1. Introduction

The Promotion of Access to Information Act 2 of 2000 (“PAIA”) gives effect to the constitutional right of access to information held by public and private bodies. Section 51 of PAIA requires the head of every private body to compile a manual that describes the records the body holds and explains how a person may request access to those records.

This Manual has been prepared by Adrian Papier t/a Eyefeast (“Eyefeast”, “we”, “us”, or “our”) in accordance with Section 51 of PAIA, as read with the Protection of Personal Information Act 4 of 2013 (POPIA).

This Manual is available on our website and on request from our Information Officer.

2. Particulars of the Private Body

3. Description of the Business

Eyefeast is an online content and experience discovery platform. We publish and curate editorial content for readers, including Experience Journals, Weekly News, Catalogue, Recipes, Monthly Books, Sport Highlights, Movies to Stream, Cinema Trailers, and Gaming.

We generate revenue through paid banner advertising, sponsored content, and affiliate links. We do not sell goods, services, or tickets directly to readers and do not process payments from readers on the website.

4. Guide on How to Use PAIA

The Information Regulator has, in terms of Section 10 of PAIA, compiled a guide on how to use the Act. The guide is available in all official South African languages and may be obtained from:

• The Information Regulator’s website: inforegulator.org.za/paia/
• The offices of the Information Regulator during normal working hours

Any person who wishes to exercise their rights under PAIA may request a copy of this guide from our Information Officer, who will provide it on request.

5. Categories of Records Held

The following categories of records are held by Eyefeast. Records marked as “available without request” are publicly accessible. All other records may be requested in terms of PAIA.

5.1 Records available without a formal PAIA request

• Terms and Conditions (published on the website)
• Privacy Policy (published on the website)
• Refund and Cancellation Policy (published on the website)
• This PAIA Manual (published on the website)
• Publicly available editorial content and marketing material

5.2 Records available on request

• Advertising and sponsorship records: contracts, booking confirmations, campaign schedules, creative briefs, and performance reports relating to advertising clients
• Financial records: invoices issued to advertising clients, payment records, bank statements, and tax records
• Correspondence: email, WhatsApp messages, and other written communications with advertisers, partners, and service providers
• Affiliate and advertising platform records: reports and correspondence received from affiliate networks and advertising platforms
• Supplier and service provider records: agreements and correspondence with hosting, analytics, and payment providers
• Compliance records: POPIA and PAIA compliance documentation, Information Officer registration records, and related correspondence

6. Records Automatically Available in Terms of Other Legislation

Certain records are available in terms of other South African legislation, and the procedures for accessing them are governed by that legislation. These include:

• Tax records, in terms of the Tax Administration Act 28 of 2011
• Records held by the Companies and Intellectual Property Commission (CIPC), where applicable

7. Purpose of Processing Personal Information

In accordance with POPIA, Eyefeast processes personal information for the following purposes:

8. Data Subject Categories and Personal Information

The following categories of data subjects are affected by our processing, and the personal information we hold about them includes:

9. Planned Recipients of Personal Information

We share personal information only with service providers who help us operate the website and our business, and only to the extent necessary. These include:

We may also disclose personal information where we are required to do so by law, court order, or a lawful request from a regulator or authority, or where it is necessary to protect our rights or the safety of others.

10. Planned Cross-Border Flows of Personal Information

Some of our service providers are located outside South Africa or store data outside South Africa. Personal information may therefore be transferred to, and processed in, the following jurisdictions:

• South Africa: Xneelo, PayFast
• United States and other jurisdictions: Google (Analytics, Ads, YouTube), Meta, Zoho, Impact, Partnerize, Fever, and other affiliate and advertising partners

In terms of Section 72 of POPIA, we may transfer personal information outside South Africa only where the recipient is subject to laws or binding rules that provide a comparable level of protection, or where the data subject has consented to the transfer. We take reasonable steps to ensure that our service providers offer adequate protection through their terms of service and data processing arrangements.

11. Security Measures to Protect Personal Information

We take reasonable technical and organisational measures to protect personal information against loss, damage, unauthorised access, and misuse. These measures include:

• HTTPS and SSL encryption on the website
• Strong passwords and secure access controls on administrative accounts
• Regular updates to WordPress, themes, and plugins
• Restricted access, so that only authorised persons can access client information
• Use of a reputable secure email provider

No method of transmission or storage is completely secure. While we take reasonable precautions, we cannot guarantee absolute security. If we become aware of a data breach that may affect a data subject, we will notify the affected persons and the Information Regulator as required by POPIA.

12. How to Request Access to Records

A person who wishes to request access to a record held by Eyefeast must submit a request using the prescribed form, Form 2 (InfoRegSA-PAIA-Form02-Reg7), which is available from the Information Regulator’s website at inforegulator.org.za/paia-forms/, or from our Information Officer.

The request must be submitted to our Information Officer using the contact details in Section 2 of this Manual, and must include:

• The requester’s full name, identity number, and contact details
• Sufficient particulars to enable us to identify the record requested
• The form of access requested (for example, a copy or inspection)
• If the request is made on behalf of another person, proof of the authority to act on that person’s behalf
• The requester’s signature

We will respond to the request within 30 days of receipt, as required by PAIA, unless an extension is lawfully permitted. If the request is refused, we will provide written reasons for the refusal and explain the requester’s right to lodge an appeal or complaint with the Information Regulator.

13. Fees

The fees payable for access to records are prescribed by PAIA and are set out in the Regulations. Fees may include a request fee, an access fee, and a fee for copying or preparing records. Where a fee is payable, we will provide the requester with a written estimate before processing the request.

A requester who is exempt from paying access fees in terms of PAIA must provide proof of exemption with the request.

14. Grounds for Refusal of Access

Access to a record may be refused on the grounds set out in Chapter 4 of Part 3 of PAIA. These grounds include, among others:

• Mandatory protection of the privacy of a third party who is a natural person
• Mandatory protection of commercial information of a third party
• Mandatory protection of certain confidential information of a third party
• Mandatory protection of the safety of individuals and protection of property
• Mandatory protection of records privileged from production in legal proceedings
• Commercial information of the private body
• Mandatory protection of research information
• Mandatory disclosure in the public interest (where applicable)

Where access is refused, the requester will be notified in writing of the refusal and the grounds for it, and will be informed of the right to lodge a complaint with the Information Regulator or to apply to a court for relief.

15. Remedies Available to Requesters

If a requester is dissatisfied with our decision on a request, they may:

• Lodge a complaint with the Information Regulator
• Apply to a court for appropriate relief

Details of how to lodge a complaint with the Information Regulator are available on the Regulator’s website at inforegulator.org.za.

16. Availability of This Manual

This Manual is available:

• On our website at www.eyefeast.co.za
• On request from our Information Officer, by email or telephone
• For inspection at our business address during normal working hours, by prior arrangement

This Manual is published free of charge. A reasonable fee may be charged for a printed copy to cover reproduction and delivery costs.

17. Contact Details

For any queries, requests, or complaints relating to PAIA or this Manual, please contact our Information Officer:

18. Amendments to This Manual

We may amend this Manual from time to time to reflect changes in our business, records, or legal obligations. The updated version will be published on our website with a revised “Last updated” date.