Last updated: 15 April 2026

Prepared in accordance with section 51 of the Promotion of Access to Information Act, 2 of 2000 (“PAIA”), as amended, and the Protection of Personal Information Act, 4 of 2013 (“POPIA”).

1. Introduction

This PAIA Manual applies to EMWIN Systems (Pty) Ltd, trading as EJM Construction Software.

The purpose of this Manual is to assist members of the public in requesting access to records held by EMWIN Systems (Pty) Ltd and to explain how personal information is processed in accordance with POPIA.

PAIA gives effect to the constitutional right of access to information where that information is required for the exercise or protection of rights, subject to lawful grounds for refusal.

2. Company Details

Name: EMWIN Systems (Pty) Ltd
Registration number: 1982/009370/07
Trading name: EJM Construction Software
Physical address: 6 Thistle Road, Forum Building, 1st Floor, Kempton Park, Gauteng, 1631
Website: www.ejm.co.za
Email: info@ejm.co.za
Telephone: 011 396 1809 / 011 396 3561

Information Officer: Ms Lana Marais
Deputy Information Officer: Mrs Alida Potgieter

3. The Information Regulator’s PAIA Guide

The Information Regulator has published a guide to help people understand how to use PAIA and POPIA.

The guide is available from the Information Regulator:

Website: www.inforegulator.org.za
General enquiries: enquiries@inforegulator.org.za
Telephone: 010 023 5200
Toll free: 0800 017 160
Address: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191

PAIA complaints may be submitted to PAIAComplaints@inforegulator.org.za.

4. Records Automatically Available

The following information is automatically available on our website without a formal PAIA request:

• Company and product information
• Website pages describing EJM modules and services
• Contact information
• Pricing information published on the website
• Newsboard posts and public updates
• Privacy Policy
• Cookie Policy
• PAIA Manual

5. Records That May Be Requested

EMWIN Systems (Pty) Ltd may hold records in the following categories:

Company Records

• Company registration documents
• Statutory records
• Governance and administrative records
• Policies and procedures

Financial Records

• Accounting records
• Tax records
• Invoices and statements
• Supplier and customer payment records

Customer and Sales Records

• Customer contact details
• Enquiry records
• Demo and callback requests
• Brochure download requests
• Pricing estimate requests
• Customer support and service records
• Contracts, proposals, and correspondence

Marketing and Website Records

• Website form submissions
• Newsletter sign-up records
• Marketing consent records
• Website analytics records
• Product and marketing materials

Human Resources Records

• Employee records
• Payroll records
• Employment contracts
• Training and disciplinary records
• Statutory employment records

Operational and Technical Records

• Software, product, and service records
• Internal operational documents
• Vendor and service provider records
• Security and access records

Access to records is subject to PAIA and may be refused where lawful grounds for refusal apply.

6. Records Available Under Other Legislation

Where applicable, EMWIN Systems (Pty) Ltd may keep records under legislation such as:

• Companies Act
• Income Tax Act
• Value-Added Tax Act
• Labour Relations Act
• Basic Conditions of Employment Act
• Employment Equity Act
• Unemployment Insurance Act
• Compensation for Occupational Injuries and Diseases Act
• Skills Development Act
• Electronic Communications and Transactions Act
• Protection of Personal Information Act
• Promotion of Access to Information Act

7. How to Request Access to Records

A request for access to records must be submitted to the Information Officer using the prescribed PAIA request form, where applicable.

Requests should be sent to:

Information Officer
EMWIN Systems (Pty) Ltd
Email: info@ejm.co.za
Address: 6 Thistle Road, Forum Building, 1st Floor, Kempton Park, Gauteng, 1631

Your request should include:

• Your full name and contact details
• A clear description of the record requested
• The right you wish to exercise or protect
• Why the record is required for that right
• Your preferred form of access
• Proof of authority, if requesting on behalf of another person

Fees may apply as permitted by PAIA. We will inform you of any applicable fees before providing access.

8. Decision on Request

We will consider each request in accordance with PAIA.

Access may be granted, partially granted, or refused. If refused, we will provide reasons where required by law.

Access may be refused for reasons including:

• Protection of another person’s privacy
• Commercial confidentiality
• Legal privilege
• Safety or security concerns
• Records that cannot be found or do not exist
• Requests that are frivolous, vexatious, or unreasonable
• Any other lawful ground of refusal under PAIA

9. POPIA: Personal Information Processing

EMWIN Systems (Pty) Ltd processes personal information for lawful business purposes, including:

• Responding to enquiries
• Providing product information, demos, brochures, and pricing estimates
• Managing customer relationships
• Providing software, support, and services
• Managing suppliers and service providers
• Processing employee and payroll information
• Sending marketing communications where permitted
• Improving website performance and user experience
• Meeting legal, accounting, tax, and regulatory obligations
• Protecting our business, systems, and users

10. Categories of Data Subjects

We may process personal information relating to:

• Website visitors
• Prospective customers
• Customers and customer representatives
• Suppliers and service providers
• Employees, contractors, and job applicants
• Business partners
• Professional advisers
• Regulators and public bodies, where applicable

11. Categories of Personal Information

We may process:

• Names and contact details
• Company and role information
• Enquiry, demo, brochure, and pricing request details
• Marketing preferences and consent records
• Customer account and support information
• Contract and billing information
• Employment and payroll information
• Technical and website usage information
• Correspondence and communication records

12. Recipients of Personal Information

Personal information may be shared with:

• Internal sales, support, administration, finance, and management personnel
• Website, hosting, analytics, and security providers
• Technical service providers and digital partners
• Payment, accounting, legal, tax, and professional advisers
• Regulators, public authorities, or law enforcement where required by law

13. Cross-Border Transfers

Some service providers may process or store information outside South Africa. Where this happens, we take reasonable steps to ensure that the transfer is lawful under POPIA and that appropriate safeguards are in place.

14. Security Safeguards

We take reasonable measures to protect personal information, including:

• Access controls
• Secure hosting and encrypted connections
• Restricted administrative access
• Internal confidentiality controls
• Monitoring and technical safeguards
• Reasonable vendor oversight

15. POPIA Rights

Data subjects may request:

• Access to personal information
• Correction or deletion of personal information
• Objection to processing
• Withdrawal of consent, where applicable
• Confirmation of whether we hold personal information
• Information about third parties who have received personal information, where applicable

Requests may be sent to info@ejm.co.za.

16. Complaints

If you are not satisfied with our response to a PAIA or POPIA request, you may contact the Information Regulator.

Information Regulator (South Africa)
Website: www.inforegulator.org.za
General enquiries: enquiries@inforegulator.org.za
POPIA complaints: POPIAComplaints@inforegulator.org.za
PAIA complaints: PAIAComplaints@inforegulator.org.za
Telephone: 010 023 5200
Toll free: 0800 017 160

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