PAIA & POPIA Manual

This is the manual of DenRev (Pty) Ltd, trading as Flamin Fairways, under section 51 of the Promotion of Access to Information Act, 2000 ("PAIA"), including the information required by the Protection of Personal Information Act, 2013 ("POPIA"). It explains what records we keep and how to ask for them.

Private body

DenRev (Pty) Ltd t/a Flamin Fairways

Registration no.

2023/005910/07

Head of the body and Information Officer

Tyron Denton

Postal and street address

7 Tomahawk Street, Pierre van Ryneveld, Centurion, 0157, South Africa

Phone

Added before launch

Email

flaminfairways@gmail.com

Website

https://flaminfairways.co.za

The Information Regulator has published a Guide on how to use PAIA and POPIA, in each official language. You can get it from the Information Regulator's website or its offices, and we'll email you a copy on request.

Everything published on this website, including all our policies, is freely available without a PAIA request. We have not published a notice under section 52 of PAIA.

• Companies Act, 2008: company registration documents, Memorandum of Incorporation, register of directors, financial records.
• Tax Administration Act, 2011 and Income Tax Act, 1962: tax records and returns.
• Value-Added Tax Act, 1991: VAT records, once we're registered.
• Electronic Communications and Transactions Act, 2002 and Consumer Protection Act, 2008: transaction records, terms and refund records.
• Protection of Personal Information Act, 2013: consent records, data requests and security incident records.

• Company: registration documents, statutory registers, minutes and resolutions.
• Finance and tax: accounting records, bank statements, invoices, receipts, tax records.
• Members: accounts, golf details, scores, tournament records, posts, consents, payments, reviews and appeals.
• Promoters: applications, agreements, payout records and bank details.
• Suppliers and sponsors: agreements, correspondence and invoices.
• Operations: course database, policies, security and incident records, website and app content.

Purposes: running the FFGL and our website, taking payments, paying promoters, keeping the league fair and safe, answering enquiries, sending marketing to people who opted in, and meeting our legal duties.

People we hold information about, and what:

• Members: contact and account, sign-up details, golf details, your golf activity, what you post, location, rewards, payments, consent records.
• Promoters: identity, contact, tax and bank details, payout records.
• People who contact us and sponsors: name, contact details and messages.
• Website visitors: IP address and technical logs.
• Suppliers: business contact and payment details.

Who receives it: Supabase, Lovable, Google, Xneelo, Yoco, Xero, our accountant and auditors, and authorities where the law requires.

Transfers outside South Africa: We only use providers that are bound by laws, binding corporate rules or written agreements giving protection substantially similar to POPIA (POPIA s72(1)(a)), or where the transfer is needed to perform our agreement with you (s72(1)(c)). Our member database is in the European Union, which is covered by the GDPR.

Security: two-step login on every admin account, server-enforced access rules, encryption in transit and at rest with our database provider, card details handled only by our payment provider, least-privilege access and an admin audit log. Full detail is in our Privacy Policy.

1. Fill in the prescribed request form (Form 2 under the PAIA Regulations), available from the Information Regulator's website or from us, and email it to flaminfairways@gmail.com.
2. Give enough detail to identify the record, the form of access you want, and, if you're asking for someone else's records, the right you want to exercise or protect.
3. Fees are set by the PAIA Regulations. There's no request fee for your own personal information. We'll tell you about any access fee before we start.
4. We decide within 30 days. We may extend this once, by up to 30 days, if the law allows, and we'll tell you why.
5. We may refuse access only on the grounds in Chapter 4 of Part 3 of PAIA, for example to protect someone else's privacy or confidential commercial information. We'll give reasons.

You can complain to the Information Regulator (South Africa) within 180 days, or apply to court.

This manual is on our website and available at our registered office during business hours. We'll email a copy free on request. We review it at least once a year and whenever our processing changes.