The Calabash of Knowledge (Pty) Ltd
Registration number: 2016/055019/07 Trading as: Calabash.courses
Last updated: 19.08.2026
The Promotion of Access to Information Act ("PAIA") gives effect to the constitutional right of access to information. It requires every private body to publish a manual explaining what records it holds and how a person may request access to them.
Section 7 of this manual sets out the processing information required by section 51(1)(c) read with the Protection of Personal Information Act ("POPIA"). It does not replace our privacy policy, which is the notice to data subjects required under section 18 of POPIA and which is available on our website. Where the two differ, the privacy policy governs how we handle personal information.
This manual is available free of charge on our website at calabash.courses and on request from the Information Officer.
| Head of the private body | Kyla Edinburg, Chief Executive Officer |
| Information Officer | Kyla Edinburg, Chief Executive Officer |
| Deputy Information Officers | None appointed |
| Directors | Kyla Edinburg, Leanne Zabow |
| Postal and physical address | 133 George Avenue, Fairfield, Johannesburg, 2196, South Africa |
| privacy [at] calabash.courses | |
| Website | calabash.courses |
The Information Regulator has compiled a guide, in each official language, containing information a person needs in order to exercise their rights under PAIA. It is available from:
The Information Regulator (South Africa) JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001 PO Box 31533, Braamfontein, Johannesburg, 2017 Email: enquiries@inforegulator.org.za Toll free: 0800 017 160 Web: inforegulator.org.za
We have not published a notice under section 52(2) of PAIA listing categories of records that are automatically available without a formal request.
The following are however freely available on our website without any request under PAIA: our privacy policy, our terms of use, course descriptions and pricing, and this manual.
We hold records in the following categories. Listing a record here does not mean access to it will be granted; a request is assessed against the grounds of refusal in Chapter 4 of PAIA.
Company and governance records Founding documents, CIPC registrations and returns, shareholder and director records, resolutions, statutory registers.
Financial records Annual financial statements, management accounts, bank records, invoices issued and received, payment records, tax returns and assessments.
Customer and user records Account registration details, professional registration numbers, course access and progress records, assessment results, certificates issued, payment history, support correspondence, marketing preferences and consent records.
Supplier and contractual records Agreements with service providers, including hosting, payment processing, email delivery, video hosting, analytics and advertising providers, and the operator agreements required under section 21 of POPIA.
Course and content records Course material, video content, presenter agreements, accreditation submissions and correspondence with professional bodies.
Operational and technical records Application source code, system configuration, server and access logs, backup records, security incident records.
Marketing records Mailing lists, campaign records, advertising account records and audience lists.
We hold records in terms of, among others:
Companies Act 71 of 2008
Income Tax Act 58 of 1962
Value Added Tax Act 89 of 1991
Tax Administration Act 28 of 2011
Protection of Personal Information Act 4 of 2013
Consumer Protection Act 68 of 2008
Categories of data subjects and their personal information
| Data subject | Personal information held |
| Customers and registered users | Name, email address, password (stored in encoded form), professional registration number, country, course activity and progress, assessment results, certificates, payment history, support correspondence, marketing preferences, IP address and device information |
| Suppliers and service providers | Contact person's name, email address, telephone number, banking details where relevant |
| Presenters and partner content producers | Name, contact details, professional credentials, biography, banking details and revenue-share payment records |
| Directors and shareholders | Name, identity number, contact details, shareholding |
| Purposes of processing | To provide access to our courses and platform, to maintain records of professional development completed, to take and record payment, to provide support, to send service and marketing communications, to advertise our services, to operate and improve the platform, and to meet our legal and tax obligations. |
| Recipients of personal information | Our service providers, being xneelo (hosting), Stripe and our Australian payment facility (payment processing), Mailjet (email delivery), Vimeo (video hosting), Google (analytics), Hotjar (analytics), and Meta (advertising). Also our professional advisers, and any regulator, court or law enforcement body entitled to the information. |
| Transborder flows | Personal information is hosted in Germany and is transferred to service providers located in the European Union and the United States. Transfers are made on the grounds set out in section 72 of POPIA, being that the recipient is subject to a law or binding agreement providing an adequate level of protection, or that the transfer is necessary to perform our contract with the data subject. |
| Security measures | Personal information is transmitted over encrypted connections. Servers are hosted in Germany and the database is backed up daily, with backups retained for 24 hours. Access to production systems and the administrative interface is limited to named individuals and sign-ins are logged. Card details are not stored on our systems; payments are handled by Stripe. |
Complete the prescribed request form and send it to the Information Officer at the address in section 2. The form is annexed to this manual and is also available from inforegulator.org.za.
Provide enough detail to identify the record and to identify yourself, and state the form of access you want and how you want to be told the outcome.
If you are requesting the record in order to exercise or protect a right, identify that right and explain why the record is required to exercise or protect it.
If you are making the request on behalf of someone else, submit proof of your authority.
Two fees may apply: a request fee, and an access fee covering the cost of searching for, preparing and reproducing the record.
A personal requester, meaning someone requesting a record about themselves, does not pay a request fee.
Fees are those prescribed in the PAIA Regulations from time to time. We will give you a written estimate before doing any work you have to pay for. If you think a fee is wrong, see section 11. Current prescribed fees are published at inforegulator.org.za.
Access may be refused on the grounds set out in Chapter 4 of PAIA, which include:
protection of the privacy of a third party who is a natural person (section 63);
protection of commercial information of a third party, including trade secrets and financial or commercial information likely to harm their interests (section 64);
protection of information supplied in confidence where disclosure would breach a duty of confidence (section 65);
protection of the safety of individuals and of property (section 66);
protection of records privileged from production in legal proceedings (section 67);
protection of our own commercial information, including trade secrets, research and information whose disclosure would put us at a disadvantage in negotiations or commercial competition (section 68); and
PAIA does not provide for an internal appeal against a decision by a private body. If your request is refused, or you are unhappy with the fee, the form of access or the time taken, you may:
complain to the Information Regulator at enquiries@inforegulator.org.za, or through the complaints process published at inforegulator.org.za; or
This manual is available:
on our website at calabash.courses;
from the Information Officer on request, by email or post; and
Copies are provided free of charge on our website. A charge equal to the prescribed reproduction fee applies to printed copies.