The Nothing Subscription

PAIA Manual

The Nothing Subscription (Pty) Ltd
Registration number 2026/397502/07

Prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 (as amended).

Date of compilation: 14 November 2026
Date of revision: 14 November 2026

1. Acronyms and abbreviations

  • "Company" or "we": The Nothing Subscription (Pty) Ltd
  • "IO": Information Officer
  • "Minister": Minister of Justice and Correctional Services
  • "PAIA": Promotion of Access to Information Act 2 of 2000 (as amended)
  • "POPIA": Protection of Personal Information Act 4 of 2013
  • "Regulator": Information Regulator (South Africa)

2. Purpose of this manual

This manual tells the public:

  • what categories of records we hold, and which are available without a formal request;
  • how to request access to a record, and the forms and fees involved;
  • who to contact;
  • how we process personal information, as required by POPIA;
  • what remedies are available if a request is refused.

We are a very small company that intentionally holds very little information. Most customer and payment information is held by Paddle.com, our Merchant of Record.

3. Key contact details

Information Officer: Luca Sebastian Henning (Managing Director)
Email for access requests: legal@nothingsubscription.com
General email: support@nothingsubscription.com
Phone: +27 82 662 5385
Physical and postal address: 2442 Christelle Street, Six Fountains Residential Estate, Silver Lakes, Pretoria, Gauteng, 0081, South Africa
Website: thenothingsubscription.com

We have not appointed a Deputy Information Officer.

4. Guide on how to use PAIA

The Regulator has published a Guide that explains how to use PAIA and POPIA to request information. It is available in all official languages and in braille.

The Guide sets out, among other things, the purpose of PAIA and POPIA, the contact details of Information Officers, how to make a request, the help available from the Regulator, and the remedies available if a request is refused.

You can get the Guide:

  • from the Regulator's website: inforegulator.org.za; or
  • from the Regulator directly: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001.

A copy of the Guide in English and Afrikaans can be requested from our Information Officer.

5. Records available without a request

These records are freely available on our website, thenothingsubscription.com:

CategoryRecordAvailable
LegalTerms and ConditionsWebsite
LegalRefund PolicyWebsite
PrivacyPrivacy NoticeWebsite
Access to informationThis PAIA ManualWebsite
CompanyName, registration number, address and contact detailsWebsite
ProductProduct description and pricesWebsite

6. Records held in terms of other legislation

We keep records as required by the following laws, where they apply to us:

LegislationRecords
Companies Act 71 of 2008Registration documents, Memorandum of Incorporation, securities register, director records, resolutions, beneficial ownership records
Income Tax Act 58 of 1962Income tax records
Tax Administration Act 28 of 2011Records supporting tax returns
Electronic Communications and Transactions Act 25 of 2002Website disclosures required by section 43
Consumer Protection Act 68 of 2008Terms and refund information
Protection of Personal Information Act 4 of 2013Privacy Notice, Information Officer registration
Promotion of Access to Information Act 2 of 2000This manual

7. Subjects and categories of records held

SubjectCategories of records
Company and statutoryCIPC registration documents, Memorandum of Incorporation, securities and beneficial ownership registers, resolutions
Finance and taxBank statements, accounting records, Paddle payout and sales reports, tax records
CustomersOrder details viewable in the Paddle dashboard (see section 8). We keep no separate customer database.
CorrespondenceEmails received at support@ and legal@, kept only as long as needed (see section 8)
Suppliers and service providersAgreements and invoices from Paddle, Framer, Google, Cloudflare and FNB
WebsiteWebsite content and aggregated, anonymous visitor statistics

8. Processing of personal information

8.1 Purpose

We process personal information only to:

  • run subscriptions, refunds and cancellations through Paddle;
  • answer emails sent to us;
  • keep company, financial and tax records required by law;
  • run and secure our website.

8.2 Categories of data subjects and their information

Data subjectPersonal information
CustomersName, email address, country, subscription amount and status, purchase history, as viewable in the Paddle dashboard. We never see card details.
People who email usEmail address, name if given, message content
Website visitorsIP address and browser details, received by our web host Framer. Framer's analytics use no cookies and do not store IP addresses.
DirectorName, ID number, contact details, as required for company records
Service providersBusiness contact details and invoices

8.3 Recipients

RecipientPurpose
Paddle.com Market LimitedMerchant of Record: payments, tax, subscriptions and customer details
Framer B.V.Website hosting and analytics
Google (Google Workspace)Email hosting
CloudflareDomain registration and DNS
First National BankBusiness banking
SARS, CIPC and the Information RegulatorStatutory filings and compliance
Accountants or auditorsFinancial and tax compliance, if appointed
Courts and law enforcementOnly when the law requires it

8.4 Transborder flows

Our service providers process information outside South Africa, including in the United Kingdom, the European Union and the United States. Each provider protects transfers under its own safeguards. Paddle, Framer and Google are established international providers with published data protection terms.

8.5 Security measures

  • We collect as little personal information as possible and keep no separate customer database.
  • Payment details are handled by Paddle and never reach us.
  • All our accounts (Paddle, Framer, Google, Cloudflare, FNB) are protected with strong passwords and two-factor authentication.
  • Only the director has access.
  • Emails are deleted within 30 days of being dealt with, unless needed for a legal matter.

9. How to request access to a record

  • Complete Form 2 (Request for Access to Record) prescribed under the PAIA Regulations. It is available on the Regulator's website, inforegulator.org.za, or from our Information Officer.
  • Email it to legal@nothingsubscription.com, or deliver it to the address in section 3.
  • Give enough detail for us to identify the record and you, and say how you want to receive it.
  • If you are requesting on behalf of someone else, include proof of your authority.

Fees: fees are as prescribed in the PAIA Regulations, published on the Regulator's website. A request fee does not apply to a personal requester asking for their own personal information. We will tell you if any fee applies before processing your request.

Timeline: we will respond within 30 days of receiving a complete request, as required by PAIA.

If your request is refused: you may lodge a complaint with the Information Regulator, or apply to court, as set out in PAIA.

10. Availability of this manual

This manual is available:

  • on our website, thenothingsubscription.com;
  • for inspection at the address in section 3, by arrangement;
  • on request from the Information Officer, at the prescribed fee for copies;
  • to the Information Regulator on request.

11. Updating this manual

We will review and update this manual regularly, and whenever our information practices change.

Issued by:

Luca Sebastian Henning
Information Officer and Managing Director
The Nothing Subscription (Pty) Ltd
14 November 2026