BOANG TECHNOLOGY PROPRIETARY LIMITED

(Registration Number: 2010/162436/07

PAIA MANUAL

Prepared in terms of section 51 of the Promotion of Access to Information Act, No. 2 of 2000 (as amended), read with the Protection of Personal Information Act, No. 4 of 2013

Item	Detail
Date of first compilation	11 AUGUST 2026
Date of last revision	11 AUGUST 2026
Version	1.0
Approved by	Mr. JACE CHEN – CHIEF EXECUTIVE OFFICER
Next scheduled review	AS AND WHEN REQUIRED

 

1. LIST OF ACRONYMS AND ABBREVIATIONS

Abbreviation	Meaning
the Company	BOANG TECHNOLOGY PROPRIETARY LIMITED
CEO	Chief Executive Officer
CPA	Consumer Protection Act, No. 68 of 2008
DIO	Deputy Information Officer
ECTA	Electronic Communications and Transactions Act, No. 25 of 2002
IO	Information Officer
Minister	Minister of Justice and Constitutional Development
PAIA	Promotion of Access to Information Act, No. 2 of 2000 (as amended)
Personal Information	Personal information as defined in section 1 of POPIA
POPIA	Protection of Personal Information Act, No. 4 of 2013
Regulations	Regulations Relating to the Promotion of Access to Information, 2021, published in Government Notice No. R.757 in Government Gazette No. 45057 of 27 August 2021
Regulator	The Information Regulator (South Africa)
Republic	Republic of South Africa
Requester	Any person making a request for access to a record of the Company in terms of PAIA
the Website	https://www.oppo.com/za/
the Online Store	https://www.oppo.com/za/store/

 

2. PURPOSE OF THIS PAIA MANUAL

2.1 This Manual is compiled in terms of section 51 of PAIA. It is intended to assist any person who wishes to request access to a record held by the Company.

2.2 This Manual enables a member of the public to:

• ascertain the categories of records held by the Company which are available without a person having to submit a formal PAIA request;
• obtain a sufficient understanding of how to make a request for access to a record of the Company, by reference to the subjects on which the Company holds records and the categories of records held on each subject;
• ascertain the records of the Company which are available in accordance with any other legislation;
• obtain the contact details of the Information Officer and the Deputy Information Officer who will assist the public with the records they intend to access;
• obtain a description of the Guide on how to use PAIA, as updated by the Regulator, and of how to obtain access to that Guide;
• understand whether the Company processes personal information, the purpose of such processing, and the categories of data subjects and of the information relating to them;
• ascertain the recipients or categories of recipients to whom personal information may be supplied;
• ascertain whether the Company has planned to transfer or process personal information outside the Republic and the recipients or categories of recipients to whom the personal information may be supplied; and
• ascertain whether the Company has appropriate security measures in place to ensure the confidentiality, integrity and availability of the personal information which is processed.

2.3 This Manual is not intended to, and does not, create any right of access other than the rights conferred by PAIA and POPIA, nor does it waive any ground of refusal available to the Company in law.

3. PARTICULARS OF THE COMPANY

Item	Detail
Full registered name	BOANG TECHNOLOGY PROPRIETARY LIMITED
Registration number	2020/126436/07
VAT number	4220291548
Nature of business	Distribution, marketing, online and offline retail sale, and after-sales service of mobile handsets, IoT devices and related accessories and services in the Republic
Head of the private body (as defined in PAIA)	Mr. JACE CHEN (CHIEF EXECUTIVE OFFICER
Physical address	1F, BUILDING 9, WOODMEAD ESTATE, 1 WOODMEAD DRIVE, SANDTON 2191
Postal address	1F, BUILDING 9, WOODMEAD ESTATE, 1 WOODMEAD DRIVE, SANDTON 2191
Telephone	080 001 4855
Corporate website	https://www.oppo.com/za/
Online store	https://www.oppo.com/za/store/

 

4. KEY CONTACT DETAILS FOR ACCESS TO INFORMATION

4.1 In terms of PAIA, the head of a private body is the Information Officer. The CEO has delegated the day-to-day administration of, implementation of and compliance with PAIA and POPIA to the Deputy Information Officer identified below. All requests must be directed to the contact details set out in this clause.

4.1 Information Officer

Item	Detail
Full name	Mr. LIAM FAURIE
Designation	HEAD OF GO-TO-MARKET
Telephone	080 001 4855
Email	liam.faurie@oppoza.com
Physical address	1F, BUILDING 9, WOODMEAD ESTATE, 1 WOODMEAD DRIVE, SANDTON 2191
Postal address	1F, BUILDING 9, WOODMEAD ESTATE, 1 WOODMEAD DRIVE, SANDTON 2191

 

4.2 Deputy Information Officer

Item	Detail
Full name	Mr. PAUL SUEN
Designation	HEAD OF AFTER SALES
Telephone	080 001 4855
Email	Paul.suen@oppoza.com

 

4.3 General contact point for access-to-information and privacy matters

Item	Detail
Dedicated email	support.za@oppo.com
Telephone	080 001 4855
Address for delivery of requests	1F, BUILDING 9, WOODMEAD ESTATE, 1 WOODMEAD DRIVE, SANDTON 2191
Office hours	Monday to Friday, 09:00 to 17:00, excluding public holidays

 

4.4 The Information Regulator

Any person who believes that the Company has not dealt adequately with a request, or who wishes to lodge a complaint, may contact the Regulator at:

Item	Detail
Postal address	P.O. Box 31533, Braamfontein, Johannesburg, 2017
Physical address	JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
General enquiries	enquiries@inforegulator.org.za
PAIA complaints	PAIAComplaints@inforegulator.org.za
POPIA complaints	POPIAComplaints@inforegulator.org.za
Website	https://inforegulator.org.za

 

5. GUIDE ON HOW TO USE PAIA AND HOW TO OBTAIN ACCESS TO IT

5.1 The Regulator has, in terms of section 10(1) of PAIA, updated and made available a Guide containing such information as may reasonably be required by a person who wishes to exercise any right contemplated in PAIA and POPIA. The Guide is available in each of the official languages and in braille.

5.2 The Guide contains a description of, among other things:

• the objects of PAIA and POPIA;
• the contact particulars of the Information Officer and every Deputy Information Officer of every public and private body;
• the manner and form of a request for access to a record of a public body (section 11) and of a private body (section 50);
• the assistance available from the Information Officer of a public body and from the Regulator in terms of PAIA and POPIA;
• all remedies available in law regarding an act or failure to act in respect of a right or duty conferred or imposed by PAIA and POPIA, including the manner of lodging an internal appeal, a complaint to the Regulator, and an application to court;
• the provisions of sections 14 and 51 requiring a public body and a private body respectively to compile a manual, and how to obtain access to such a manual;
• the provisions of sections 15 and 52 providing for the voluntary disclosure of categories of records;
• the notices issued in terms of sections 22 and 54 regarding fees payable in relation to requests for access; and
• the regulations made in terms of section 92.

5.3 The Guide may be obtained:

• from the website of the Regulator at https://inforegulator.org.za;
• directly, in English, at https://inforegulator.org.za/wp-content/uploads/2020/07/PAIA-Guide-English_20210905.pdf;
• upon request to the Information Officer of the Company at the contact details in clause 4; and
• by inspection at the offices of the Company during normal business hours.

6. CATEGORIES OF RECORDS AVAILABLE WITHOUT A FORMAL REQUEST

6.1 The Company has not published a notice in terms of section 52(2) of PAIA. However, the Company voluntarily makes the following categories of records available without a person having to submit a formal PAIA request.

Category of record	Types of record	Available on the Website / Online Store	Available on request
Corporate information	Company name, registration number, physical address and contact details	Yes	Yes
Product information	Product specifications, user manuals, quick start guides, product images	Yes	Yes
Commercial terms	Prices, promotions, delivery charges, payment methods, full price disclosures required by section 43 of ECTA	Yes	Yes
Contractual documents	Terms and Conditions of Sale, Website Terms of Use, Returns, Refunds and Cancellation Policy, Warranty Terms	Yes	Yes
Privacy documents	Privacy Policy (Privacy Notice), Cookie Policy, direct marketing preference information	Yes	Yes
This Manual	PAIA Manual	Yes	Yes
Marketing material	Brochures, press releases, promotional and advertising material published by the Company	Yes	Yes
Regulatory information	Product approval and certification marks displayed on packaging and product pages	Yes	Yes

 

6.2 The records listed above may be inspected, and copies may be obtained, free of charge from the Website or the Online Store. Where a printed copy is requested from the Company, the reproduction fees set out in Annexure A apply.

7. RECORDS AVAILABLE IN TERMS OF OTHER LEGISLATION

7.1 The following records of the Company are available in accordance with legislation other than PAIA. Access to such records is governed by the relevant legislation and not by this Manual.

Category of record	Applicable legislation
Memorandum of Incorporation, registration certificate, share register, annual returns, directors' details	Companies Act, No. 71 of 2008
Tax records, VAT records, PAYE, UIF and SDL records	Tax Administration Act, No. 28 of 2011; Income Tax Act, No. 58 of 1962; Value-Added Tax Act, No. 89 of 1991
Employment records, contracts of employment, payroll and leave records	Basic Conditions of Employment Act, No. 75 of 1997; Labour Relations Act, No. 66 of 1995
Employment equity and skills development records	Employment Equity Act, No. 55 of 1998; Skills Development Act, No. 97 of 1998
Occupational health and safety records	Occupational Health and Safety Act, No. 85 of 1993
Injury on duty records	Compensation for Occupational Injuries and Diseases Act, No. 130 of 1993
Unemployment insurance records	Unemployment Insurance Act, No. 63 of 2001; Unemployment Insurance Contributions Act, No. 4 of 2002
Consumer information, product labelling, warranty and returns records	Consumer Protection Act, No. 68 of 2008
Electronic transaction disclosures and records	Electronic Communications and Transactions Act, No. 25 of 2002
Records of personal information processing	Protection of Personal Information Act, No. 4 of 2013
Import, export and customs records	Customs and Excise Act, No. 91 of 1964
Product type approval and compliance records	Electronic Communications Act, No. 36 of 2005; National Regulator for Compulsory Specifications Act, No. 5 of 2008
This Manual	Promotion of Access to Information Act, No. 2 of 2000
Broad-Based Black Economic Empowerment certificate	Broad-Based Black Economic Empowerment Act, No. 53 of 2003

 

8. SUBJECTS AND CATEGORIES OF RECORDS HELD BY THE COMPANY

8.1 The following table describes the subjects on which the Company holds records and the categories of records held on each subject, as required by section 51(1)(e) of PAIA. The table is descriptive and is not an exhaustive list of every individual record.

Subject	Categories of records held	Access
1. Corporate governance and statutory records	Memorandum of Incorporation; certificate of incorporation; statutory registers; share register; records of directors and prescribed officers; minutes of board, committee and shareholder meetings; resolutions; delegations of authority; corporate policies	On PAIA request
2. Finance, tax and treasury	Annual financial statements; management accounts; general ledger and trial balance; budgets and forecasts; bank statements and banking records; accounts payable and receivable; tax returns and assessments; customs and import documentation; audit reports and correspondence	On PAIA request
3. Human resources and employment	Recruitment and applicant records; contracts of employment; personnel files; payroll, remuneration and benefit records; leave and attendance; performance and disciplinary records; training records; employment equity and skills development plans and reports; health and safety records; employee policies and codes of conduct	On PAIA request
4. Sales, orders and fulfilment	Customer orders and order histories; tax invoices and credit notes; payment, settlement, chargeback and refund records; delivery and courier records; stock, inventory and warehousing records; returns and exchange records; sales reports and channel performance data	On PAIA request
5. Customers and after-sales service	Customer account and registration data; product registration and warranty records; repair, service and replacement records; service-centre records; customer support tickets, correspondence, complaints and resolution records; call-centre and chat logs; consumer dispute and CPA complaint records	On PAIA request
6. Marketing, advertising and communications	Marketing plans, strategies and budgets; advertising, promotional and campaign material; media plans and placement records; endorsement, influencer, agency and sponsorship agreements; consumer and market research; promotional competition rules and records; direct marketing consent and preference records; brand and public relations records	Published material on the Website; all other records on PAIA request
7. Website, online store and platform operations	Website and Online Store terms, policies and notices; platform configuration and content records; system, transaction and access logs; cookie and consent records; analytics and traffic data; security incident and vulnerability records; disaster recovery and backup records	On PAIA request
8. Procurement, suppliers and business partners	Distribution, reseller and dealer agreements; supply, service and outsourcing agreements; payment gateway, logistics, IT, hosting and marketing service provider agreements; operator and retail partner agreements; non-disclosure agreements; data processing / operator agreements; purchase orders; supplier due diligence records	On PAIA request
9. Product compliance and certification	Type approval and licence records; letters of authority and compulsory specification records; product test and conformity reports; product safety, labelling and packaging records; recall and field-action records; product manuals and warranty terms	Published material on the Website; all other records on PAIA request
10. Legal, compliance and risk	Legal opinions and advice; litigation, arbitration and dispute records; regulatory correspondence and filings; insurance policies and claims; intellectual property registrations and licences; PAIA and POPIA registers, request logs and annual reports; compliance risk assessments; internal investigation records	On PAIA request
11. Information technology and security	IT policies and standards; network and system architecture documentation; asset registers; access control and user administration records; backup, retention and destruction records; penetration test and audit reports; business continuity plans	On PAIA request

 

8.2 Records held by the Company may contain information belonging to, or originating from, third parties, including the brand owner and its affiliates, suppliers, service providers and customers. Where a request relates to such information, the Company will apply the procedure in clause 12 and the grounds of refusal in clause 10, and will notify the affected third party in terms of section 71 of PAIA before any decision to grant access is taken.

9. REQUEST PROCEDURE

9.1 Right of access to records of a private body

In terms of section 50(1) of PAIA, a Requester must be given access to a record of the Company only if:

• the record is required for the exercise or protection of any right;
• the Requester complies with all the procedural requirements in PAIA relating to a request for access to that record; and
• access to that record is not refused in terms of any ground for refusal contemplated in Chapter 4 of Part 3 of PAIA.

9.2 Form of request

9.2.1 A request for access must be made on Form 2 (Request for Access to Record) prescribed by Regulation 7 of the Regulations. Form 2 is available from the Regulator's website and from the Information Officer on request, and is attached to this Manual as Annexure B.

9.2.2 The completed Form 2 must be delivered to the Information Officer at the address or email address set out in clause 4, and must:

• provide sufficient particulars to enable the Information Officer to identify the record or records requested and to identify the Requester;
• indicate the form of access required;
• specify a postal address or email address of the Requester in the Republic;
• identify the right that the Requester is seeking to exercise or protect;
• explain why the requested record is required for the exercise or protection of that right;
• state whether the Requester wishes to be informed of the decision in any manner in addition to a written reply, and specify the necessary particulars for that manner; and
• where the request is made on behalf of another person, include proof of the capacity in which the request is made, to the reasonable satisfaction of the Information Officer.

9.2.3 If a Requester is unable to make a written request because of illiteracy or disability, the request may be made orally, and the Information Officer will reduce it to writing on Form 2, and provide the Requester with a copy.

9.3 Fees

9.3.1 Before further processing a request, the Information Officer will, by written notice, require the Requester to pay the prescribed request fee set out in Annexure A, in terms of section 54(1) of PAIA.

9.3.2 No request fee is payable where the record requested contains personal information about the Requester.

9.3.3 Where the search for and preparation of a record for disclosure is likely to exceed six hours, the Information Officer will require the Requester to pay a deposit as set out in Annexure A before the request is further processed. If access is subsequently refused, the deposit will be repaid to the Requester.

9.3.4 The Company is entitled to withhold a record until all applicable fees have been paid.

9.4 Decision and notification

9.4.1 The Information Officer will decide on the request and notify the Requester of the decision, using Form 3 (Outcome of Request and of Fees Payable) prescribed by Regulation 8, within 30 (thirty) days of receipt of the request.

9.4.2 The 30-day period may be extended once for a further period not exceeding 30 (thirty) days where the request is for a large number of records, or requires a search through a large number of records or records held at premises other than the office receiving the request, or requires consultation with a third party or another body, and the extension is reasonable. The Requester will be notified in writing of any extension and of the reasons for it.

9.4.3 The notification of the decision will state the decision, the applicable access fee, the form in which access will be given, and, where access is refused, adequate reasons for the refusal including the provisions of PAIA relied upon, and will advise the Requester of the right to lodge a complaint with the Regulator or an application with a court, and the period within which this must be done.

9.4.4 If the Information Officer fails to give the decision within the period permitted, the Company is regarded, in terms of section 58 of PAIA, as having refused the request.

9.5 Records that cannot be found or do not exist

If all reasonable steps have been taken to find a record and there are reasonable grounds to believe that the record either does not exist or cannot be found, the Information Officer will notify the Requester by way of an affidavit or affirmation containing a full account of all steps taken to find the record or to determine whether it exists. Such notification is regarded as a refusal for the purposes of PAIA. If the record is later found, the Requester will be given access unless access is refused on a ground contemplated in clause 10.

9.6 Third-party notification

Where a request relates to a record containing information about a third party, including personal information, confidential commercial information or information supplied in confidence, the Information Officer will, in terms of sections 71 to 73 of PAIA, take all reasonable steps to inform that third party of the request within 21 (twenty-one) days, and afford the third party an opportunity to make representations or to consent to disclosure before a decision is taken.

9.7 False or misleading information

If the Company suspects that a Requester has obtained or sought to obtain access to a record through the submission of materially false or misleading information, the Company reserves all its rights, including the right to institute legal proceedings and to lay criminal charges against such Requester.

10. GROUNDS FOR REFUSAL OF ACCESS

10.1 The Company may or, where PAIA so requires, must refuse access to a record on any of the grounds set out in Chapter 4 of Part 3 of PAIA, including the following:

Section	Ground for refusal
s 63	Mandatory protection of the privacy of a third party who is a natural person, including a deceased natural person, which would involve the unreasonable disclosure of personal information about that natural person
s 64	Mandatory protection of the commercial information of a third party, including trade secrets, financial, commercial, scientific or technical information the disclosure of which would be likely to cause harm to the commercial or financial interests of that third party, and information supplied in confidence the disclosure of which could reasonably be expected to put that third party at a disadvantage in contractual or other negotiations or to prejudice it in commercial competition
s 65	Mandatory protection of certain confidential information, the disclosure of which would constitute an action for breach of a duty of confidence owed to a third party in terms of an agreement
s 66	Mandatory protection of the safety of individuals and protection of property
s 67	Mandatory protection of records privileged from production in legal proceedings
s 68	The commercial activities of the Company, including trade secrets of the Company, financial, commercial, scientific or technical information the disclosure of which would be likely to cause harm to the commercial or financial interests of the Company, information the disclosure of which could reasonably be expected to put the Company at a disadvantage in contractual or other negotiations or to prejudice it in commercial competition, and a computer program owned by the Company
s 69	Mandatory protection of research information of a third party, and protection of research information of the Company
s 70	Mandatory disclosure in the public interest, notwithstanding any other ground of refusal, where the record reveals evidence of a substantial contravention of, or failure to comply with, the law, or an imminent and serious public safety or environmental risk, and the public interest in disclosure clearly outweighs the harm contemplated in the relevant provision

 

10.2 Where a request for access is refused in part, the Information Officer will grant access to that part of the record which does not contain, and can reasonably be severed from, any part which falls within a ground of refusal.

11. REMEDIES AVAILABLE TO A REQUESTER

11.1 PAIA does not provide for an internal appeal against a decision of the head of a private body.

11.2 A Requester who is dissatisfied with a decision of the Company, including a deemed refusal, may:

• lodge a complaint with the Regulator in terms of section 77A of PAIA, on Form 5 prescribed by the Regulations, within 180 (one hundred and eighty) days of the decision; or
• apply to a court, in terms of section 78 of PAIA, for appropriate relief.

11.3 A third party who is dissatisfied with a decision of the Company to grant access to a record may exercise the same remedies within the periods prescribed by PAIA.

12. PROCESSING OF PERSONAL INFORMATION IN TERMS OF POPIA

12.1 The Company processes personal information as a responsible party in terms of POPIA. Further detail is set out in the Company's Privacy Policy, available at https://www.oppo.com/za/privacy/.

12.1 Purpose of processing personal information

The Company processes personal information for, among others, the following purposes:

• registering and administering customer accounts on the Online Store;
• concluding and performing contracts of sale, including order processing, payment, invoicing, delivery, returns, cancellations and refunds;
• product registration, warranty administration, repair and after-sales service;
• customer support, complaint handling and dispute resolution;
• direct marketing, where the data subject has consented or is an existing customer in respect of similar products, in accordance with section 69 of POPIA;
• market research, customer satisfaction surveys and analysis of aggregated sales and service trends;
• website and application operation, personalisation, security, analytics and fraud prevention;
• recruitment, employment administration and management of the Company's personnel;
• supplier, service provider and business partner management; and
• compliance with legal, regulatory, tax, accounting and reporting obligations, and the establishment, exercise or defence of legal claims.

12.2 Categories of data subjects and of personal information relating to them

Category of data subject	Personal information that may be processed
Customers and prospective customers	Name and surname; identity or passport number where required; email address; telephone number; physical and delivery address; account credentials; order and purchase history; product and device identifiers including IMEI and serial number; warranty and repair records; payment and billing information (payment card data is processed by the payment gateway and is not stored by the Company); marketing preferences and consent records; correspondence and complaint records
Website and Online Store visitors	IP address; device and browser identifiers; cookie and similar technology identifiers; approximate location derived from IP address; pages viewed and browsing behaviour; referral source; session and transaction logs
Employees, job applicants and contractors	Name and contact details; identity number; date of birth; gender, race and nationality where required for statutory reporting; qualifications and employment history; banking details; remuneration and benefits; tax and statutory numbers; performance, disciplinary and training records; health and safety records; next of kin and emergency contact details
Suppliers, service providers and business partners, and their personnel	Name and contact details of representatives; company registration and VAT numbers; banking details; contractual and performance records; due diligence records
Third parties involved in service delivery	Name and contact details of persons collecting or receiving goods; authorised representatives; complainants and their representatives

 

12.3 Recipients or categories of recipients to whom personal information may be supplied

Category of personal information	Recipients or categories of recipients
Order, delivery and contact details	Logistics, courier, warehousing and installation service providers
Payment and transaction details	Payment gateway providers, acquiring banks, card schemes and fraud-screening providers
Account, device and service records	Authorised service centres, repair partners and spare parts providers
Account, device, usage and marketing data	Guangdong OPPO Mobile Telecommunications Corp., Ltd., to the extent necessary for platform operation, product and account services, warranty administration and permitted marketing
Website and application data	IT, cloud hosting, content delivery, customer relationship management, analytics and marketing technology service providers
Marketing and campaign data	Advertising agencies, media platforms and marketing service providers
Employment and payroll data	Payroll administrators, retirement fund and medical scheme administrators, employment agencies, background and qualification verification providers
Any category of personal information	Professional advisors including attorneys, auditors and insurers; regulators and statutory oversight bodies; the South African Revenue Service; courts, tribunals, arbitrators and law enforcement agencies; any person making a successful request for access in terms of PAIA or POPIA; and any other person where required or permitted by law

 

12.4 Planned transborder flows of personal information

12.4.1 The Company transfers, or plans to transfer, personal information to recipients in countries outside the Republic, including the People's Republic of China, Singapore, the European Union, for the purposes of platform operation and hosting, group product and account services, technical support, warranty administration and, where applicable, marketing services.

12.4.2 Such countries may not have data protection laws that provide a level of protection substantially similar to POPIA. The Company will effect any transborder transfer only in accordance with section 72 of POPIA, on the basis of one or more of the following:

• the recipient is subject to a law, binding corporate rules or a binding agreement which provides an adequate level of protection that upholds principles for the reasonable processing of the information substantially similar to the conditions for the lawful processing of personal information under POPIA, and includes provisions substantially similar to section 72 relating to onward transfers;
• the data subject has consented to the transfer;
• the transfer is necessary for the performance of a contract between the data subject and the Company, or for the implementation of pre-contractual measures taken in response to the data subject's request;
• the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the data subject between the Company and a third party; or
• the transfer is for the benefit of the data subject in the circumstances contemplated in section 72(1)(e) of POPIA.

12.4.3 The Company concludes written agreements with all operators and cross-border recipients imposing obligations of confidentiality, security and lawful processing.

12.5 General description of information security measures

The Company implements appropriate, reasonable technical and organisational measures to secure the integrity and confidentiality of personal information in its possession or under its control, and to prevent loss of, damage to, or unauthorised destruction of, and unlawful access to or processing of, personal information. These measures include:

• role-based access control, unique user credentials and multi-factor authentication for administrative access;
• encryption of personal information in transit and, where appropriate, at rest;
• network security controls including firewalls, intrusion detection and anti-malware protection;
• secure configuration, patch management and vulnerability scanning;
• logging, monitoring and review of access to systems containing personal information;
• backup, business continuity and disaster recovery arrangements;
• written confidentiality undertakings by personnel, and regular privacy and information security awareness training;
• due diligence on, and written operator agreements with, all third parties that process personal information on behalf of the Company;
• a documented security compromise response procedure providing for notification of the Regulator and affected data subjects in terms of section 22 of POPIA; and
• documented retention periods and secure destruction or de-identification of personal information that is no longer required.

13. RIGHTS OF DATA SUBJECTS UNDER POPIA

13.1 A data subject may, upon proof of identity, exercise the following rights free of charge, save where a fee is expressly permitted:

• to request confirmation, free of charge, of whether the Company holds personal information about the data subject, and to request access to that information, including the identities of all third parties who have or have had access to it. A request for access is made on Form 2 under PAIA, and the applicable access fees in Annexure A may apply to the provision of copies;
• to object, at any time, on reasonable grounds relating to the data subject's particular situation, to the processing of personal information in terms of section 11(3) of POPIA, by submitting Form 1 prescribed under the POPIA Regulations;
• to request the correction or deletion of personal information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully, or the destruction or deletion of a record of personal information that the Company is no longer authorised to retain, by submitting Form 2 prescribed under the POPIA Regulations;
• to object at any time to the processing of personal information for purposes of direct marketing, and to withdraw consent to direct marketing by electronic communication in terms of section 69 of POPIA, at no cost;
• not to be subject to a decision which results in legal consequences or which affects the data subject to a substantial degree, based solely on the automated processing of personal information intended to provide a profile of the data subject, save as permitted by section 71 of POPIA;
• to submit a complaint to the Regulator regarding an alleged interference with the protection of personal information; and
• to institute civil proceedings regarding an alleged interference with the protection of personal information.

13.2 Requests and objections in terms of this clause must be submitted to the Information Officer at the contact details in clause 4. The Company will respond within a reasonable time and, where applicable, within the periods prescribed by PAIA.

14. AVAILABILITY OF THIS MANUAL

14.1 A copy of this Manual is available:

• on the Company's website at https://www.oppo.com/za/;
• on the Online Store at https://www.oppo.com/za/store/, accessible from the footer of every page;
• at the principal place of business of the Company set out in clause 3, for public inspection during normal business hours;
• to any person upon request and upon payment of the prescribed fee set out in Annexure A; and
• to the Information Regulator upon request.

14.2 This Manual is available in English. In accordance with the recommendation of the Regulator, the Company may make the Manual available in additional official languages.

15. UPDATING OF THIS MANUAL

15.1 The head of the Company will update this Manual on a regular basis, and in any event:

• at least once every 12 (twelve) months;
• whenever the Information Officer or any Deputy Information Officer changes;
• whenever there is a material change to the Company's business, the categories of records it holds, or its processing of personal information; and
• whenever there is a change to PAIA, POPIA, the Regulations or the prescribed forms or fees.

15.2 The Company maintains a register of all requests received and decisions taken in terms of PAIA, and submits an annual report to the Regulator in respect of each reporting period from 1 April to 31 March, on or before 30 June of each year, in terms of section 83(4) of PAIA.

16. APPROVAL

Compiled and approved on this 11 day of AUGUST 2026.

Item	Detail
Signature	_______________________________
Full name	Mr. JACE CHEN
Designation	CHIEF EXECUTIVE OFFICER
On behalf of	BOANG TECHNOLOGY PROPRIETARY LIMITED

 

A signed copy of this Manual may be obtained from the Information Officer at the contact details set out in clause 4.

ANNEXURE A: FEES PAYABLE

A1. The fees set out below are those prescribed in Annexure B to the Regulations Relating to the Promotion of Access to Information, 2021, published in Government Notice No. R.757 in Government Gazette No. 45057 of 27 August 2021, as applicable to private bodies. All fees are subject to amendment by the Minister from time to time, and the most recent published fee schedule will apply.

A2. Request fee

Item	Fee
Request fee payable by every Requester, other than a personal requester	R140.00
Request for access to a record containing personal information about the Requester	No request fee payable

 

A3. Fees for reproduction

Item	Fee (subject to any change as published by Government Gazette)
Every photocopy or printed black and white copy of an A4-size page or part thereof	R2.00
Every printed copy of an A4-size page or part thereof held on a computer or in electronic or machine-readable form	R2.00
Copy on a flash drive, where the flash drive is provided by the Requester	R40.00
Copy on a compact disc, where the compact disc is provided by the Requester	R40.00
Copy on a compact disc, where the compact disc is provided by the Company	R60.00
Transcription of an audio record, per A4-size page or part thereof	R24.00
Copy of an audio record on a flash drive, where the flash drive is provided by the Requester	R40.00
Copy of an audio record on a compact disc, where the compact disc is provided by the Requester	R40.00
Copy of an audio record on a compact disc, where the compact disc is provided by the Company	R60.00
Transcription of visual images, and copies of visual images	To be outsourced; the actual cost will be quoted to the Requester

 

A4. Fees for search and preparation

Item	Fee (subject to any change as published by Government Gazette)
Search for and preparation of the record for disclosure, for each hour or part of an hour, excluding the first hour, reasonably required for such search and preparation	R145.00
Maximum total fee payable for search and preparation	R435.00

 

A5. Deposit

Item	Amount (subject to any change as published by Government Gazette)
Where the Information Officer is of the opinion that the search for and preparation of the record for disclosure will exceed six hours, a deposit is payable before the request is further processed	One third of the amount of the access fee which would be payable if the request were granted

 

A6. If a deposit has been paid and access to the record is subsequently refused, the deposit will be repaid to the Requester.

A7. Postage, or the cost of electronic transmission of a record, is payable at the actual cost incurred by the Company where a copy of a record must be posted or transmitted to the Requester.

A8. All fees are payable by electronic funds transfer to the bank account nominated by the Information Officer. Value-added tax is payable on all fees where applicable.

ANNEXURE B: PRESCRIBED FORMS

B1. The following prescribed forms apply to requests made to, and decisions taken by, the Company. A copy of each applicable form is attached to this Manual. Forms published before the 2021 Regulations, including the former Form A and Form C, may no longer be used.

Form	Purpose	Prescribed by	Used by
Form 2	Request for Access to Record	Regulation 7 of the PAIA Regulations, 2021	Requester
Form 3	Outcome of Request and of Fees Payable	Regulation 8 of the PAIA Regulations, 2021	The Company
Form 4	Internal Appeal Form	Regulation 9 of the PAIA Regulations, 2021	Not applicable to private bodies. PAIA does not provide for an internal appeal against a decision of the head of a private body
Form 5	Complaint to the Information Regulator	Regulation 10 of the PAIA Regulations, 2021	Requester or third party
POPIA Form 1	Objection to the Processing of Personal Information	Regulation 2 of the POPIA Regulations, 2018	Data subject
POPIA Form 2	Request for Correction or Deletion of Personal Information or Destruction or Deletion of a Record of Personal Information	Regulation 3 of the POPIA Regulations, 2018	Data subject

 

B2. The current version of each form is published by the Information Regulator and may be downloaded from the following addresses:

• PAIA forms index page: https://inforegulator.org.za/paia-forms/
• POPIA forms index page: https://inforegulator.org.za/popia-forms/
• Form 2 (Request for Access to Record): https://inforegulator.org.za/wp-content/uploads/2020/07/InfoRegSA-PAIA-Form02-Reg7.pdf
• Form 3 (Outcome of Request and of Fees Payable): https://inforegulator.org.za/wp-content/uploads/2020/07/Form-3-PAIA.pdf
• Form 5 (Complaint Form): https://inforegulator.org.za/wp-content/uploads/2020/07/InfoRegSA-PAIA-Form05-Reg10-1.pdf
• POPIA Form 1 (Objection to Processing): https://inforegulator.org.za/wp-content/uploads/2020/07/FORM-1-OBJECTION-TO-THE-PROCESSING-OF-PERSONAL-INFORMATION.pdf
• POPIA Form 2 (Correction or Deletion): https://inforegulator.org.za/wp-content/uploads/2020/07/FORM-2-REQUEST-FOR-CORRECTION-OR-DELETION-OF-PERSONAL-INFORMATION-OR.pdf

B3. A request for access to a record must be made on a form that corresponds substantially with Form 2. Where any prescribed form is amended or replaced, the version published by the Information Regulator at the date of the request applies, and this Manual will be updated accordingly.

B4. A copy of any form may also be obtained free of charge from the Information Officer at the contact details set out in clause 4.