PAIA Manual

Manual prepared in terms of section 51 of the Promotion of Access to Information Act, 2 of 2000.

1. Introduction

This Manual is prepared in accordance with section 51 of the Promotion of Access to Information Act, 2000 ("PAIA"). The Manual is intended to assist requesters in identifying the records held by Drummond Holdings (Pty) Ltd ("the Company") and the procedure for requesting access to those records.

The Company conducts business under the trading name "Couch Cup," which operates skill-based competitive video gaming tournaments.

2. Particulars of the Company

• Registered name: Drummond Holdings (Pty) Ltd
• Trading name: Couch Cup
• Company registration number: 2026/209853/07
• Type of entity: Private company
• Physical address: Cape Town, Western Cape, South Africa
• Email: hello@couchcup.co.za
• Website: couchcup.co.za

3. Information Officer

The Information Officer of the Company is:

• Name: Hugo Drummond
• Position: Sole Director, Drummond Holdings (Pty) Ltd
• Email: privacy@couchcup.co.za

The Information Officer is registered with the Information Regulator of South Africa under POPIA. No Deputy Information Officer has been appointed at the date of this Manual.

4. Guide on how to use PAIA

The Information Regulator has published a Guide in terms of section 10 of PAIA. Available from the Information Regulator at:

• Website: inforegulator.org.za
• General enquiries: enquiries@inforegulator.org.za
• PAIA complaints: PAIAComplaints@inforegulator.org.za
• POPIA complaints: POPIAComplaints@inforegulator.org.za
• Telephone: +27 (10) 023 5200

5. Records available without a request

The following categories of records are made available without requiring a formal PAIA request, accessible on the Company's website at couchcup.co.za:

• The Couch Cup Terms and Conditions and Privacy Policy.
• Promotional Competition Rules for current and recent Tournaments.
• Information about current and upcoming Tournaments.
• The list of current third-party service providers at couchcup.co.za/providers.
• This PAIA Manual.

6. Records held by the Company

6.1 Records about the Company

• Company registration documents (CIPC).
• Memorandum of Incorporation.
• Tax records and SARS correspondence.
• Banking records.
• Insurance policies.
• Internal governance records.

6.2 Records about Tournaments

• Tournament rules and Game-Specific Addenda.
• Promotional Competition Rules and supporting CPA section 36 records.
• Bracket records and match scheduling records.
• Match results, screenshots, and stream URLs submitted as proof.
• Dispute records and adjudication decisions.
• Prize payment records.
• Records of cancellations, extensions, or modifications.

6.3 Records about Participants

• Signup records (name, email, mobile number, PSN ID, country, date of birth).
• Marketing consent records.
• Communications with Participants (email correspondence and transactional records).
• Records of disqualifications and bans.

6.4 Records about service providers

• Contracts with service providers (hosting, database, email, community, payments).
• Data Processing Agreements in terms of section 21 of POPIA.
• Correspondence relating to security incidents or breaches.

6.5 Records held in terms of other legislation

• Companies Act, 71 of 2008 — corporate governance records, annual returns, directors' records.
• Tax Administration Act, 28 of 2011 — tax records and supporting documentation.
• Consumer Protection Act, 68 of 2008 — promotional competition records, consumer complaints.
• Protection of Personal Information Act, 4 of 2013 — records of processing activities, consent records, security compromise records.

7. How to request access to a record

A request for access must be made on Form 2 (available from the Information Regulator's website or on request from the Information Officer). The completed form must be submitted to the Information Officer at privacy@couchcup.co.za, accompanied by proof of identity and sufficient particulars to identify the record.

The Information Officer will respond within 30 days of receipt, in accordance with section 56 of PAIA. The 30-day period may be extended once by a further 30 days where the request relates to a large number of records.

8. Fees

The fees payable are set out in the Regulations to PAIA. A personal requester (requesting records about themselves) is not required to pay a request fee but may be charged an access fee for the actual cost of producing the records. The Information Officer will provide a fee estimate before processing any request.

9. Grounds for refusal of access

Access may be refused on grounds set out in Chapter 4 of Part 3 of PAIA, including mandatory protection of privacy of a third party, mandatory protection of commercial information, protection of safety of individuals, or commercial information of the Company. Where a request is refused, the requester will be notified in writing of the refusal and available remedies.

10. Remedies if access is refused

• Lodge a complaint with the Information Regulator at PAIAComplaints@inforegulator.org.za.
• Apply to a court of competent jurisdiction in accordance with section 78 of PAIA.

11. POPIA — rights of data subjects

A data subject has the rights set out in POPIA, including the right of access (section 23), the right to correction (section 24), the right to object to processing, and the right to lodge a complaint with the Information Regulator at POPIAComplaints@inforegulator.org.za.

Requests to exercise rights under POPIA should be addressed to the Information Officer at privacy@couchcup.co.za.

12. Amendment of this Manual

This Manual will be updated as required to reflect changes in the Company's operations or applicable law. The current version is available on the Couch Cup website at couchcup.co.za.