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PAIA Manual

Version 1.0 · approved 18 October 2026 · effective 18 October 2026

Prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000, as amended

MomentDrops (Pty) Ltd

1. Introduction and Legal Basis

1.1 This PAIA Manual has been prepared by MomentDrops (Pty) Ltd ("MomentDrops", "the Company", "we", "us" or "our") in accordance with section 51 of the Promotion of Access to Information Act 2 of 2000, as amended ("PAIA").

1.2 PAIA gives effect to the constitutional right of access to information. In relation to a private body, access may be requested to records required for the exercise or protection of a right, subject to the requirements and lawful grounds for refusal set out in PAIA.

1.3 This Manual also provides information about the processing of personal information by MomentDrops, as contemplated by the Protection of Personal Information Act 4 of 2013 ("POPIA").

1.4 The Manual describes the categories of records held by MomentDrops, how requests for access may be submitted, applicable fees, available remedies and the Company's general personal-information processing practices.

1.5 The availability of a record in a category listed in this Manual does not mean that access to that record will automatically be granted.

2. Definitions and Abbreviations

For purposes of this Manual:

  • PAIA means the Promotion of Access to Information Act 2 of 2000, as amended.
  • POPIA means the Protection of Personal Information Act 4 of 2013.
  • Information Regulator means the Information Regulator established under POPIA.
  • Information Officer means the person responsible for handling applicable access-to-information and personal-information matters on behalf of MomentDrops.
  • Personal information has the meaning assigned to it in POPIA.
  • Data subject means the person to whom personal information relates.
  • Record means recorded information in any form or medium, as contemplated by PAIA.
  • Requester means a person requesting access to a record in accordance with PAIA.
  • Operator means a person or organisation processing personal information for MomentDrops under a contract or mandate, without coming under its direct authority.
  • MomentDrops platform means the Company's website and related services for collecting, storing, organising and making wedding photographs and videos available to the relevant couple.

References to legislation include applicable amendments and regulations.

3. Company Details and Information Officer

Registered company: MomentDrops (Pty) Ltd

Registration number: 2026/693581/07

Information Officer: Armand Slabbert

Telephone: 082 835 0219

Email: hello@momentdrops.com

Physical address: 20 Lupin Crescent, Milnerton, Cape Town, Western Cape, 7441, South Africa

Postal address: 20 Lupin Crescent, Milnerton, Cape Town, Western Cape, 7441, South Africa

Website: www.momentdrops.com

3.1 The Information Officer is the primary contact for requests relating to access to records under PAIA and the exercise of applicable rights under POPIA.

3.2 Requests should preferably be submitted in writing by email so that the Company can identify the requested records and maintain an appropriate record of correspondence.

3.3 MomentDrops will maintain its Information Officer registration and related information in accordance with applicable requirements.

4. Purpose and Scope of This Manual

4.1 The purposes of this Manual are to:

  • Inform members of the public about the records and categories of records held by MomentDrops.
  • Explain how a person may request access to those records.
  • Identify records that are publicly available or accessible under other legislation.
  • Describe how MomentDrops processes personal information.
  • Explain the applicable access-request procedures, fees and remedies.

4.2 This Manual applies to records held by MomentDrops in connection with its business activities, including the operation of its wedding memory collection platform.

4.3 It does not grant unrestricted access to private wedding galleries, guest photographs or videos, confidential business records, personal information belonging to other people, or legally protected information.

4.4 Requests will be assessed individually in accordance with PAIA, POPIA and other applicable law.

5. Guide on How to Use PAIA

5.1 The Information Regulator has published a guide explaining how PAIA operates and how members of the public may exercise their rights under PAIA and POPIA.

5.2 The Guide includes information about:

  • The purpose of PAIA and POPIA.
  • The procedure for requesting access to records.
  • The assistance available from the Information Regulator.
  • Applicable fees.
  • Complaints and other legal remedies.
  • Relevant forms and regulations.

5.3 The Guide and related resources may be obtained through the Information Regulator's official website at www.inforegulator.org.za or its eServices platform at eservices.inforegulator.org.za.

5.4 MomentDrops will make the Guide available for inspection at its principal place of business in the languages and manner required by the applicable regulations.

5.5 A person requiring assistance in identifying the appropriate access procedure may contact the Information Officer using the details in section 3.

6. Records Available Without a Formal PAIA Request

6.1 Certain information is made publicly available through the MomentDrops website without requiring a formal PAIA request.

6.2 Such information may include:

  • General information about MomentDrops and its services.
  • Published wedding collection packages and prices.
  • Publicly available help and frequently asked questions.
  • Contact information.
  • Terms and Conditions.
  • The Privacy Notice.
  • This PAIA Manual, once published.
  • Other information deliberately published by MomentDrops for public access.

6.3 Public availability does not extend to private couple accounts, wedding galleries, guest-uploaded media or internal operational records.

6.4 The availability of these public records does not, by itself, constitute a claim that a formal notice under section 52(2) of PAIA has been issued.

7. Records Accessible Under Other Legislation

7.1 MomentDrops may hold records that are created, maintained or made accessible under applicable South African legislation.

7.2 Depending on the Company's activities and statutory obligations, relevant legislation may include:

  • Companies Act 71 of 2008.
  • Income Tax Act 58 of 1962.
  • Tax Administration Act 28 of 2011.
  • Value-Added Tax Act 89 of 1991, where applicable.
  • Consumer Protection Act 68 of 2008.
  • Electronic Communications and Transactions Act 25 of 2002.
  • Protection of Personal Information Act 4 of 2013.
  • Promotion of Access to Information Act 2 of 2000.
  • Employment-related legislation, where applicable.

7.3 Access to records governed by other legislation remains subject to the requirements, limitations and procedures of the relevant legislation.

7.4 This list is intended to identify potentially relevant legislation and does not represent that MomentDrops holds every category of record contemplated by each Act.

8. Subjects and Categories of Records Held

8.1 MomentDrops may hold records relating to the following subjects:

Corporate and governance records

  • Company registration and incorporation documents.
  • Shareholder and director records.
  • Statutory registers, resolutions and relevant agreements.

Financial and taxation records

  • Accounting records, invoices and receipts.
  • Tax and statutory reporting records.
  • Payment transaction and reconciliation records.
  • Financial agreements and business expenditure records.

Customer and wedding event records

  • Couple account and contact information.
  • Wedding event dates and related setup details.
  • Selected packages and payment status.
  • Event configuration and guest-upload settings.
  • Customer service communications.

Photographs, videos and related media records

  • Wedding photographs and videos uploaded through the platform.
  • Associated upload information and available media metadata.
  • Gallery organisation and storage records.
  • Download, retention and deletion-related operational records.

Technology and security records

  • Application configuration and system documentation.
  • Access and authentication-related records.
  • Security, operational and incident records.
  • Backup, recovery and storage-related records.

Commercial and service-provider records

  • Supplier and service-provider agreements.
  • Marketing and referral arrangements.
  • Business correspondence.
  • Website and domain administration records.

Legal and compliance records

  • Privacy notices, terms and policies.
  • Consent and acceptance records.
  • Privacy and access requests.
  • Relevant compliance correspondence and registers.

8.2 These categories describe the general subjects on which MomentDrops may hold records. Not every category will necessarily contain records at all times.

8.3 Access to particular records may be limited or refused in accordance with PAIA and other applicable law.

9. Processing of Personal Information

9.1 MomentDrops processes personal information for purposes connected with operating, securing and administering its wedding memory collection platform and meeting its legal obligations.

9.2 The purposes of processing may include:

  • Creating and managing couple accounts.
  • Establishing and administering wedding events.
  • Processing purchases and confirming payment status.
  • Enabling guests to upload photographs and videos.
  • Organising and displaying private wedding galleries to the relevant couple.
  • Responding to support and privacy requests.
  • Protecting accounts, media and platform security.
  • Managing retention, recovery, backups and lawful deletion.
  • Maintaining financial, legal and compliance records.
  • Communicating essential service information.

9.3 Categories of data subjects may include:

Couples and account holders: names, email addresses, account identifiers, wedding details, transaction information, communications and account activity.

Wedding guests and other people appearing in media: photographs, videos, any optional uploader name, relevant upload information and available media metadata. Wedding media may incidentally depict children or other individuals.

Suppliers, service providers and business contacts: names, business contact information, correspondence, contracts and payment-related information.

Website visitors and support requesters: contact details, submitted enquiries and limited technical or security-related information.

9.4 MomentDrops is designed so that guests can contribute through a wedding-specific link or QR code without creating an account. Providing a guest name is optional.

9.5 The relevant couple's wedding gallery is private. Guest access to an upload link does not automatically grant access to the couple's gallery or account.

9.6 Personal information is retained in accordance with applicable legal requirements, the Company's published Privacy Notice and the retention arrangements relevant to the service.

9.7 Further details about the Company's processing activities and privacy rights are available in the Privacy Notice at www.momentdrops.com/privacy.

10. Cross-Border Transfers of Personal Information

MomentDrops uses cloud-based infrastructure and third-party service providers to operate its platform. Personal information, including wedding photographs and videos, may be stored, transferred or processed outside South Africa.

MomentDrops will take reasonable steps to ensure that cross-border transfers comply with Section 72 of the Protection of Personal Information Act (POPIA), including the use of appropriate contractual, technical and organisational safeguards where applicable.

The location of data processing and storage, and the safeguards provided by relevant service providers, will be reviewed as part of MomentDrops' production configuration and ongoing privacy compliance.

11. Recipients and Service Providers

11.1 MomentDrops may disclose or make personal information accessible to appropriate categories of recipients where necessary for lawful business purposes.

11.2 These may include:

  • Cloud hosting, database and file-storage providers.
  • Payment processing providers.
  • Email and transactional communication providers.
  • Technical infrastructure, security and backup service providers.
  • Professional advisers, where appropriately authorised.
  • Regulatory, law-enforcement or other authorities where disclosure is legally required.
  • The relevant couple, in relation to media contributed to their wedding event.

11.3 Access by service providers is intended to be limited to what is necessary for the relevant service or lawful purpose.

11.4 MomentDrops will maintain an internal service-provider record identifying relevant providers, processing purposes, locations and applicable safeguards.

11.5 MomentDrops does not treat possession of a wedding upload link as authorisation to disclose the couple's private gallery to an unrelated person.

11.6 Personal information will not be disclosed merely because a third party requests it. Each disclosure must have an appropriate lawful basis.

12. Information Security Measures

12.1 MomentDrops recognises the importance of protecting wedding photographs, videos and other personal information against unauthorised access, loss, damage, alteration and unlawful processing.

12.2 Its information security arrangements include, or are designed to include, measures appropriate to the nature of the information and the risks involved, such as:

  • Authentication and access controls for couple accounts.
  • Restricted access to private wedding galleries.
  • Private media storage and controlled file access.
  • Secure communication and transmission mechanisms.
  • Input and file validation.
  • Logging, monitoring and incident-response procedures.
  • Retention and deletion controls.
  • Backup and recovery arrangements.
  • Administrative access restrictions.
  • Security maintenance and review procedures.

12.3 Security measures are reviewed and adjusted as the platform and its operational environment develop.

12.4 No online service can guarantee absolute security. MomentDrops will take reasonable and appropriate steps to safeguard the confidentiality, integrity and availability of personal information in accordance with applicable law.

12.5 The description in this section is general and does not disclose confidential technical security configurations.

13. Procedure for Requesting Access to Records

13.1 A person wishing to request access to a record held by MomentDrops under PAIA should submit the prescribed Form 2: Request for Access to Record to the Information Officer.

13.2 Requests may be submitted by email to hello@momentdrops.com or by using the contact details in section 3.

13.3 A request should provide sufficient information to enable MomentDrops to:

  • Identify the requester and, where relevant, verify their authority.
  • Identify the requested record.
  • Understand the form in which access is requested.
  • Contact the requester regarding the request.
  • Identify the right the requester seeks to exercise or protect and explain why the record is required for that purpose, where PAIA requires this.

13.4 A person acting on behalf of another person may be required to provide proof of authority.

13.5 MomentDrops may request reasonable clarification or supporting information necessary to process the request lawfully.

13.6 The Company will assess requests in accordance with PAIA, POPIA and applicable third-party confidentiality and privacy protections.

13.7 Requests by data subjects to access, correct or delete their own personal information may also be submitted through the Company's privacy request process at www.momentdrops.com/privacy/request, where appropriate.

13.8 A privacy request and a formal PAIA request are not necessarily the same procedure. MomentDrops will explain the appropriate process where clarification is required.

14. Fees, Decisions and Timeframes

14.1 Fees for formal PAIA requests will be determined in accordance with the applicable PAIA regulations and prescribed fee schedules.

14.2 Where legally applicable, fees may relate to:

  • The prescribed request fee.
  • Searching for and preparing records.
  • Reproducing records in the requested format.
  • Delivery or other permitted access-related costs.

14.3 Any applicable fees and payment requirements will be communicated to the requester in accordance with the prescribed procedure.

14.4 MomentDrops will ordinarily communicate its decision within 30 days of receiving a valid request, subject to applicable statutory provisions, including any lawful extension.

14.5 Where permitted under PAIA, the response period may be extended by up to a further 30 days, with notice to the requester and reasons for the extension.

14.6 Where applicable, MomentDrops will use the prescribed Form 3: Outcome of Request and of Fees Payable.

14.7 The Company may provide access to an appropriate part of a record where the remainder is lawfully withheld and severance is required or permitted.

14.8 Public access to this Manual and inspection of the printed Manual at the Company's address, by prior appointment, are free of charge.

15. Grounds for Refusal and Available Remedies

15.1 MomentDrops may be required or permitted to refuse access to a record on grounds provided for in PAIA.

15.2 Such grounds may include:

  • Protection of the privacy of another individual.
  • Protection of confidential commercial information.
  • Protection of information supplied in confidence.
  • Protection of the safety of individuals or property.
  • Protection of legally privileged information.
  • Protection of the Company's commercial information where permitted by law.
  • Other grounds prescribed by PAIA.

15.3 The Company will consider any applicable public-interest disclosure provisions and other statutory requirements before refusing access.

15.4 Where a request is refused, MomentDrops will provide the decision and reasons in the manner required by PAIA.

15.5 A requester who is dissatisfied with a decision may, subject to applicable requirements and time limits, lodge a complaint with the Information Regulator or pursue an appropriate court remedy.

15.6 The internal appeal procedure applicable to certain public bodies does not ordinarily apply to decisions of a private body such as MomentDrops.

15.7 Information about complaints, forms and available remedies can be obtained from the Information Regulator at www.inforegulator.org.za.

16. Availability, Review and Updating of This Manual

Availability of the PAIA Manual

The MomentDrops PAIA Manual is available electronically on the company's website at www.momentdrops.com/paia.

A printed copy is also available for inspection, free of charge, by prior appointment at:

20 Lupin Crescent, Milnerton, Cape Town, Western Cape, 7441.

Appointments may be arranged by emailing hello@momentdrops.com or calling 082 835 0219.

Requests for access to records must follow the applicable PAIA procedures.

16.1 This Manual is published in English.

16.2 The Information Officer will review the Manual periodically and update it when necessary to reflect material changes in the Company's activities, records, contact details, personal-information processing practices or applicable legal requirements.

16.3 The current version and relevant document dates will be displayed on the published Manual.

16.4 A copy will be made available to the Information Regulator upon request.

16.5 The Manual will be reviewed before initial publication and whenever material changes require an update.