PAIA Manual

Manual prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 ("PAIA")

Version 1.0 Effective date: effective date — to be confirmed Next review: one year after the effective date — to be confirmed

1. Purpose of this manual

PAIA gives everyone a right of access to information held by public and private bodies where that information is needed to exercise or protect a right. This manual explains what records we hold and how to ask for them.

It also serves as our manual under section 51 of the Protection of Personal Information Act 4 of 2013, insofar as that Act requires one.

2. Details of the private body

Information Officer

Requests for access to records must be addressed to the Information Officer.

3. The PAIA Guide

The Information Regulator has published a guide, in terms of section 10 of PAIA, on how to use the Act. It is available in all official languages, free of charge, from:

The Information Regulator (South Africa) JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001 P.O. Box 31533, Braamfontein, Johannesburg, 2017 Email: PAIAComplaints.IR@justice.gov.za Website: https://inforegulator.org.za

4. Records available without a formal request

The following are published and may be obtained without a PAIA request:

• The HuntBook SA Terms of Service
• The HuntBook SA Privacy Policy
• This manual
• Farm listings and other content published on the platform
• Subscription plans and prices, as shown in the app

You can also see and correct your own personal information at any time in the app, under Profile, and download or delete your account there. You do not need a PAIA request for your own information — see section 11 of the Privacy Policy.

5. Categories of records we hold

Records are kept in electronic form, and are not all automatically available.

5.1 User and account records

• Registration details, profile information and contact details
• Authentication records, including sign-in history and two-factor status
• Hunter preferences, saved farms and location where shared
• Assistant conversations
• Reviews and hunter evaluations
• Support correspondence and diagnostics submissions

5.2 Farm and listing records

• Farm profiles, descriptions, addresses and coordinates
• Game listings, pricing, accommodation, hides, roads and map features
• Photographs and media
• Farm verification documents and the outcome of verification reviews
• Specials and promotions

5.3 Financial and billing records

• Subscription records, plan history and status
• Payment confirmations received from PayFast
• Invoices and accounting records
• Tax records

5.4 Company records

• Founding documents and CIPC filings
• Statutory registers
• Contracts with service providers
• Insurance records

5.5 Employment records, if any

• Employment contracts and personnel records
• Payroll and statutory deduction records
• Records required under the Basic Conditions of Employment Act, the Labour

Relations Act, the Employment Equity Act, the Skills Development Act, the Unemployment Insurance Act and the Compensation for Occupational Injuries and Diseases Act

5.6 Operational and technical records

• System logs, audit logs and security records
• Backups
• Source code and technical documentation

6. Legislation under which records are kept

Records are held under, among others:

• Companies Act 71 of 2008
• Consumer Protection Act 68 of 2008
• Electronic Communications and Transactions Act 25 of 2002
• Income Tax Act 58 of 1962
• Value-Added Tax Act 89 of 1991
• Protection of Personal Information Act 4 of 2013
• Promotion of Access to Information Act 2 of 2000
• Basic Conditions of Employment Act 75 of 1997
• Labour Relations Act 66 of 1995

7. How to request a record

• Complete Form 2 of the PAIA regulations (the request form for access to a

record of a private body). The current form is available from https://inforegulator.org.za.

• Send it to the Information Officer at the address in section 2.
• Give enough detail to let us find the record, and enough detail about the

right you are trying to exercise or protect to let us decide the request.

• State how you want the record delivered, and give a contact address.
• If you are asking on someone else's behalf, attach proof of your authority.

8. Fees

Two fees may apply, as prescribed in the PAIA regulations:

• A request fee, payable before we process the request.
• An access fee, covering the cost of searching for, preparing, copying and

sending the record.

We will tell you what is payable before doing the work, and we may require a deposit where preparation will take more than the prescribed number of hours.

No fee is payable for a request for your own personal information.

The prescribed amounts change from time to time. The current amounts are those published in the PAIA regulations.

9. Our decision

We will decide within 30 days of receiving a properly completed request, and tell you in writing. We may extend that by a further 30 days where the request covers a large number of records or requires a search of records held elsewhere, and we will tell you if we do.

If we grant the request, we will tell you the access fee, the form of access, and your right to appeal the fee.

If we refuse it, we will tell you why, which section we relied on, and that you may apply to court.

10. Grounds on which we must or may refuse

PAIA requires or permits refusal in certain cases, including where disclosure would:

• unreasonably disclose someone else's personal information (section 63);
• breach a duty of confidence owed to a third party (section 65);
• disclose commercial information of a third party, including trade secrets

(section 64);

• endanger someone's life or physical safety, or prejudice the security of

property (section 66);

• disclose privileged legal communications (section 67);
• disclose our own trade secrets, research or commercially sensitive information

(section 68); or

• be a request that is manifestly frivolous or vexatious (section 45).

Where part of a record may be released and part may not, we will release the part we can.

11. Remedies

There is no internal appeal against a decision of a private body.

If you are unhappy with our decision you may:

• lodge a complaint with the Information Regulator, using the prescribed

form, at PAIAComplaints.IR@justice.gov.za; or

• apply to a court with jurisdiction, within 180 days of the decision.

12. Availability of this manual

This manual is available:

• in the HuntBook SA app, under Profile;
• at https://app.huntbooksa.co.za/legal/paia-manual.html;
• from the Information Officer, on request; and
• at our physical address, for inspection during business hours.

It is available free of charge in electronic form. A printed copy may attract the prescribed fee.

13. Review

We review this manual at least once a year and whenever our records or business change materially.