1. Introduction and purpose
Halloterra (Pty) Ltd, registration number 2026/154512/07, operates Amigomap as a trading name and business division. Amigomap provides a software-as-a-service mapping and experiential platform to businesses and organisations.
This Manual is prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000, as amended (PAIA), and includes information relevant to the Protection of Personal Information Act 4 of 2013 (POPIA).
PAIA gives effect to the constitutional right of access to information. In relation to a private body, access is available only where the requested record is required for the exercise or protection of a right and the procedural requirements of PAIA are met.
The listing of a record or category in this Manual does not mean that access will automatically be granted. Every request is considered under PAIA, including its mandatory and discretionary grounds for refusal.
2. Company and Information Officer details
| Private body | Halloterra (Pty) Ltd |
| Registration number | 2026/154512/07 |
| Trading name and division | Amigomap |
| Business description | SaaS mapping and experiential platform for businesses and organisations |
| Head of private body / Information Officer | David de Waal |
| Physical and postal address | 184 Upper Buitenkant Street, Oranjezicht, Cape Town, 8001, South Africa |
| Telephone | +27 82 901 0733 |
| PAIA and legal email | legal@amigomap.com |
| Privacy email | privacy@amigomap.com |
| Website | https://amigomap.com |
3. Availability and status of this Manual
This Manual is available in English on the Amigomap website at https://amigomap.com/PAIA_Manual.html and may be requested by email from legal@amigomap.com.
A copy may be inspected at 184 Upper Buitenkant Street, Oranjezicht, Cape Town, 8001, South Africa during normal business hours, subject to reasonable security and prior appointment arrangements.
This Manual may be updated when Halloterra's business, records, processing activities, contact details or applicable law changes.
4. The Information Regulator guide
The Information Regulator has published a guide explaining how to use PAIA, the forms and fees that apply, available remedies, and how to complain. The current guide and forms are available from the Information Regulator website.
| Information Regulator website | https://inforegulator.org.za |
| PAIA guidance | https://inforegulator.org.za/paia-guidelines/ |
| PAIA forms | https://inforegulator.org.za/paia-forms/ |
| Physical address | Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191 |
| Postal address | P.O. Box 31533, Braamfontein, Johannesburg, 2017 |
| Telephone | 010 023 5200 |
| Toll-free | 0800 017 160 |
| General enquiries | enquiries@inforegulator.org.za |
| PAIA complaints | PAIAComplaints@inforegulator.org.za |
5. Records available without a formal PAIA request
Halloterra has not published a notice under section 52 of PAIA declaring categories of records automatically available. However, the following information may ordinarily be accessed without a formal PAIA request, subject to availability and any applicable terms:
- information published on the Amigomap website, including product, pricing, support and legal information;
- Halloterra company information obtainable from the Companies and Intellectual Property Commission or another public register;
- public maps and public content intentionally made available through Amigomap by a customer, while that content remains published and accessible;
- documents or information supplied directly to a customer, user, supplier or other contracting party in the ordinary course of the relevant relationship; and
- information that a data subject may obtain through the processes described in the Amigomap Privacy Policy, subject to verification and applicable law.
6. Records held by Halloterra
Halloterra may hold the following categories of records. Access remains subject to PAIA, confidentiality, privacy, privilege, intellectual property and other legal restrictions.
| Subject | Categories of records or information |
|---|---|
| Corporate and governance | Company registration and constitutional documents; registers and resolutions; director and shareholder records; governance policies; statutory filings. |
| Finance, tax and billing | Accounting records; bank and payment records; invoices; Paddle transaction and settlement records; tax records; budgets; management accounts; insurance records. |
| Customers and users | Customer and organisation details; account and role records; invitations; domains; plans; usage and billing administration; support correspondence; contracts and commercial communications. |
| Amigomap service and Customer Content | Map configuration records; routes and tracks; map access settings; images, icons and logos; comments and photographs; published-map records; usage-meter records; backups and operational metadata. |
| Technology and security | Software and source-code records; architecture and technical documentation; access, audit, security and error logs; incident records; infrastructure and provider records; continuity and backup records. |
| Intellectual property | Copyright, trademark, domain-name, licence, design, confidential know-how and other proprietary records; third-party licence and attribution records. |
| Suppliers and service providers | Contracts; proposals; quotations; invoices; due-diligence records; service-level and data-processing terms; correspondence and performance records. |
| Marketing and communications | Website content; campaigns; enquiries; contact forms; newsletters; marketing preferences; market research and sales records. |
| Personnel and contractors, where applicable | Applications; contracts; payroll and tax records; performance and disciplinary records; leave, training, occupational health and safety, and other employment-related records. |
| Legal and compliance | Legal advice and privileged material; disputes and claims; regulatory communications; privacy and PAIA records; policies; risk assessments; compliance and incident records. |
7. Records retained under legislation
Halloterra retains records under legislation applicable to its activities. The following list is indicative, not exhaustive, and each item applies only to the extent relevant:
- Companies Act 71 of 2008;
- Income Tax Act 58 of 1962 and Tax Administration Act 28 of 2011;
- Value-Added Tax Act 89 of 1991;
- Electronic Communications and Transactions Act 25 of 2002;
- Consumer Protection Act 68 of 2008;
- Promotion of Access to Information Act 2 of 2000;
- Protection of Personal Information Act 4 of 2013;
- Copyright Act 98 of 1978 and Trade Marks Act 194 of 1993;
- Cybercrimes Act 19 of 2020;
- Basic Conditions of Employment Act 75 of 1997, Labour Relations Act 66 of 1995, Employment Equity Act 55 of 1998, Skills Development Act 97 of 1998, Unemployment Insurance Act 63 of 2001, Compensation for Occupational Injuries and Diseases Act 130 of 1993 and Occupational Health and Safety Act 85 of 1993, where applicable; and
- other statutes, regulations, codes, court orders or lawful regulatory requirements applicable from time to time.
A record kept under legislation is not necessarily available to every requester. Access remains subject to the relevant legislation and PAIA.
8. Processing of personal information
More detailed information is contained in the Amigomap Privacy Policy. The summary below is provided for section 51 of PAIA.
8.1 Purposes of processing
- providing, administering, securing and supporting Amigomap accounts and services;
- authenticating users and managing customer organisations, roles and invitations;
- hosting, delivering, moderating and displaying maps and Customer Content;
- measuring usage, administering plans, fulfilling purchases and maintaining billing and tax records;
- communicating with customers, users, prospects, suppliers and public contributors;
- preventing fraud, abuse and security incidents and enforcing agreements;
- improving service performance and features; and
- complying with law and establishing, exercising or defending legal rights.
8.2 Categories of data subjects and information
| Subject | Categories of records or information |
|---|---|
| Website visitors and prospects | Contact details; enquiries; device, browser, IP, usage and marketing-preference information. |
| Customers and organisation contacts | Identity, contact, company, contract, plan, billing, support and administrative information. |
| Authorised users and invitees | Name, email, organisation, role, account identifiers, authentication status, activity and support records. |
| Map viewers and public contributors | Technical usage information and, where submitted, names or aliases, comments, photographs, coordinates and associated metadata. |
| Suppliers, advisers and contractors | Identity, contact, contract, invoice, payment, due-diligence and correspondence records. |
| Personnel and applicants, where applicable | Identity, contact, employment, payroll, tax, qualification and performance information. |
8.3 Recipients or categories of recipients
- the relevant customer and its authorised account administrators;
- service providers supporting authentication, hosting, databases, cloud storage, mapping, media delivery, email, support, billing, security and monitoring, including providers such as Clerk, Paddle, Mapbox and Cloudinary;
- professional advisers, insurers, auditors and genuine transaction counterparties subject to appropriate safeguards;
- courts, regulators, law-enforcement bodies and other persons where disclosure is required or permitted by law; and
- other recipients instructed or authorised by the relevant customer or data subject, where lawful.
8.4 Transborder processing
Halloterra is based in South Africa, but users and service providers may be located in other countries. Personal information may therefore be processed outside South Africa. Where required, Halloterra uses contractual protections, provider due diligence and other lawful safeguards intended to meet section 72 of POPIA and other applicable transfer requirements.
8.5 Security measures
Halloterra uses reasonable technical and organisational safeguards appropriate to the information and risks involved. These may include access controls, authentication, secure transmission, segregation of customer data, logging, backups, provider management, vulnerability and incident management, and staff or contractor confidentiality controls. No system can be guaranteed to be completely secure.
9. How to request access to a record
A requester must use the prescribed Form 2, Request for Access to Record, available from the Information Regulator website. The completed form must be sent to the Information Officer at legal@amigomap.com or delivered to the address in section 2.
- Provide sufficient detail to identify the requester and the record requested.
- Attach proof of identity. If acting for another person, attach proof of authority or capacity.
- Identify the right to be exercised or protected and explain why the requested record is required for that purpose.
- State the preferred form of access and the contact details for the response.
- Pay any prescribed request fee, deposit or access fee when lawfully required.
A person who cannot complete the prescribed form because of illiteracy or disability may contact the Information Officer for reasonable assistance.
Halloterra will ordinarily decide a properly completed request within 30 days. PAIA permits the period to be extended once for not more than a further 30 days in specified circumstances, with written notice of the extension.
Halloterra can provide only records in its possession or under its control. Where a requested record cannot be found or does not exist, Halloterra will deal with the request as required by PAIA.
10. Fees
The request, reproduction, search, preparation, deposit and delivery fees prescribed under PAIA may apply. The current official fee structure is published by the Information Regulator at https://inforegulator.org.za/paia-fees-structure-2/.
The current prescribed request fee for a private-body request is R140, subject to any exemption or later amendment. Halloterra may require payment before processing or providing access where PAIA permits.
11. Grounds on which access may be refused
Halloterra may or must refuse access where PAIA requires or permits refusal. Grounds may include:
- unreasonable disclosure of a third party's personal information;
- protection of a third party's trade secrets, financial, commercial, scientific or technical information, or information supplied in confidence;
- breach of a duty of confidence owed to a third party;
- risks to safety, security, property or protected persons;
- records protected by legal professional privilege;
- Halloterra's trade secrets, commercial, financial, scientific or technical information, or information that could prejudice negotiations or commercial competition;
- research information whose disclosure would cause serious disadvantage;
- records whose disclosure is prohibited by another law; and
- requests that are manifestly frivolous or vexatious or would involve an unreasonable diversion of resources.
Where a record contains severable information, Halloterra will consider granting access to any part that may lawfully be disclosed.
12. Decisions, complaints and court remedies
Halloterra will notify the requester of its decision and any fees payable in the prescribed manner. A private body does not have an internal PAIA appeal process.
A requester or affected third party who is dissatisfied with a decision, or with a failure to respond, may submit a written complaint to the Information Regulator using the prescribed Form 5 within the period allowed by PAIA, generally 180 days from the relevant decision. The form and current submission methods are available at https://inforegulator.org.za/paia-forms/ and through the Regulator's eServices portal.
A court application may be made in the circumstances and within the periods provided by PAIA, generally after the complaints procedure under section 77A has been exhausted. A requester should obtain independent legal advice where necessary.
13. Approval and revision
This Manual was approved by David de Waal, Director and Head of Halloterra (Pty) Ltd, on 4 August 2026.
Last updated: 4 August 2026.