PAIA Manual

This manual is prepared in accordance with section 51 of the Promotion of Access to Information Act, 2 of 2000 ("PAIA") and is designed to provide a reference to the records held by IKA MEDIA GROUP (PTY) LTD and the process to request access to such records.

IKA MEDIA GROUP (PTY) LTD ("Ika", "we", "us", "our") is a private company registered in the Republic of South Africa. We provide a service that enables writers ("Creators") to publish newsletters and other content ("Posts") and allows users ("Readers") to subscribe to these Posts.

This manual is integral to our commitment to transparency and compliance with South African law, including the Protection of Personal Information Act 4 of 2013 ("POPIA"). Our legally binding Terms of Service, Privacy Policy, and Content Guidelines are incorporated by reference into this manual.

All requests for access to records under PAIA must be directed to our designated Information Officer:

PAIA grants a requester access to records of a private body, if the record is required for the exercise or protection of any rights. A guide on how to use PAIA has been compiled by the South African Information Regulator in terms of Section 10 of PAIA.

The guide contains information on:

• The objects of PAIA and POPIA.
• The contact details of the Information Regulator.
• The process for submitting a request for access to a record.
• The remedies available in respect of a private body that fails to comply with PAIA.

For more information, please contact the Information Regulator:

• Website: https://inforegulator.org.za/
• Email: complaints.IR@justice.gov.za

The following records are automatically available on the Ika website and do not require a formal PAIA request:

• Terms of Service
• Privacy Policy
• Content Guidelines
• Refund Policy
• Any other marketing and promotional material made publicly available.

Ika is committed to the protection of personal information in line with POPIA. Our Privacy Policy provides a detailed account of our data processing activities.

5.1 Purpose of Processing and Lawful Basis

We only process Personal Information when we have a lawful basis under POPIA to do so. This includes:

• To Perform Our Contract: To provide core services like maintaining accounts, facilitating subscriptions, and processing payouts.
• For our Legitimate Interests: For security, platform improvement, and to enforce our Terms of Service.
• With Your Consent: For specific purposes like sending marketing communications.
• To Comply with a Legal Obligation: For duties such as "Know Your Customer" (KYC) requirements.

5.2 Categories of Data Subjects and Information Processed

• Creators: Name, email address, password, payout and identity verification information (bank details, ID docs), content of Posts, communications, and usage data.
• Readers: Name, email address, password, communications, and usage data.

For POPIA purposes, Ika is the "Responsible Party" for user account data, while the Creator is the "Responsible Party" for their subscriber lists, and Ika acts as their "Operator".

5.3 Recipients of Personal Information

We do not sell personal information. We share it only with:

• Readers and Creators: A Reader's email and name are shared with the Creator they subscribe to.
• Our Payment Processor (Paystack): For processing payments and payouts.
• Service Providers ("Operators"): For services like cloud hosting, under strict data protection agreements.
• For Legal Reasons: If required by law or a valid court order.

5.4 Trans-border Information Flows

We may use service providers outside South Africa. When we transfer Personal Information internationally, we will do so in full compliance with POPIA to ensure it is protected.

5.5 General Description of Information Security Measures

We have implemented appropriate and reasonable technical and organizational measures to protect your Personal Information. Our payment processing is handled by Paystack, a PCI-DSS Level 1 certified provider.

We hold the following categories of records:

1. Form of Request: A request for access to a record must be made using the prescribed Form 2. This form is available from the Information Regulator's website.
2. Submission: The completed form must be submitted to the Information Officer at the email address provided in Section 2 of this manual.
3. Proof of Identity: The requester must provide sufficient proof of their identity. If a request is made on behalf of another person, proof of the capacity in which the requester is making the request must be provided.
4. Payment of Fees: The applicable prescribed request fee must be paid before the request is processed.
5. Processing: The Information Officer will process the request and notify the requester of the decision and any applicable access fees.

Access to a record may be refused on grounds stipulated in PAIA, which include, but are not limited to:

• Mandatory protection of the privacy of a third party who is a natural person.
• Mandatory protection of the commercial information of a third party.
• Mandatory protection of certain confidential information of a third party.
• Mandatory protection of the safety of individuals and the protection of property.
• Mandatory protection of records privileged from production in legal proceedings.
• The commercial information of Ika.

There are two types of fees required to be paid in terms of PAIA:

Request Fee: A non-refundable request fee is payable by the requester, other than a personal requester, before the request is processed.

Access Fee: If the request for access is granted, the requester will be required to pay an access fee for the search, preparation, and reproduction of the records.

The full schedule of fees is available in the PAIA Regulations published by the government.

If you are unsuccessful with your request for access, you have the right to:

• Lodge an internal appeal against the decision of the Information Officer (if an internal appeal procedure is available).
• Lodge a complaint with the Information Regulator of South Africa. The complaint must be submitted on the prescribed form to the Information Regulator at: complaints.IR@justice.gov.za.
• Apply to a court with appropriate jurisdiction for relief after you have exhausted the internal appeal procedure or the complaint procedure with the Information Regulator.

This manual is available for inspection at no cost at the offices of IKA MEDIA GROUP (PTY) LTD (by appointment) and can be viewed on our website.