Prepared in accordance with Section 51 of the Promotion of Access to Information Act, No. 2 of 2000 ("PAIA"), as amended by the Protection of Personal Information Act, No. 4 of 2013 ("POPIA").
Entity: Yield SPM (Pty) Ltd
Registration Number: 2024/185151/07
Version: 1.0
Effective Date: April 2026
Next Review: April 2027
Required under Section 51(1)(a) of PAIA
| Detail | Information |
|---|---|
| Information Officer | Lindie le Roux |
| Deputy Information Officer | Karel le Roux (Charl) |
| Postal Address | 23 Kameeldoringdraai, Woodland Hills, Bloemfontein, Free State, 9301 |
| Street Address | 23 Kameeldoringdraai, Woodland Hills, Bloemfontein, Free State, 9301 |
| Telephone | 084 460 7266 |
| privacy@practacular.com | |
| Website | https://alteragro.com |
Required under Section 51(1)(b) of PAIA
The South African Human Rights Commission ("SAHRC") has compiled a guide in terms of Section 10 of PAIA. This guide contains information to assist a person wishing to exercise any right contemplated in PAIA. The guide is available from:
Required under Section 51(1)(c) of PAIA (as read with Section 52)
The following categories of records are available on the Yield SPM website (alteragro.com) without a formal PAIA request:
Required under Section 51(1)(d) of PAIA
Yield SPM holds records that may be required or produced in terms of the following legislation. This list is not exhaustive and is provided for reference only. The inclusion of any legislation does not imply that all records held by Yield SPM fall under such legislation.
| Legislation | Records |
|---|---|
| Companies Act 71 of 2008 | Memorandum of Incorporation, share register, director records, annual returns, financial statements |
| Income Tax Act 58 of 1962 | Tax returns, tax certificates, provisional tax records |
| Value-Added Tax Act 89 of 1991 | VAT registration, returns, invoices |
| Basic Conditions of Employment Act 75 of 1997 | Employment contracts, attendance records (if applicable) |
| Electronic Communications and Transactions Act 25 of 2002 | Electronic contracts, consent records, data messages |
| Protection of Personal Information Act 4 of 2013 | Consent records, data subject requests, processing records, security compromise notifications |
| Consumer Protection Act 68 of 2008 | Subscription agreements, cancellation records, refund records |
| Financial Intelligence Centre Act 38 of 2001 | Client identification and verification records (if applicable) |
| Promotion of Access to Information Act 2 of 2000 | This manual, request records |
| Copyright Act 98 of 1978 | Software source code, documentation, creative works |
Required under Section 51(1)(e) of PAIA
Required under Section 51(1)(c)(i) of PAIA, as inserted by Section 112 of POPIA
Yield SPM processes personal information for the following purposes:
| Purpose | Lawful Basis (POPIA Section 11) |
|---|---|
| To provide the Practacular practice management service to accounting firms | Performance of a contract (Section 11(1)(b)) |
| To provide the Atteste art collection management service | Performance of a contract (Section 11(1)(b)) |
| To process subscription payments | Performance of a contract (Section 11(1)(b)) |
| To comply with tax, accounting, and company law obligations | Compliance with a legal obligation (Section 11(1)(c)) |
| To send service-related communications (not marketing) | Legitimate interest (Section 11(1)(f)) |
| To improve our products through aggregated, anonymised usage analysis | Legitimate interest (Section 11(1)(f)) |
| To detect and prevent fraud or security incidents | Legitimate interest (Section 11(1)(f)) |
| AI-assisted processing of financial data (Practacular) | Consent (Section 11(1)(a)) |
| AI-assisted analysis of artwork and voice data (Atteste) | Consent (Section 11(1)(a)) |
Required under Section 51(1)(c)(ii) of PAIA, as inserted by Section 112 of POPIA
| Category | Personal Information |
|---|---|
| Firm administrators | Name, email, phone, CIPC registration number, firm address |
| Staff members | Name, email, role within firm |
| Firm clients (processed on behalf of accounting firms) | Name, ID number, tax number, financial data, contact details |
| Category | Personal Information |
|---|---|
| Individual collectors | Name, email, subscription tier, profile preferences |
| Gallery partners | Business name, contact person, email, subscription details |
| Heirs/estate designees | Name, contact details, relationship to collector |
| Category | Personal Information |
|---|---|
| Website visitors | IP address, browser information (via standard web logs only) |
| Correspondents | Name, email, content of correspondence |
Required under Section 51(1)(c)(iii) of PAIA, as inserted by Section 112 of POPIA
Personal information may be shared with the following categories of recipients:
| Recipient | Purpose | Jurisdiction |
|---|---|---|
| Anthropic, PBC (Claude AI) | AI text processing for both products | United States |
| Google LLC (Gemini AI) | AI vision, text, and speech-to-text processing | United States |
| ElevenLabs, Inc. | Voice synthesis (Atteste only) | United States |
| Paystack Payments Limited | Payment processing (Practacular) | Nigeria / South Africa |
| Lemon Squeezy, LLC | Payment processing as Merchant of Record (Practacular) | United States |
| Google Cloud Platform | Cloud hosting (Firestore, Cloud Functions, Storage) | South Africa (africa-south1 region) |
| South African Revenue Service | As required by law | South Africa |
| Information Regulator | As required by POPIA | South Africa |
| Law enforcement | As required by law or court order | South Africa |
Required under Section 51(1)(c)(iv) of PAIA, as inserted by Section 112 of POPIA
Yield SPM transfers personal information outside the Republic of South Africa in the following circumstances:
| Transfer | Destination | Safeguard (POPIA Section 72) |
|---|---|---|
| AI text processing via Anthropic Claude | United States | Contractual obligations ensuring POPIA-equivalent protection (Section 72(1)(a)) and consent of data subjects (Section 72(1)(b)) |
| AI vision/STT processing via Google Gemini | United States | Contractual obligations and consent |
| Voice synthesis via ElevenLabs | United States / EU | Contractual obligations and consent |
| Payment processing via LemonSqueezy | United States | Contractual obligations (Merchant of Record model) and necessity for performance of contract (Section 72(1)(c)) |
| Payment processing via Paystack | Nigeria / South Africa | Contractual obligations and necessity for performance of contract |
All cross-border transfers are disclosed to data subjects in the relevant Privacy Policy and consent is obtained prior to first use of the products.
Note: Primary data storage (Firestore) is hosted in the Google Cloud africa-south1 region (Johannesburg, South Africa). Personal information at rest remains within South Africa.
Required under Section 51(1)(c)(v) of PAIA, as inserted by Section 112 of POPIA
In accordance with Section 19 of POPIA, Yield SPM maintains the following technical and organisational measures:
Required under Section 51(1)(f) of PAIA
A request for access to a record held by Yield SPM must be made on the prescribed Form C (as set out in Annexure A of the PAIA Regulations, Government Gazette No. 44946 of 27 August 2021).
The completed Form C must be submitted to the Information Officer at:
The requester must:
The Information Officer will respond within 30 days of receipt of a properly completed request, as required by Section 56 of PAIA.
Access may be refused on the grounds set out in Chapter 4 of Part 3 of PAIA, including but not limited to:
The Information Officer will provide written reasons for any refusal.
Required under Section 51(1)(f) of PAIA, read with Section 54
The fees for access to records are prescribed by the PAIA Regulations (Annexure B, Government Gazette No. 44946 of 27 August 2021).
A request fee and an access fee may be payable. The Information Officer will notify the requester of any applicable fees before providing access. A deposit may be required if the access fee is likely to exceed a prescribed threshold.
The requester may lodge an application with a court against the payment of the access fee in terms of Section 54(3)(b) of PAIA.
In addition to the right of access under PAIA, data subjects have the following rights under POPIA:
| Right | POPIA Section | Description |
|---|---|---|
| Right to be notified | Section 18 | To be told what personal information is being collected and why |
| Right of access | Section 23 | To request confirmation and access to personal information held |
| Right to correction | Section 24 | To request correction or deletion of inaccurate, irrelevant, or excessive information |
| Right to object | Section 11(3) | To object to processing based on legitimate interest |
| Right to complain | Section 74 | To submit a complaint to the Information Regulator |
| Right not to be subject to automated decision-making | Section 71 | To not be subject to a decision based solely on automated processing, including profiling |
To exercise any of these rights, contact the Information Officer at privacy@practacular.com.
This manual is available:
This manual will be reviewed and updated at least annually, or when there are material changes to the personal information processing activities of Yield SPM (Pty) Ltd.
| Version | Date | Changes |
|---|---|---|
| 1.0 | April 2026 | Initial version |
This manual does not constitute legal advice. It has been prepared to comply with the requirements of Section 51 of the Promotion of Access to Information Act 2 of 2000 and the relevant provisions of the Protection of Personal Information Act 4 of 2013.