PAIA manual — ZARP Stablecoin (Pty) Ltd
Prepared under section 51 of the Promotion of Access to Information Act 2 of 2000, as amended · Version 1 · compiled 4 November 2026
1. Acronyms
| FIC Act | Financial Intelligence Centre Act 38 of 2001 |
| Inves | Inves Capital (Pty) Ltd, registration number 2016/437415/07 |
| PAIA | Promotion of Access to Information Act 2 of 2000, as amended |
| POPIA | Protection of Personal Information Act 4 of 2013 |
| Regulator | Information Regulator |
| ZARP Stablecoin | ZARP Stablecoin (Pty) Ltd, registration number 2020/762178/07 |
2. What this manual is for
This manual helps you:
- find the records ZARP Stablecoin makes available without a request (section 5);
- make a request for a record ZARP Stablecoin holds, knowing the subjects it holds records on (sections 7 and 9);
- find the records ZARP Stablecoin holds under other laws (section 6);
- reach ZARP Stablecoin’s Information Officer (section 3);
- find the Regulator’s guide on how to use PAIA (section 4); and
- know how ZARP Stablecoin processes personal information (section 8).
3. Contact details
ZARP Stablecoin is a private company and a juristic representative of Inves Capital (Pty) Ltd. It runs the ZARP brand and the website zarpstablecoin.com. Inves, not ZARP Stablecoin, issues and redeems ZARP, contracts with ZARP partners and is responsible for their personal information; Inves publishes its own manual at inv.es/paia-manual.html. ZARP Stablecoin was registered as Rand Reserve (Pty) Ltd and later named Venox Digital Assets (Pty) Ltd.
| Information Officer | The Information Officer of ZARP Stablecoin (Pty) Ltd |
| Email, for requests under PAIA and POPIA | compliance@zarpstablecoin.com |
| Telephone | +27 64 874 1021 |
| Physical address | 31 Parliament Street, Speakers Corner, Cape Town, 8000 |
| Postal address | 31 Parliament Street, Speakers Corner, Cape Town, 8000 |
| General email | hello@zarpstablecoin.com |
| Website | zarpstablecoin.com |
4. The Regulator’s guide on how to use PAIA
4.1 The Regulator has updated and made available the Guide on how to use PAIA under section 10(1) of PAIA. It is for anyone who wishes to exercise a right under PAIA or POPIA.
4.2 The Guide is available in each official language and in braille. It describes the objects of PAIA and POPIA; how to reach information officers; how to request a record of a public or private body; the help available from the Regulator; every remedy, including a complaint to the Regulator and an application to court; the manuals bodies must compile; the voluntary disclosure of records; the fees; and the regulations made under PAIA.
4.3 You can get the Guide:
- from the Regulator’s website, inforegulator.org.za;
- from the Regulator’s office, during normal office hours; or
- on request to ZARP Stablecoin’s Information Officer.
4.4 A copy of the Guide in English and Afrikaans is available for inspection at ZARP Stablecoin’s office, at the address in section 3, during normal business hours.
5. Records available without a request
| Category | Records | On the website | On request |
|---|---|---|---|
| Terms | The ZARP Terms of Service | zarpstablecoin.com/terms | ✓ |
| Disclosures | The FAIS disclosure; the compliance page | zarpstablecoin.com/fais-disclosure; zarpstablecoin.com/compliance | ✓ |
| Reserves | The independent reserve attestation reports for ZARP | zarpstablecoin.com/transparency | ✓ |
| Data protection | Inves’s privacy policy; this manual | zarpstablecoin.com/privacy; zarpstablecoin.com/paia-manual | ✓ |
| News | Articles about ZARP | zarpstablecoin.com/news | ✓ |
6. Records held under other laws
| Law | Records |
|---|---|
| Companies Act 71 of 2008 | Memorandum of incorporation, registers of directors and securities, minutes and resolutions, annual financial statements |
| Financial Intelligence Centre Act 38 of 2001 | Records of its registration with the Financial Intelligence Centre |
| Financial Advisory and Intermediary Services Act 37 of 2002 | Records of its appointment as a juristic representative of Inves |
| Income Tax Act 58 of 1962; Tax Administration Act 28 of 2011; Value-Added Tax Act 89 of 1991 | Tax records and returns |
| Electronic Communications and Transactions Act 25 of 2002 | Electronic records |
| Protection of Personal Information Act 4 of 2013 | Records of the processing of personal information |
| Promotion of Access to Information Act 2 of 2000 | This manual; records of requests |
7. Subjects on which ZARP Stablecoin holds records
| Subject | Categories of records |
|---|---|
| Company and governance | Incorporation documents, statutory registers, board and shareholder resolutions, minutes |
| Representation | Its appointment as Inves’s juristic representative; correspondence with Inves |
| Treasury held for Inves | Statements of the two bank and investment accounts it holds in its own name as Inves’s agent; the reserve attestation report issued in its name in September 2026 |
| Website and brand | The content of zarpstablecoin.com; messages sent through its forms and to its mailboxes, which it passes to Inves |
| Cloud account held for Inves | The transitional Amazon Web Services account, held in ZARP Stablecoin’s name, in which Inves’s partner platform runs until Inves’s own accounts replace it |
| Finance | Financial statements, accounting and tax records |
| Suppliers and advisers | Agreements, invoices and correspondence |
8. Processing of personal information
8.1 Purpose
ZARP Stablecoin processes personal information:
- for Inves, as its juristic representative: when it runs zarpstablecoin.com and its forms, receives messages to its mailboxes and holds the cloud account Inves’s platform runs in. Inves decides what is done with that information and is responsible for it; its privacy policy explains how; and
- for itself: to run the company, keep its accounts and deal with its directors, shareholders, suppliers and advisers.
8.2 Data subjects and their information
| Data subjects | Personal information |
|---|---|
| People who use zarpstablecoin.com’s forms or write to its mailboxes | Name, email address, company, message; for the CARF self-certification form, the company’s tax details and the signatory’s name, email address and capacity |
| Website visitors | IP address and browser details, in the hosting provider’s logs |
| ZARP partners and their people, in the platform Inves runs in the account ZARP Stablecoin holds | As described in Inves’s privacy policy |
| Directors and shareholders | Names, contact details, identity numbers, shareholdings |
| Suppliers and advisers | Names, contact details, registration and VAT numbers, bank details |
8.3 Recipients
| Personal information | Recipients |
|---|---|
| Website messages and form submissions | Inves Capital (Pty) Ltd; Formspree, which delivers the forms |
| Google (Google Workspace) | |
| Website visitors’ IP addresses and browser details | GitHub, which hosts zarpstablecoin.com; Google Fonts and CoinGecko, which serve parts of its pages |
| The platform data in the cloud account | Amazon Web Services; Inves Capital (Pty) Ltd and its technology provider, Totemiq Limited, as Inves’s privacy policy describes |
| Company and tax records | The Companies and Intellectual Property Commission; the South African Revenue Service; its auditors and legal advisers |
8.4 Transborder flows
| To | Country | Information |
|---|---|---|
| Formspree | United States | Form submissions |
| Several countries | ||
| GitHub, Google Fonts, CoinGecko | United States and other countries | Website visitors’ IP addresses and browser details |
The platform data in the cloud account is stored in Cape Town; Inves’s privacy policy describes how it leaves South Africa.
8.5 Security measures
- The cloud account’s data stored in Cape Town, encrypted at rest and in transit, under the measures in Inves’s privacy policy.
- Form submissions and messages passed only to Inves.
- Access to the company’s records limited to the people who need it.
8.6 Retention
ZARP Stablecoin keeps its company and tax records for the periods the Companies Act and tax law require. Information it holds for Inves is kept for the periods in Inves’s privacy policy.
9. How to request a record
9.1 Who may ask. Anyone may ask for a record of ZARP Stablecoin that they need to exercise or protect a right (PAIA section 50). You may also ask for your own personal information under POPIA section 23, by the same procedure. A request about information ZARP Stablecoin holds for Inves is passed to Inves to answer.
9.2 How. Send Form 2 of the PAIA Regulations, 2021 to the Information Officer at the email or address in section 3. The form is in the Regulations and in the Regulator’s Guide. State the record, the right you need it for, and how you want to receive it. If you ask for someone else, include proof that you may.
9.3 Fees. The fees are those prescribed for private bodies in Annexure B of the PAIA Regulations, 2021. A request fee is payable before a request is processed, except by a person asking for their own personal information. ZARP Stablecoin may also charge for searching for and preparing a record, and for copies. If the search will take more than six hours, it may ask for a deposit of up to one third of the access fee. It tells you the fees on Form 3 before it processes the request.
9.4 Answer. ZARP Stablecoin answers within 30 days of receiving the request. It may extend that once, by up to 30 days, and tells you why (PAIA sections 56 and 57). If it does not answer in time, the request is regarded as refused.
9.5 Third parties. If a record concerns another person, ZARP Stablecoin tells that person and considers what they say before deciding (PAIA section 71).
9.6 Grounds for refusal. ZARP Stablecoin must or may refuse access on the grounds in Chapter 4 of Part 3 of PAIA, including to protect another person’s privacy, a third party’s commercial or confidential information, the safety of people or property, records privileged in legal proceedings, and its own commercial information.
9.7 Correction, deletion and objection. To ask for personal information to be corrected or deleted, use Form 2 of the POPIA Regulations, 2018. To object to its processing, use Form 1 of those Regulations.
9.8 Remedies. If you disagree with the decision, you may complain to the Regulator within 180 days (PAIA sections 77A and 77B), or apply to a court (section 78). The Regulator: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191; PAIAComplaints@inforegulator.org.za for access requests and POPIAComplaints@inforegulator.org.za for personal information; 010 023 5200; inforegulator.org.za.
10. Availability and updating of this manual
10.1 This manual is available:
- on zarpstablecoin.com/paia-manual;
- at ZARP Stablecoin’s office, at the address in section 3, for inspection during normal business hours;
- to anyone on request, for the copying fee in Annexure B of the PAIA Regulations, 2021; and
- to the Regulator, on request.
10.2 The Information Officer reviews this manual at least once a year, and whenever what it describes changes.
Issued by the Information Officer, ZARP Stablecoin (Pty) Ltd