member records, guardians and children, memberships, billing and debit order details (last 4 digits of bank accounts only), attendance, bookings, gradings, messages, shop orders, signed waivers and contracts, consent log, club website content. These records belong to the club. See section 3.

Being listed here does not mean a record will be released. Access is subject to the grounds of refusal in PAIA.

9. How we process personal information

Why we use it, for our own data (we are the responsible party):

Our lawful grounds are contract, legal duty, consent (marketing, the Meta pixel and advertising cookies) and legitimate interest under POPIA section 11(1)(f) (answering enquiries, keeping the service safe, and the demo builder, which uses a prospect club's public information). Where we rely on legitimate interest, we tell you and you may object.

Why we use it, for club data (we are the club's operator):

We only process club data on the club's instructions, under our Data Processing Agreement (Version 2026-11-04 (v1.0)). The club accepts it by ticking a box on the onboarding page. That acceptance is binding under the Electronic Communications and Transactions Act 25 of 2002 (sections 11, 13 and 22), so it is a written contract for POPIA section 21.

Whose information, and what

PeoplePersonal information
Leads and website visitorsname, email, phone, club name, message, IP address, device and browser data, pages visited, cookie choices, and (only with marketing consent) hashed name, email and phone sent to Meta through the Conversions API
Club owners, admins and staffname, email, phone, role, login and audit records, messages to us
Clubs as businessesbusiness name, registration and VAT numbers, address, billing contact, plan, invoices, payments
Supplierscontact names, emails, phones, bank details for payment
Staff and contractors (where we have them)identity number, contact details, bank details, tax number, pay, leave
Club members, prospects and trial bookings (as operator)name, date of birth, gender, contact details, address, emergency contact, membership and payment history, last 4 digits of bank account, attendance, bookings, gradings, photos (with photo consent), messages, signed documents, consent records
Children (as operator)the same as members, plus guardian details. Guardians sign up and consent for children.
Guardians (as operator)name, contact details, relationship, signatures, billing details
Special personal information (as operator)health or medical notes a member chooses to give (POPIA section 26). Health notes are never sent to the AI. We do not use photos for face recognition, so no biometric processing.

Who receives it

We share personal information only with the following, and only as needed:

RecipientWhy
The club that owns the datait is their data
Supabase Inc. (on AWS)database, file storage, sign-in, server functions
Cloudflare Inc.hosting pages and club websites, DNS, network, bot checks, email routing
Twilio Inc., on each club's own Twilio account (WhatsApp Business sender under the club's own Meta agreement)WhatsApp messages
Resend Inc.sign-in codes and club emails
Zoho Corporationonly when a club connects its own Zoho mailbox
Netcash (Pty) LtdSouth African debit orders (bank details go direct to Netcash)
Yoco, Ozow, Paystack, PayFast, Stripe, PayPal, 9Paycard and online payments, only when a club connects its own account (9Pay not live yet)
Anthropic PBCAI features (Ask Dojo, onboarding pre-fill, demo builder), under its commercial API terms. Anthropic does not train on API data. It keeps API inputs and outputs for a limited period under those terms and its data processing agreement, then deletes them. Every AI call has a token cap. Health notes are never sent.
Meta Platformsthe pixel on our own sites and on club sites where added, only after the visitor accepts marketing cookies; the Conversions API on our own lead forms, only with that consent. For collecting and sending this data, Meta and we can be joint controllers under Meta's Business Tools Terms and its Controller Addendum. After that, Meta uses the data as its own controller under its own policy.
GitHub Inc.encrypted backup copies and source code
Apple, Google, Mozilla push servicespush notifications to members' phones
Our professional advisers (accountants, auditors and legal advisers, when we use them)professional services
SARS, the Regulator, courts, law enforcementwhen the law requires it

Before we add or replace a sub-processor that processes club data, we email the club 30 days ahead and the club may object. The current list is on our sub-processors page.

Transfers across borders

How we keep it safe

10. How to ask for a record

  1. Use the prescribed form. Complete Form 2 (Request for access to record) under regulation 7 of the PAIA Regulations, 2021. It is on the Regulator's PAIA forms page.
  2. Send it to the Information Officer by email to [email protected], or deliver or post it to 120 Edison Crescent, Hennopspark, Centurion, 0172.
  3. Give enough detail so we can find the record, say which form of access you want (copy, inspection, electronic), and how you want to be told of our decision.
  4. Prove who you are. Include a copy of your ID. If you ask on behalf of someone else, include proof of your authority.
  5. Say which right you are exercising or protecting and why you need the record (PAIA section 53).
  6. Pay the fees in the table below. A request fee is payable before we process a request, unless you ask for your own personal information. An access fee may be payable for search, preparation and copies. We may ask for a deposit if the search will take long.
  7. Our answer. We decide within 30 days of receiving a complete request. We may extend this once by up to 30 more days and will tell you why (PAIA sections 56 and 57).
  8. Refusal. We may refuse on the grounds in Chapter 4 of Part 3 of PAIA (for example, to protect another person's privacy, commercial information of a third party, confidential information, or our own commercial information). If part of a record can be released, we will release that part. We will tell you the reasons.
  9. Third parties. If a record contains a third party's information, we must tell them and give them a chance to object before we decide (PAIA section 71).
  10. Remedies. There is no internal appeal against a private body. If you are not happy with our decision, you may lodge a complaint with the Regulator within 180 days of our decision (PAIA sections 77A and 77B), or apply to court (PAIA section 78). Complaints go through the eServices portal or to [email protected].

Fees

The prescribed fees for private bodies under the PAIA Regulations, 2021, as listed by the Regulator as at 4 November 2026 (source):

ItemFee
Request feeR140.00 (not payable if you ask for your own personal information)
Photocopy or printed copy, per A4 pageR2.00 per page or part of a page
Copy in a computer readable formR40.00 on a flash drive or CD you supply; R60.00 on a CD we supply
Transcription of an audio record, per A4 pageR24.00
Copy of an audio recordR40.00 on a flash drive or CD you supply; R60.00 on a CD we supply
Transcription or copy of visual imagesthe cost quoted by the service provider we use
Search and preparationR145.00 per hour or part of an hour, not counting the first hour, up to R435.00 in total
Depositif the search will take more than 6 hours, one third of the access fee
Postage, email or other electronic transferthe actual cost

You may apply to court to set aside a fee or deposit.

Your own personal information

You may ask us, free of charge, to confirm whether we hold personal information about you (POPIA section 23). To get a copy of it, use Form 2 of the PAIA Regulations; no request fee applies, but an access fee may. To ask us to correct or delete it, use Form 2 of the POPIA Regulations (Request for correction or deletion of personal information), or simply email the Information Officer (POPIA section 24). We answer within 30 days. If you are a club member, ask your club or use the member app first (see section 3).

Objection to processing. You may object at any time to processing based on legitimate interest, and to direct marketing (POPIA section 11(3)). Use Form 1 of the POPIA Regulations (Objection to the processing of personal information), or email the Information Officer. The POPIA forms are on the Regulator's POPIA forms page.

Complaints to the Regulator. You may complain to the Regulator about how we process your personal information (POPIA section 74), on the eServices portal or to [email protected].

11. Where this manual is available

We email a copy free of charge. If you ask for a printed copy, we may charge the prescribed fee of R2.00 per A4 page.

12. Updating this manual

Our Information Officer reviews this manual at least once a year, and whenever our processing changes (for example a new supplier, a new country or a new product). Last reviewed: 4 November 2026.

Brett Clarke, Information Officer and Director, 4 November 2026.