Ellermon

PAIA manual

Last updated 29 August 2026 · Version 1.0

This manual is published by Ellermon Holdings (Pty) Ltd (registration number 2026/561599/07) in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 ("PAIA"), as amended by the Protection of Personal Information Act 4 of 2013 ("POPIA"). It tells you what records we hold and how to request access to them.

Contents

  1. Particulars of the private body
  2. The Regulator's guide
  3. Records available without a request
  4. Records held in terms of other legislation
  5. Subjects and categories of records held
  6. Processing of personal information
  7. How to request a record
  8. Grounds for refusal
  9. Fees
  10. Remedies
  11. Availability of this manual

1. Particulars of the private body

Name
Ellermon Holdings (Pty) Ltd
Registration number
2026/561599/07
Type of entity
Private company incorporated in the Republic of South Africa
Date of incorporation
16 July 2026
Financial year end
June
Registered office
4 Westminster Avenue
Bryanston
Johannesburg
Gauteng, 2191
South Africa
Postal address
4 Westminster Avenue
Bryanston
Johannesburg
Gauteng, 2191
South Africa
Website
https://ellermon.com

Head of the private body

The head of the private body, as defined in section 1 of PAIA, is the chief executive officer or equivalent officer of Ellermon Holdings (Pty) Ltd. The head has designated the Information Officer below to deal with requests made under PAIA.

Information Officer

Name
Michael Ian Rolle
Capacity
Director
Email
admin@ellermon.com
Postal address
4 Westminster Avenue
Bryanston
Johannesburg
Gauteng, 2191
South Africa

The Information Officer is appointed under section 55 of POPIA and is whose registration with the Information Regulator is in progress. We have not designated a Deputy Information Officer; the company is small enough that the Information Officer deals with every request personally.

2. The Regulator's guide on how to use PAIA

The Information Regulator (South Africa) has compiled a guide, in terms of section 10 of PAIA, containing the information a person needs to exercise their rights under the Act. It is available in each official language from the Regulator:

Address
JD House, 27 Stiemens Street
Braamfontein, Johannesburg, 2001
P.O Box 31533, Braamfontein, Johannesburg, 2017
Email
inforeg@inforegulator.org.za
Website
https://inforegulator.org.za

3. Records available without a PAIA request

Ellermon Holdings (Pty) Ltd has not published a notice in terms of section 52(2) of PAIA listing categories of records automatically available without a request.

We do, however, make the following available on this website to anyone, free of charge and without any request:

In addition, a GradeLens user can see and export all of their own records from inside the app at any time, without making a PAIA request. That is almost always faster than this process.

4. Records held in terms of other legislation

We hold records in terms of, among others:

Listing a statute here does not mean every record it contemplates exists. The company was incorporated on 16 July 2026 and its records are correspondingly limited.

5. Subjects and categories of records held

Section 51(1)(e): sufficient detail to identify the records we hold.
SubjectCategories of record
Company secretarial Certificate of incorporation, Memorandum of Incorporation, register of directors, beneficial ownership filings, CIPC correspondence, annual returns, resolutions and minutes
Financial Accounting records, annual financial statements, bank records, invoices, tax returns and SARS correspondence
Customer and user GradeLens account records, learner records, subjects, terms, assessment categories, assessments and marks, calendar events, notification preferences, support and privacy correspondence
Product and technical Source code, technical documentation, architecture and design records, API contracts, test records, deployment and infrastructure configuration, server and audit logs
Data protection This manual, privacy and POPIA notices, records of data subject requests and our responses, records of any security compromise and notifications, operator agreements
Contracts and suppliers Agreements with service providers, app store developer agreements, licences and non-disclosure agreements
Employment Employment contracts, payroll records, statutory returns and personnel files, in respect of any employees
Intellectual property Trade mark and domain registrations, licences, and records of ownership in software
Marketing Website content, product descriptions and app store listing material

6. Processing of personal information

Section 51(1)(c) requires this manual to describe the personal information we process, the purposes, the recipients, and any cross-border transfers. That description is set out in full in our POPIA processing notice and Privacy Policy, which form part of this manual. In summary:

7. How to request a record

  1. Complete Form C — "Request for Access to Record of Private Body" — prescribed by regulation under PAIA and available from https://inforegulator.org.za.
  2. Send it to the Information Officer at admin@ellermon.com, or by post to 4 Westminster Avenue, Bryanston, Johannesburg, Gauteng, 2191, South Africa.
  3. Provide enough detail for us to identify the record and to identify you, state the form of access you want, and give an address in the Republic for our reply. If you are requesting on someone else's behalf, submit proof of your authority.
  4. State the right you are seeking to exercise or protect, and explain why the record is required to exercise or protect it. Section 50 of PAIA makes this the test for access to a private body's records, and a request that does not address it cannot succeed.
  5. Pay the request fee if one is payable. We will tell you the amount before you incur it.
  6. We decide within 30 days and notify you in writing. That period may be extended by a further 30 days where the request is for a large number of records or requires a search through records held elsewhere; we will tell you if it is extended and why.

If you are asking for your own personal information — or your child's — you do not need Form C or a fee. Use the simpler route at making a data request, or just do it yourself in the app.

8. Grounds for refusal

We must or may refuse a request where PAIA requires or permits it, including where granting access would:

Section 70 requires access despite those grounds where disclosure would reveal a substantial contravention of the law or an imminent and serious public safety or environmental risk, and the public interest in disclosure clearly outweighs the harm.

If we refuse, we will give you written reasons and tell you how to appeal.

9. Fees

Fees are those prescribed by regulation under PAIA and published in the Government Gazette. There are two kinds: a request fee, payable before we process a request, and an access fee covering the cost of searching for, reproducing and preparing the record.

Because the prescribed tariff is amended from time to time, this manual does not reproduce the amounts. The current tariff is published at https://inforegulator.org.za, and we will quote you the applicable figures when you make a request.

10. Remedies available to you

There is no internal appeal against a decision of the head of a private body. If we refuse your request, or you are unhappy with the fee, the form of access, or the extension of the deadline, you may:

11. Availability of this manual

This manual is available:

It is available in English. We review it at least once a year and whenever our operations change materially.