POPIA & PAIA Manual

Last updated: 12 June 2026

PromoStars is a South African online discovery, presentation, and enquiry platform for promotional models, brand ambassadors, hostesses, event staff, agencies, brands, campaign managers, event organisers, and related users.

This page is intended to serve as PromoStars’ privacy and access-to-information notice for purposes of the Protection of Personal Information Act, 4 of 2013 (“POPIA”) and the Promotion of Access to Information Act, 2 of 2000 (“PAIA”), where applicable.

1. Operator and Responsible Party Details

2. Purpose of This Manual

This manual is intended to help users, data subjects, clients, agencies, models, suppliers, and members of the public understand:

• What personal information PromoStars may process.
• Why PromoStars processes personal information.
• Which categories of people and organisations may be affected.
• Who personal information may be shared with.
• How data subjects may request access, correction, deletion, objection, or restriction.
• How PAIA access-to-information requests may be submitted.
• How PromoStars approaches privacy, security, retention, and platform transparency.

3. Categories of Data Subjects

PromoStars may process personal information relating to:

• Promotional models, brand ambassadors, hostesses, event staff, and other talent users.
• Clients, agencies, brands, campaign managers, recruiters, and event organisers.
• Registered account users.
• Website visitors and users who browse public pages.
• People who submit enquiries, support requests, complaints, legal notices, or privacy requests.
• Service providers, contractors, platform administrators, moderators, and technical support contacts.
• Any person whose image, name, contact detail, or other information appears in user-submitted content.

4. Categories of Personal Information Processed

Depending on how the platform is used, PromoStars may process:

• Identity and profile information, including name, alias, biography, city, services, experience, and public profile details.
• Contact information, including email address, phone number, social links, and communication preferences.
• Photographs, portfolio images, profile images, and other media submitted to the platform.
• Profile attributes, such as service categories, location/city, presentation details, ratings, featured status, and profile indicators.
• Account information, including login details, password hashes, roles, profile state, moderation state, and account activity.
• Enquiry and opportunity information, including client details, event details, request messages, dates, venues, and shortlists.
• Technical information, including IP address, browser/device data, cookies, analytics events, security logs, and session data.
• Administrative, moderation, support, complaint, legal, and audit information.

5. Special Personal Information and Children

PromoStars does not intentionally require users to submit special personal information unless it is necessary for a lawful platform purpose or the user deliberately chooses to include it in submitted content. Users should not upload unnecessary sensitive information to public profiles.

Public talent profiles are intended for adults. Users creating public talent profiles or applying for opportunities must be at least 18 years old unless PromoStars has expressly approved a different arrangement in writing and a competent parent or legal guardian has provided all required consent.

6. Purposes of Processing

PromoStars may process personal information to:

• Create, review, moderate, publish, and manage profiles.
• Enable public discovery of promotional models, brand ambassadors, hostesses, and event staff.
• Allow clients and agencies to browse, shortlist, request, contact, and review potential talent.
• Generate profile pages, profile cards, PDF shortlists, QR-code links, discovery pages, and related platform features.
• Send account, enquiry, operational, safety, moderation, legal, and support communications.
• Operate login, security, session handling, abuse prevention, fraud prevention, and platform protection features.
• Improve site usability, search discovery, analytics, SEO performance, and platform functionality.
• Handle complaints, disputes, legal notices, POPIA requests, PAIA requests, and regulatory obligations.
• Comply with applicable law, enforce terms, and protect legitimate business interests.

7. Legal Basis and Justification

PromoStars processes personal information where there is a lawful basis to do so, including consent, contract-related necessity, compliance with legal obligations, legitimate interests, protection of rights, platform operation, fraud/security prevention, and information that a user has deliberately made public through a profile or submission.

8. Public Profiles, Search Engines, and Sharing

PromoStars is a discovery platform. Public profile information may be displayed publicly, indexed by search engines, included in internal search results, shared in shortlist packs, sent to clients or agencies, and used in platform discovery pages.

Users should only publish information and images that they are comfortable making visible in this context. Removing a profile from PromoStars does not guarantee immediate removal from third-party caches, search indexes, screenshots, downloads, or records lawfully retained by third parties.

9. Recipients and Categories of Recipients

Personal information may be shared with:

• Clients, agencies, brands, campaign managers, event organisers, and other platform users for opportunity-related purposes.
• Hosting, email, analytics, security, database, storage, backup, development, and technical service providers.
• Professional advisers, legal representatives, auditors, insurers, or regulators where required.
• Law enforcement, courts, regulators, or public bodies where legally required or reasonably necessary.
• Third parties involved in handling complaints, disputes, abuse reports, legal requests, or platform-protection matters.

10. Cross-Border Processing

Some technical service providers, email providers, analytics providers, hosting providers, or cloud services may process or store information outside South Africa. Where this occurs, PromoStars will take reasonable steps to use reputable providers and appropriate safeguards consistent with applicable law.

11. Retention

PromoStars retains personal information for as long as reasonably necessary for the purposes for which it was collected, including platform operation, profile publication, account management, legal compliance, security, audit, dispute handling, fraud prevention, and legitimate business purposes.

Users may request correction, removal, deactivation, or deletion of certain personal information. PromoStars may retain limited records where required or permitted by law, including for legal, security, audit, dispute, backup, or abuse-prevention purposes.

12. Security Safeguards

PromoStars uses reasonable administrative, technical, and organisational safeguards intended to protect personal information against loss, damage, unauthorised access, unlawful processing, misuse, alteration, or disclosure.

No online platform can guarantee absolute security. Users are responsible for keeping login credentials secure and notifying PromoStars if they suspect unauthorised access to their account.

13. Security Compromises

If PromoStars has reasonable grounds to believe that personal information has been accessed or acquired by an unauthorised person, PromoStars will take reasonable steps required by applicable law, which may include investigating the incident, restoring system integrity, notifying the Information Regulator, notifying affected data subjects where required, and taking steps to reduce potential harm.

14. Data Subject Rights

Subject to applicable law and verification requirements, data subjects may request that PromoStars:

• Confirm whether PromoStars holds personal information about them.
• Provide access to their personal information.
• Correct or update inaccurate, outdated, incomplete, excessive, or misleading information.
• Delete or remove information that PromoStars is no longer authorised to retain.
• Object to certain processing where permitted by law.
• Restrict or stop certain direct marketing or non-essential communications.
• Deactivate or remove a public profile, subject to reasonable retention and legal limitations.

15. How to Submit a POPIA Request

POPIA requests should be sent to info@promostars.co.za. PromoStars may require reasonable proof of identity and authority before processing a request.

Please include enough information for PromoStars to identify the relevant account, profile, enquiry, or record. Do not send unnecessary sensitive information.

16. PAIA Access-to-Information Requests

PAIA allows a requester to request access to records held by a private body where the record is required for the exercise or protection of a right and the procedural requirements are met.

PAIA requests should be sent to info@promostars.co.za and addressed to the Information Officer. A requester should clearly identify:

• The record requested.
• The right the requester seeks to exercise or protect.
• Why the requested record is required for that right.
• The requester’s contact details.
• Proof of identity and authority, where applicable.
• The preferred form of access, where reasonably possible.

17. Categories of Records Held

PromoStars may hold the following categories of records:

• Company, operator, administrative, domain, platform, and governance records.
• Website, software, database, hosting, backup, security, analytics, and technical records.
• User account, profile, moderation, support, complaint, and communication records.
• Client, agency, enquiry, shortlist, event brief, and opportunity-related records.
• Marketing, SEO, content, page, media, and platform-publication records.
• Supplier, contractor, service-provider, invoice, tax, accounting, and operational records.
• Legal, compliance, privacy, POPIA, PAIA, dispute, and audit records.

18. Records Automatically Available

Certain information may be available without a formal PAIA request, including public website pages, public model profiles, published legal pages, platform help pages, public discovery pages, public marketing content, and other information made openly available on the PromoStars website.

19. Grounds for Refusal or Limitation

Access to records may be refused, limited, redacted, delayed, or conditioned where permitted or required by law, including where disclosure would affect privacy, confidentiality, commercial information, legal privilege, safety, security, third-party rights, law enforcement, active disputes, or information that PromoStars is not legally required or permitted to disclose.

20. Fees

PAIA requests may be subject to prescribed fees, reproduction fees, search/preparation fees, or access fees where permitted by law. PromoStars may provide an estimate where applicable before processing a request that requires payment.

21. Complaints and the Information Regulator

If a requester or data subject is not satisfied with PromoStars’ response, they may have the right to complain to the Information Regulator or pursue other remedies available under applicable law.

PromoStars encourages users to contact us first so that we can attempt to resolve privacy, profile, access, correction, or removal concerns directly.

22. Related Pages

• Download PDF Manual
• Privacy Policy
• Terms of Use
• Promotional Model Safety Guide