Skip to content
TradeloopIncredible

PAIA manual

This manual is published under 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 explains what records we keep and how you can ask for them.

1. Who we are

  • Name: Tradeloop
  • Registration number: not set yet
  • Address: not set yet
  • Phone: not set yet
  • Email: tradeloop@closetheloop.com.au
  • Website: not set yet

We run a trade-in service: customers bring a phone, tablet or laptop to a trade-in counter at a partner store, staff check it, and an accepted offer is paid as store credit.

2. Information Officer

The head of Tradeloop has made not named yet our Information Officer. Send every request under PAIA or POPIA to them.

3. The Regulator's guide

The Information Regulator publishes a guide on how to use PAIA and POPIA (section 10 of PAIA). It is available on the Regulator's website, inforegulator.org.za, in every official language. You can also ask our Information Officer for a copy to read at our offices.

4. Records available without a request

You do not need to make a request for these. They are on our website:

  • our privacy notice
  • our terms of use
  • this manual
  • the information on our public pages, such as how trade-ins work, store locations and frequently asked questions

5. Records we keep under other laws

We keep records as these laws require, among others:

  • Companies Act 71 of 2008
  • Second-Hand Goods Act 6 of 2009
  • Consumer Protection Act 68 of 2008
  • Protection of Personal Information Act 4 of 2013
  • Electronic Communications and Transactions Act 25 of 2002
  • Income Tax Act 58 of 1962, Value-Added Tax Act 89 of 1991 and Tax Administration Act 28 of 2011
  • Basic Conditions of Employment Act 75 of 1997 and Labour Relations Act 66 of 1995

6. Categories of records we hold

  • Company records: founding documents, registers, minutes and statutory returns.
  • Financial records: accounts, tax records, banking records and invoices.
  • Trade-in records: each trade-in's device, its serial number or IMEI, its condition check, the offer and who approved it.
  • The second-hand goods register: the seller's identity details and the device details the Second-Hand Goods Act requires.
  • Customer records: name, ID number and a photo of the ID document, mobile number, email address, and the messages we sent.
  • Voucher and store credit records: each voucher issued, its balance and where it was spent.
  • Partner and supplier records: agreements with partner retailers and service providers, and correspondence with them.
  • Staff records: employment contracts, payroll, and leave and training records.
  • Systems records: access logs, audit trails and security records.

Some of these may be refused under the grounds in Chapter 4 of Part 3 of PAIA, for example to protect someone else's personal information or commercial information.

7. How we process personal information

Why we process it
  • to confirm who is selling a device and that they may sell it
  • to keep the register the Second-Hand Goods Act requires and to check that a device is not reported stolen
  • to make an offer, issue store credit and let customers check their vouchers
  • to send receipts, vouchers, sign-in codes and the messages a customer asks for
  • to run our business, pay our staff and meet our legal duties
Whose information we hold, and what
  • Customers: name, ID number, ID document photo, contact details, device details, and trade-in and voucher history.
  • People who ask for an online estimate: the email address or mobile number they give.
  • Partner retailers' staff who use the service: name, work email, store and what they did in the system.
  • Our staff: the information an employer needs, such as identity, contact, bank and tax details.
  • Suppliers and partners: company details and contact people.
Who receives it
  • the service providers that host our systems and send our messages, under agreements that protect the information
  • the partner retailer at whose store the trade-in took place, for its own trade-ins
  • the police and other authorities, when the law requires it
Information sent outside South Africa

Some of our systems are hosted by service providers outside South Africa. We only use providers bound by law or agreement to protect personal information to a standard at least as high as POPIA's (section 72 of POPIA).

How we keep it safe

Access is limited to the people who need it and every change is recorded. Information is encrypted in transit, systems are kept up to date, and a breach is reported to the Information Regulator and the people affected as POPIA requires.

8. How to ask for a record

  1. Fill in Form 2 (Request for access to a record), from the Information Regulator's website or from our Information Officer.
  2. Send it to our Information Officer at the email address above.
  3. Say which record you want, how you want access (a copy, or to view it), and, if you ask on someone else's behalf, show that you may.
  4. Say which right you want to exercise or protect, and why you need the record for it (section 53 of PAIA).

We decide within 30 days. We may extend that once, by up to 30 days, and we will tell you why. If you are refused, we explain why, and you may complain to the Information Regulator or apply to a court.

To ask for your own personal information, to correct it or to have it deleted, you can also sign in to the customer portal or ask at any trade-in counter.

9. Fees

The fees are those prescribed in the PAIA regulations published by the Minister and the Information Regulator. There are two kinds:

  • a request fee, which you do not pay when you ask for your own personal information
  • an access fee, for searching for, preparing and copying the record

We tell you the amount before we do the work. The current fee list is in the Regulator's guide.

10. Where to find this manual

This manual is on our website, and our Information Officer can give you a copy. We update it when our records or how we process information change.