Vital Pursuit · Consulting

Vital Pursuit PAIA Manual

Prepared in terms of Section 51 of the Promotion of Access to Information Act No. 2 of 2000 (as amended) for:

Table of contents

  1. List of acronyms and abbreviations
  2. Purpose of this manual
  3. Company details
  4. Information Officer and contact details for access to information
  5. The Regulator's Guide on how to use PAIA
  6. Records available without a formal request
  7. Records available in terms of other legislation
  8. Categories of records held by the Company
  9. Description of subjects and categories of records held
  10. Processing of personal information (POPIA section 51(1)(c) to (e))
  11. How to request access to records
  12. Fees
  13. Grounds for refusal of access
  14. Notice on data subject rights
  15. Availability of the manual
  16. Updating of the manual
  17. Signatory

1. List of acronyms and abbreviations

2. Purpose of this manual

This manual is compiled in accordance with Section 51 of PAIA. It explains what records the Company holds, how a person may request access to them, and how the Company processes personal information, as required by PAIA and by section 51(1)(c) to (e) of PAIA read with POPIA.

Overview of the Company and of Asset Assistant

The Company publishes the Asset Assistant mobile application on Google Play and provides technology and consulting services. Asset Assistant is an on-device asset register for South African businesses: a user photographs a movable asset, optional AI features identify it, read its invoice and estimate its value, and the register is exported to PDF, CSV or the user's own accounting system. The user's asset records and photographs are stored on the user's own device, not on the Company's systems, and the app has no user accounts. This design is reflected throughout sections 8 to 10 of this manual, and it is why the Company holds almost no records about app users.

3. Company details

4. Information Officer and contact details for access to information

Deputy Information Officer(s): none appointed.

5. The Regulator's Guide on how to use PAIA

In terms of Section 10 of PAIA, the Information Regulator has compiled a Guide on how to use PAIA and how to exercise the right of access to personal information under section 23 of POPIA. The Guide is available in all official languages and can be obtained as follows:

6. Records available without a formal request

The following records are available on the Company's website, or from the Information Officer on request, without a formal PAIA request:

The Asset Assistant legal documents are published at the addresses given in the app's Terms and Privacy screen and on the Google Play listing.

7. Records available in terms of other legislation

Where applicable, records are also available in terms of the following legislation, subject to the conditions in each Act:

8. Categories of records held by the Company

Corporate and operational records

Financial records

Personnel records

Client records (consulting)

Third-party service provider records

Asset Assistant records (the app)

The Company deliberately holds very little in relation to app users. The app has no user accounts and no server-side copy of any customer's register. What the Company does hold:

What the Company does not hold: customers' asset registers, photographs, invoices, GPS positions, backups, backup passphrases, payment card details, or anything a customer sends to their own accounting system (for example Xero) through the app.

9. Description of subjects and categories of records held

SubjectCategories of records
Strategy and planningBusiness plans, strategic documents
Human resourcesHR policies, employment contracts, employee records
Legal and complianceRegulatory compliance documents, PAIA manual, POPIA notices and policies, Information Officer registration
MarketingMarketing material, website and Google Play listing content, market research
Technology and productSystem architecture, software documentation, security documentation, Asset Assistant source code and release records
Asset Assistant service operationAI usage logs, support reports, purchase verification records, relay operation records (see section 8)
ConsultingClient contracts, deliverables, correspondence
FinanceAccounting records, tax records, Google Play reports

10. Processing of personal information

This section is included in terms of section 51(1)(c) to (e) of PAIA, read with POPIA.

10.1 Purpose of processing personal information

The Company processes personal information to:

10.2 Categories of data subjects and personal information

Category of data subjectPersonal information processed
Asset Assistant usersNo accounts are kept. The IP address and app identifier of each request are held in technical request logs for 90 days. Other personal information may arise only from: a support report or email the user chooses to send; a vendor name logged from an invoice with the user's consent; a report of an AI result. Photographs and documents sent for AI processing pass through the Company's service in transit only and are not stored.
Team-mode field workersA device label typed by the organisation owner and a pseudonymous device token. The organisation owner, not the Company, is the responsible party for the organisation's register.
Website enquirersName, email address, and optionally phone number and organisation, with the message they send through the contact form on https://vitalpursuit.co.za (and, if they choose to include it, the Strategy Preview text and AI response). Received by email and kept as business correspondence in Google Workspace.
Consulting clients and their staffName, business address, email, telephone number, role, contract and billing details, and any information the client supplies for a consulting engagement (which may include healthcare-related information where the engagement concerns a healthcare business)
Employees and contractorsName, address, identity number, employment history, qualifications, banking and payroll details
Service providersCompany details, contact information, banking and tax details

10.3 Recipients of personal information

Personal information may be shared with:

10.4 Planned transborder flows of personal information

The Company's own service and its retained logs run inside South Africa on Google Cloud. Transfers to OpenAI are necessary to provide the feature the user requests and are made under binding terms that require OpenAI to protect the data, as contemplated by section 72 of POPIA.

10.5 Information security measures

11. How to request access to records

  1. Complete the prescribed form. Use Form 2 (Request for Access to Record of a Private Body), available from the Information Regulator at https://inforegulator.org.za/wp-content/uploads/2020/07/InfoRegSA-PAIA-Form02-Reg7.pdf or from the Information Officer.
  2. Submit the form to the Information Officer by email to info-officer@vitalpursuit.co.za, or by post or hand delivery to 32 Ryneveld Street, Stellenbosch, 7600.
  3. Include in the request: a description of the record sufficient to identify it; the right you wish to exercise or protect and why the record is required for that purpose; the form of access you prefer (inspection, copy, electronic copy); your identity details and proof of identity; and, if you are requesting on behalf of someone else, proof of the capacity in which you act.
  4. Pay the applicable fees (section 12) when notified.

The Company will respond within 30 days of receiving a complete request, which may be extended once by up to 30 days where PAIA permits. If a request is refused, reasons will be given as PAIA requires.

If you need help completing the form, contact the Information Officer.

12. Fees

Fees are those prescribed in the PAIA Regulations (2021), Annexure B, as published by the Information Regulator. At the date of this revision:

The current schedule is at https://inforegulator.org.za/paia-fees-structure-2/. If the Regulator amends the fees, the amended fees apply.

13. Grounds for refusal of access

The Company may refuse access to a record on the grounds set out in Chapter 4 of Part 3 of PAIA, including where the record contains:

Access may not be refused where disclosure would reveal evidence of 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 (section 70). Where access is refused, the Company will give reasons as PAIA requires, and the requester may lodge a complaint with the Information Regulator or apply to court.

14. Notice on data subject rights

Under POPIA you have the right to:

To exercise these rights, contact the Information Officer at info-officer@vitalpursuit.co.za. Asset Assistant users control their own register directly on their device; uninstalling the app erases all local data.

15. Availability of the manual

A copy of this manual is available:

16. Updating of the manual

The Company will review this manual at least annually and update it whenever there is a change in legislation, in the Company's activities, or in the way it processes personal information. The dates of compilation and revision appear on the first page.

17. Signatory

Issued by:

Jan H. Esser Chief Executive Officer and Information Officer Bioscience and Technology Holdings (Pty) Ltd, trading as Vital Pursuit

Date: 17 September 2026