PAIA Manual

PAIA Manual

Prepared in terms of Section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA)

Last updated: 26 August 2026

1. Introduction

This manual is published by Secret Elements Media (Pty) Ltd, trading as BettingGuru SA, registered in South Africa under Registration No. 2026/664470/07 (referred to as “we,” “us” or “the Company”).

The Promotion of Access to Information Act (PAIA) gives effect to the constitutional right of access to information held by public and private bodies. This manual explains how a person may request access to records held by the Company.

2. Contact Details

Company Name Secret Elements Media (Pty) Ltd
Trading Name BettingGuru SA
Registration Number 2026/664470/07
Physical Address 138 Briza Road, Cape Town, 7441, South Africa
Website https://bettingguru.co.za
Email info@bettingguru.co.za
Information Officer The Director, Secret Elements Media (Pty) Ltd, contactable at info@bettingguru.co.za

3. Guide on How to Use PAIA

The South African Human Rights Commission has published a guide on how to use PAIA, as required by Section 10 of the Act. This guide is available from the South African Human Rights Commission, or from the Information Regulator.

4. Records Available Without a PAIA Request

Certain information is already publicly available on our website without the need to submit a formal PAIA request, including:

  • Our Privacy Policy
  • Our Disclaimer and Affiliate Disclosure
  • Our Responsible Gambling information
  • General company and contact information
  • Published articles, reviews and guides

5. Records Held by the Company

Subject to the grounds for refusal set out in PAIA, the categories of records that may be held by the Company include:

  • Company registration and statutory records, including CIPC and SARS registration documents
  • Website content, including articles, reviews and editorial records
  • Correspondence with users submitted through contact forms or email
  • Records relating to affiliate partnerships and commercial agreements
  • Website analytics and usage data
  • Financial and accounting records
  • Records relating to the processing of personal information under POPIA

Inclusion of a category of record in this manual does not guarantee that access will be granted. Requests are considered in accordance with the grounds for refusal set out in PAIA.

6. Records Available in Terms of Other Legislation

Certain records may also be available under other legislation, including the Companies Act 71 of 2008 and the Protection of Personal Information Act 4 of 2013 (POPIA).

7. How to Request Access to a Record

A person wishing to request access to a record held by the Company must complete the prescribed request form (Form 2, in terms of the PAIA Regulations) and submit it to the Information Officer using the contact details in Section 2.

A request must provide sufficient detail to enable the record to be identified, along with the requester’s contact details and, where applicable, proof of identity.

Prescribed fees may apply in accordance with PAIA and its regulations. Fee amounts are determined by the applicable government gazette in force at the time of the request.

8. Grounds for Refusal

Access to a record may be refused on the grounds set out in PAIA, which include, among others, protection of privacy, protection of commercially sensitive information, protection of legal privilege and protection of records relating to law enforcement or ongoing negotiations.

9. Processing of Personal Information

The Company processes personal information in accordance with POPIA. Full details of how personal information is collected, used and protected are set out in our Privacy Policy.

The Company is registered with the Information Regulator of South Africa, and our Information Officer’s contact details are set out in Section 2 of this manual.

10. Availability of This Manual

This manual is available on our website at https://bettingguru.co.za/paia-manual/. A copy may also be requested from the Information Officer using the contact details in Section 2.

11. Changes to This Manual

We may update this manual from time to time to reflect changes in our operations, contact details or legal obligations. The most recent version will always be published on this page.