Legal

PAIA Manual

Manual prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000, as amended ("PAIA"), read with the Protection of Personal Information Act 4 of 2013 ("POPIA"). Last updated: 1 October 2026.

1. The business

  • Name: DeeMusiq, a venture of The Dembe Group
  • Registration number: Enterprise registration particulars available on request from the Information Officer (see section 3)
  • Physical address: KwaZulu-Natal, South Africa — full street address available on request from the Information Officer (see section 3)
  • Postal address: Available on request from the Information Officer (see section 3)
  • Website: deemusiq.co.za
  • Email: deemusiq@protonmail.com

2. Information Officer and contact

The head of the business is the Information Officer by default in terms of section 51(1)(a) of PAIA read with section 55 of POPIA, and has been formally designated as such. The Information Officer is responsible for PAIA requests and POPIA compliance, and may be contacted at deemusiq@protonmail.com (subject line: "PAIA request" or "POPIA enquiry"). A Deputy Information Officer may be designated in writing; current designations are available on request.

3. The Information Regulator's guide

The Information Regulator (South Africa) has compiled a guide on how to use PAIA, as contemplated by section 10 of the Act. The guide is available from the Regulator at inforegulator.org.za (JD House, 27 Stiemens Street, Braamfontein, Johannesburg; complaints: POPIAComplaints@inforegulator.org.za; PAIA: PAIAComplaints@inforegulator.org.za). Please consult the guide if you are unsure how to exercise your rights.

4. Records available without a request

The following records are freely available on our website and do not require a PAIA request:

  • this PAIA manual;
  • the Privacy Policy, Terms of Service and Security & Data Breach Notice;
  • product information, download links and press materials; and
  • your own personal information, which you can export or delete yourself at any time from within the DeeMusiq app (profile → privacy → export / delete account). Using this self-service function is faster than a PAIA request.

5. Applicable legislation

We hold records in terms of, among others, the following legislation, to the extent applicable to our operations:

  • Promotion of Access to Information Act 2 of 2000
  • Protection of Personal Information Act 4 of 2013
  • Consumer Protection Act 68 of 2008
  • Electronic Communications and Transactions Act 25 of 2002
  • Companies Act 71 of 2008 / Close Corporations Act 69 of 1984 (as applicable to the entity form)
  • Income Tax Act 58 of 1962, Value-Added Tax Act 89 of 1991 (financial and payout records)
  • Copyright Act 98 of 1978 (catalogue and licensing records)
  • Basic Conditions of Employment Act 75 of 1997 and Labour Relations Act 66 of 1995 (to the extent we have employees)

6. Subjects and categories of records we hold

  • User records: account identifiers, email addresses (where registered), device identifiers, usage and listening history, support correspondence. Phone numbers are stored only as keyed hashes.
  • Artist/creator records: profile information, uploaded content and metadata, verification documents, token balances and payout requests.
  • Payment records: payment intents, provider references and settlement records (card and banking details are processed by our payment providers and are not stored by us; artist payout details are stored encrypted).
  • Operational records: security and audit logs, moderation records, webhook and integration logs (retained for limited periods).
  • Corporate records: founding documents, contracts, financial and tax records, correspondence.

7. Processing of personal information under POPIA

Purpose: we process personal information to operate the streaming service (accounts, playback, downloads), to run the token wallet and artist payouts, to comply with tax and company law, to secure the platform, and to communicate with users.

Data subjects: listeners/users, artists and creators, suppliers and business contacts, and website visitors.

Recipients: payment providers (to settle transactions), hosting and content-delivery providers (under operator obligations), professional advisers, and public authorities where required by law.

Transborder flows: some infrastructure providers store or process data outside South Africa; where section 72 of POPIA applies, transfers are made only to parties bound by law, binding corporate rules or binding agreements providing substantially similar protection.

Security measures: described in our Security & Data Breach Notice (encryption in transit and at rest for sensitive fields, keyed hashing of direct identifiers, access controls and audit logging, retention limits).

8. How to request access (procedure and form)

  1. Complete Form 2 (Request for Access to Record), available from the Information Regulator's website or from us on request.
  2. Email the completed form to deemusiq@protonmail.com with the subject line "PAIA request", or post it to the address in section 1.
  3. Provide enough detail to identify the record and the right you are exercising or protecting, and proof of identity (and of authority, if you act for someone else).
  4. We will respond within 30 days of receiving a compliant request, as required by section 56 of PAIA (extendable once by a further 30 days on notice to you).

9. Fees

Fees are charged as prescribed in the PAIA Regulations. In summary: a requester seeking access to a record containing their own personal information pays no request fee; other requesters pay the prescribed request fee; and reproduction, search and preparation fees may apply as per the current fee schedule published by the Regulator. We will notify you of any fee (and any required deposit) before processing further.

10. Grounds for refusal and remedies

Access may be refused only on the grounds set out in Chapter 4 of Part 2 of PAIA (for example, protection of another's privacy, commercial confidentiality, or legal privilege), and we will give written reasons for any refusal. If your request is refused, or you are unhappy with our response, you may lodge a complaint with the Information Regulator (contact details in section 3) or apply to a competent court within 180 days.

11. Availability of this manual

This manual is published at deemusiq.co.za/paia.html, is available for inspection at our physical address on request, and has been prepared in the form substantially aligned with the Regulator's guidance. It is reviewed annually and on material change to our processing activities.