PAIA Manual — Trescent AI

Contents

Purpose and scope

This Manual has been prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000, as amended (“PAIA”). It helps members of the public understand what records Trescent AI holds, how those records may be accessed, and how Trescent AI processes personal information.

Its purposes are to:

identify records that may be available without a formal PAIA request;
describe the subjects and categories of records held by Trescent AI;
provide the contact details of the Information Officer and Deputy Information Officer;
explain the forms, fees and time periods applicable to an access request;
describe relevant personal-information processing and safeguards; and
identify available remedies if a requester is dissatisfied with a decision or failure to respond.

Important: This Manual does not create an automatic right of access. Access remains subject to PAIA, including its procedural requirements and grounds for refusal.

Company overview

Trescent AI is a South African software company that develops, owns and operates its own digital products and technology assets. Its current product portfolio includes Performance! Call Center Dashboard, a software-as-a-service platform used for call-centre performance visibility, gamification, management and reporting.

This Manual applies to records held by Trescent AI across its corporate activities, websites, products, technology assets, commercial relationships and legal obligations.

Registered name: Trescent AI (Pty) Ltd
Company registration: 2026/557303/07
Regulator registration: 2026-063197
Nature of business: Software product development, ownership and operation; SaaS and digital platforms
Current product: Performance! Call Center Dashboard
Website: trescent.co.za
General email: info@trescent.co.za
Telephone: +27 65 988 7072
Physical address: 13 Headingly Close, Sherwood, Port Elizabeth, South Africa
Postal address: Same as physical address

Key contacts for access to information

Information Officer

Darryn Burton

Director and Information Officer

privacy@trescent.co.za

Deputy Information Officer

Thapelo Masiwa

Registered Deputy Information Officer

privacy@trescent.co.za

Requests and related correspondence should be marked “PAIA Request” and sent to privacy@trescent.co.za. Requests delivered physically should be addressed to the Information Officer at 13 Headingly Close, Sherwood, Port Elizabeth, South Africa.

Guide on how to use PAIA

The Information Regulator has published a Guide explaining how to use PAIA and exercise rights under PAIA and POPIA. The Guide is available in South Africa's official languages and may be obtained from the Information Regulator or requested from Trescent AI's Information Officer.

Official resourcePAIA information and guidance Official guideGuide on how to use PAIA Prescribed formForm 2: Request for Access Current schedulePAIA fee structure

Requests for your own personal information: You may also have rights under POPIA to request access to or correction of personal information. Trescent AI may determine whether a request should be processed under PAIA, POPIA or both.

Records available without a formal request

The following records may be available without completing Form 2, to the extent that they have been published or otherwise designated as freely available. Availability may change and may be subject to reasonable identity, security or usage controls.

Category	Records	How available
Company information	Registered company name, registration number and public contact details	Trescent AI website or on request
Product information	Published descriptions of Performance!, feature summaries and marketing material	Performance! or Trescent AI website
Legal and privacy	Terms, privacy and security information, cookie notice where applicable, and this Manual	Relevant website legal pages
Service providers	Published hosting, payment, email or other provider information	Privacy Policy or subprocessor page
Public announcements	Company or product announcements and published updates	Official company channels
Vacancies	Publicly advertised employment or contractor opportunities, if any	Website or nominated recruitment channel

Records available under other legislation

Trescent AI may create, retain or make records available under the following legislation, where applicable. Inclusion does not mean every record is automatically public.

Companies Act 71 of 2008Company registration, constitutional, governance, securities and statutory records

Income Tax Act 58 of 1962 and Tax Administration Act 28 of 2011Tax, accounting and supporting records

Value-Added Tax Act 89 of 1991VAT records, if and while Trescent AI is registered as a VAT vendor

Basic Conditions of Employment Act 75 of 1997Employment and remuneration records, where applicable

Labour Relations Act 66 of 1995Employment-relations and disciplinary records, where applicable

Employment Equity Act 55 of 1998Employment-equity records, where applicable

Unemployment Insurance legislationUIF registration and contribution records, where applicable

Compensation for Occupational Injuries and Diseases Act 130 of 1993Employment and incident records, where applicable

Electronic Communications and Transactions Act 25 of 2002Electronic communications, transactions, website and e-commerce disclosures

Protection of Personal Information Act 4 of 2013Personal-information processing, security and data-subject request records

Promotion of Access to Information Act 2 of 2000This Manual and PAIA request records

Consumer Protection Act 68 of 2008Customer and service records where the Act applies

Copyright Act 98 of 1978 and Trade Marks Act 194 of 1993Copyright, brand, software, design and trade-mark records

Cybercrimes Act 19 of 2020Security incident and cybercrime-related records where applicable

Subjects and categories of records held

The fact that a category is listed below does not mean access will automatically be granted.

Corporate and governance

Incorporation records, the Memorandum of Incorporation, statutory registers, director and shareholder records, resolutions, policies and governance correspondence.

Finance, accounting and tax

Invoices, receipts, banking and payment records, management accounts, budgets, tax records, financial statements, expenses and procurement records.

Customers and agreements

Customer details, proposals, quotations, Order Forms, subscriptions, contracts, account notes, support and implementation records.

Performance! operations

Product specifications, configuration and campaign settings, feature documentation, dashboard and portal records, releases and operating procedures.

Intellectual property

Source and object code, databases, architecture, UI/UX designs, graphics, documentation, trade secrets, copyright, trade marks and assignments.

Customer and Agent Data

Account and user details, Agent Data, targets, lead counts, leaderboards, statistics, campaign data, display codes and audit records.

Billing and payments

Subscription plans, active-agent counts, invoices, payment status, credits, adjustments, tax details and reconciliation records.

Technology and security

System logs, access controls, incidents, assessments, backups, infrastructure records and vendor security information.

Privacy and compliance

Privacy policies, processing records, requests, preference records, security-compromise records and regulatory correspondence.

Suppliers and subprocessors

Vendor contracts, due diligence, service descriptions, invoices, processing terms, service levels and security records.

People records

Recruitment, employment, contractor, payroll, leave, performance, disciplinary, training and termination records where applicable.

Marketing and communications

Website content, product literature, campaigns, enquiries, media, partnerships, mailing preferences and analytics where implemented.

Legal and disputes

Legal advice, claims, disputes, complaints, litigation, settlements and privileged communications.

Processing of personal information

Purposes of processing

Trescent AI processes personal information only for legitimate business and legal purposes, including:

registering, onboarding and administering customer organisations and Authorised Users;
providing, securing, supporting and improving Trescent AI's websites and digital products;
processing subscriptions, active-agent counts, invoices, tax and payment-status information;
communicating about accounts, support, service notices, security, billing and legal matters;
processing Agent Data on behalf of customers for performance visibility, reporting, gamification and management;
preventing fraud, misuse, unauthorised access and security incidents;
meeting legal, regulatory, accounting, tax and audit requirements;
managing suppliers, advisers, employees, contractors and applicants;
responding to enquiries, complaints and formal requests;
conducting analytics and product improvement, preferably using aggregated or de-identified information; and
sending marketing communications where legally permitted.

Categories of data subjects and information

Data subject	Personal information that may be processed
Customer organisations and contacts	Names, titles, company details, contacts, billing and tax information, contracts, subscriptions, payment status and communications
Authorised Users	Names, usernames, work email, role, organisation, permissions, login, device, session, activity and support information
Agents and customer employees	Names or identifiers, teams, campaigns, performance counts, targets, rankings, streaks, activity and historical performance
Prospective customers	Names, company and contact details, enquiries, communications, preferences and technical website data
Suppliers and advisers	Business contacts, registration and tax details, contracts, invoices, banking, due diligence and service records
Employees, applicants and directors	Identity and contact information, qualifications, employment, payroll, performance, leave, screening and governance records
Website and Platform visitors	IP address, browser and device information, cookies or local storage, session tokens, logs and diagnostic information
Requesters and correspondents	Identity and contact information, request details, supporting documents, correspondence, decisions and outcomes

Recipients

Recipient category	Purpose
Hosting and infrastructure	Render Services, Inc. and approved infrastructure, database, storage, monitoring or security providers
Payments	Paystack South Africa (Pty) Ltd and relevant banks or payment networks
Email and communications	A2 Hosting, Inc. provides business email hosting infrastructure. No dedicated transactional platform-email provider is currently implemented.
Customer organisations	Administrators, supervisors and authorised staff permitted to view relevant Customer Data and Agent Data
Professional advisers	Attorneys, accountants, auditors, insurers, tax and compliance advisers under appropriate confidentiality duties
Authorities	CIPC, SARS, the Information Regulator, courts and law enforcement where permitted or required
Business transactions	Potential investors, purchasers, successors or advisers under lawful processing and confidentiality safeguards

Cross-border processing

Trescent AI uses technology service providers that may process or store personal information outside South Africa. Cross-border processing is undertaken only where permitted by POPIA and subject to appropriate safeguards.

Provider	Purpose	Location
Render Services, Inc.	Cloud hosting, backend infrastructure, database and system logs	Frankfurt, Germany for the primary application and database region
Paystack and payment partners	Payment processing, verification, settlement and anti-fraud functions	South Africa and other countries used by Paystack and its partners, including AWS infrastructure in Ireland
A2 Hosting, Inc.	Business email hosting infrastructure	United States

Security safeguards

Depending on the system and information concerned, safeguards may include role-based permissions, authentication and session controls, encryption, customer-data separation, monitoring, audit trails, backups, controlled administrative access, confidentiality requirements, supplier review and incident-response procedures.

No internet-connected system can be guaranteed completely secure. Security incidents may be reported to security@trescent.co.za.

How to request access to a record

A requester must complete prescribed Form 2 and submit it to the Information Officer. A request to a private body must identify the right the requester seeks to exercise or protect and explain why the requested record is required for that purpose.

1
Download and complete Form 2.Open the official form
2
Identify yourself and the record.Provide sufficient detail about the requester, record and preferred form of access.
3
Attach supporting proof.Include proof of identity and, if acting for someone else, proof of authority.
4
Explain the right involved.Identify the right to be exercised or protected and why the record is required.
5
Submit the request.Email the signed request to privacy@trescent.co.za or deliver it to the address in section 3.
6
Pay a prescribed fee if required.Trescent AI will notify you if a lawful request fee, access fee or deposit applies.

A PAIA request must seek an existing recorded record. A general question, request for explanation, or request that Trescent AI create a new record is not necessarily a PAIA request.

Decision, fees and possible refusal

Time period

Trescent AI will communicate its decision as soon as reasonably possible and ordinarily within 30 calendar days after receiving a valid request. PAIA may permit a single extension of up to a further 30 days. The requester will be notified of the extension and reason.

Fees

Trescent AI may require a prescribed request fee, access fee or deposit where applicable. Current amounts and exemptions should be checked against the Information Regulator's PAIA fee structure.

Grounds for refusal

A request may or must be refused on grounds stated in PAIA, including protection of:

the privacy and personal information of third parties;
commercial information, trade secrets and financial interests;
confidential or legally privileged information;
the safety of individuals and security of property or systems;
research information where disclosure would cause serious disadvantage; and
records protected from disclosure by law.

If only part of a record is protected, Trescent AI will consider whether the protected information can reasonably be separated and access granted to the remainder.

Remedies and complaints

There is no compulsory internal appeal process for a private body. A requester or affected third party dissatisfied with a decision, fee, extension, form of access, failure to respond or other PAIA matter may lodge a complaint with the Information Regulator or approach a court, subject to PAIA.

Complaint form: Form 5: Complaint Form
Complaint email: PAIAComplaints@inforegulator.org.za
Website: inforegulator.org.za/paia
Telephone: 010 023 5200 / 0800 017 160
Address: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191
General enquiries: enquiries@inforegulator.org.za
General time period: A complaint should generally be lodged within 180 days of the decision or deemed refusal, subject to PAIA and any condonation process.

Availability and updating of this Manual

This Manual is available:

on this permanent Trescent AI legal page;
for inspection at Trescent AI's principal office during normal business hours, by prior arrangement;
to a person upon request, subject to any reasonable prescribed fee for a hard copy; and
to the Information Regulator upon request.

Publication URL: https://trescent.co.za/legal/paia
Inspection address: 13 Headingly Close, Sherwood, Port Elizabeth, South Africa
Business hours: Monday to Friday, 08:00–17:00 SAST, excluding South African public holidays, by prior arrangement

Trescent AI will review this Manual periodically and whenever material changes occur to its business, contact details, records, personal-information processing or legal obligations.

Issued on behalf of Trescent AI (Pty) Ltd Darryn Burton