PAIA Manual

DL Integrated Services (Pty) Ltd

Registration number: 2026/288043/07

Registered address: [DAN: insert full postal/street address]

Email: daniel@dlintegratedservices.com

Telephone: [DAN: insert a number, or state "No telephone line currently registered; please contact via email"]

Fax: Not applicable.

Name: Daniel Ludik

Email: daniel@dlintegratedservices.com

Daniel Ludik is appointed as the Information Officer under section 55 of the Protection of Personal Information Act 4 of 2013 (POPIA), effective [DAN: insert date you are completing this].

No Deputy Information Officers have been designated. As the sole director of the company, the Information Officer role is held directly by the head of the body.

The Information Regulator has published a Guide on how to use PAIA, available at inforegulator.org.za.

A copy of the Guide may be requested from our Information Officer or accessed directly via the Information Regulator's website.

The following records are published on our website and available without a formal PAIA request:

This PAIA Manual (/paia).

Our Privacy Policy (/datenschutz).

Our Terms of Service (/terms).

Company registration and annual return records are available via the Companies and Intellectual Property Commission (CIPC).

No other records are currently held under separate legislative access regimes.

App users (registered learners): account data; profile data; voice recordings and derived analyses; learning and progress data; AI coach chat history; payment and billing metadata; technical usage data; and consent records. More detail is provided in our Privacy Policy (/datenschutz).

Classroom and company administrator accounts: aggregated, anonymised usage metrics only. Administrators do not have access to individual recordings, transcripts, chat content, or specific learner mistakes.

We process personal information to deliver the EnglishPro language-learning platform, including personalised exercises, AI-generated feedback, progress tracking, and certificates.

We also process information to bill subscribers, provide support, and meet legal and security obligations.

Full details of processing purposes are set out in our Privacy Policy (/datenschutz).

Individual app users: registered learners aged 16 and above, or learners aged 13 to 15 who have provided guardian consent. Information includes account, profile, learning, voice, and billing metadata.

Company and classroom administrators: business contact details and aggregated, anonymised usage data only.

Our processors: Supabase (database and authentication), Lemon Squeezy (payment processing), and Resend (transactional email).

For classroom accounts, the assigned teacher may see individually attributable learner results during active sessions.

Company administrators see only aggregated, anonymised data in the company dashboard.

We do not sell personal information and do not share it for marketing purposes.

Personal information is processed by infrastructure and service providers (Supabase, Lemon Squeezy, and Resend) that may process data outside South Africa.

Please see our Privacy Policy (/datenschutz), section 8, for the safeguards currently in place, including Data Processing Agreements incorporating Standard Contractual Clauses.

Row-level security is enforced at the database level, restricting access to authorised users only.

No payment card data is stored in our systems; card data is handled exclusively by Lemon Squeezy.

Data transmission is encrypted. Administrative access is limited to the Information Officer.

This manual is available on our website at all times.

It is also available for inspection at our registered address by prior appointment during normal business hours. Contact the Information Officer to arrange an appointment.