1. Introduction

1.1. SMS2Bet services is an online sports betting and gaming company that offers betting and gambling products to the South African market. We have partnered with leading wagering software providers, feed providers, trading providers to offer our players a first-class gaming experience.

2. PAIA and POPIA

2.1. The Promotion of Access to Information Act 2 of 2000 (“PAIA”) grants a requester access to records of a private body, if the record is required for the exercise or protection of any rights. If a public body lodges a request, the public body must be acting in the public interest.

2.2. The Protection of Personal Information Act 4 of 2013 (“POPIA”) gives effect to the constitutional right to privacy. One of the data processing principles under POPIA is that of data subject participation, which allows for data subjects to access and correct their personal information held by a responsible party. This manual provides for data subject to request this information from the Company.

3. Requests for Information

3.1. Requests in terms of PAIA must be made in accordance with the prescribed procedures, at the prescribed rates provided. The forms and tariff are dealt with in Regulations 6 and 7 promulgated in terms of PAIA.

3.2. Proof of payment of the said prescribed fee must accompany the completed application form.

4. The Guide

4.1. Requesters are referred to the Guide in terms of Section 10 which has been compiled by the South African Human Rights Commission (“SAHRC”) and will be updated and made availableby it until 30 June 2021, whereafter it will be updated and made available by the Information Regulator. The Guide contains information for the purposes of exercising Constitutional Rights and is available in all of the official languages.

4.2. The contact details of the Information Regulator are: Postal Address P.O. Box 31533, Braamfontein, Johannesburg, 2017 Email Address inforeg@justice.gov.za Website https://www.justice.gov.za/inforeg/

1. Latest notice in terms of Section 52(2) (if any)

1.1. At this stage no notice has been published on the categories of records that are automatically available without a person having to request access in terms of PAIA.

5. Information Available in terms of any other Legislation

Information is held and maintained by the Company in compliance with the following legislation:

  • Arbitration Act No. 42 of 1965
  • Basic Conditions of Employment No. 75 of1997
  • Broad Based Black Economic Empowerment Act No. 53 of 2003
  • Companies Act No. 71 of 2008
  • Compensation for Occupational Injuries and Health Diseases Act No.130 of 1993
  • Consumer Protection Act No. 68 of 2008
  • Copyright Act No. 98 of 1978
  • Currency and Exchanges Act No. 9 of 1933
  • Debt Collectors Act No. 114 of 1998
  • Electronic Communications Act No. 36 of 2005
  • Electronic Communications and Transactions Act No. 25 of 2002
  • Employment Equity Act No. 55 of 1998
  • Finance Act No. 35 of 2000
  • Financial Intelligence Centre Act No. 38 of 2001
  • Income Tax Act No. 95 of 1967
  • Insolvency Act No. 24 of 1936 Page 3 of 12
  • Insurance Act No 27 of 1943
  • Intellectual Property Laws Amendments Act No. 38 of 1997
  • Labour Relations Act No. 66 of 1995
  • Long Term Insurance Act No. 52 of 1998
  • Medical Schemes Act No. 131 of 1998
  • National Credit Act No. 34 of 2005
  • National Gambling Act No. 7 of 2004
  • Occupational Health & Safety Act No. 85 of 1993
  • Patents Act No. 57 of 1978
  • Pension Funds Act No. 24 of 1956
  • Prescription Act No. 68 of 1969
  • Prevention and Combating of Corrupt Activities Act No. 12 of 2004
  • Prevention of Organized Crime Act No. 121 of 1998
  • Protection of Personal Information Act No. 4 of 2013
  • SA Reserve Bank Act No. 90 of 1989
  • Short Term Insurance Act No. 53 of 1998
  • Skills Development Act No. 97 of 1998
  • Skills Development Levies Act No. 9 of 1999
  • Trademarks Act No. 194 of 1993
  • Unemployment Contribution Act No. 4 of 2002
  • Unemployment Insurance Act No. 30 of 1996
  • Value Added Tax Act 89 of 1991

6. Schedule of Records of the Company

The records held by the Company, both those that can be accessed without an application in terms of PAIA and otherwise, are listed in Schedule 1.

7. Schedule of Personal Information Processed by the Company

7.1. Schedule of Personal Information. The personal information processed by the Company in terms of POPIA is set out in Schedule 2.

7.2. Planned and actual transborder flows of personal information. The Company may use hosting or cloud services to store and process personal information that are not located in the RSA. If it does so, it will ensure that the level of protection given to the personal information is at least as good as that provided for under RSA Law, either by means of a binding contract with the service provider, or by using a service provider located in a country with privacy laws of similar or stronger effect.

7.3. Information Security Measures. The Company employs appropriate, reasonable technical and organisational measures to secure the integrity and confidentiality of personal information in its possession or under its control, which include the following: 1.1.1. Identifying reasonably foreseeable internal and external risks to personal and other information in its possession or under its control; 1.1.2. Establishing and maintaining appropriate safeguards against the risks identified; 1.1.3. Regularly verifying that the safeguards are effectively implemented; Page 4 of 12 1.1.4. Ensuring that the safeguards are continually updated in response to new risks or deficiencies in previously implemented safeguards;

2. Other Prescribed Information

2.1. At the time of the compilation of this manual, no further information has been prescribed.

3. Availability of Manual

3.1. This manual is available free of charge for inspection at the above-mentioned address; and at the South African Human Rights Commission.

3.2. Copies of the manual may be obtained, subject to the prescribed fees.

3.3. The manual may also be accessed on the Company’s website or alternatively a copy is available upon request directly from the SAHRC.

4. Reservation of Rights

4.1. Nothing in this manual is to be construed as a waiver of the right to the confidentiality of any document or any legal privilege or right of non-disclosure attaching to any document mentioned herein, whether in terms of any statute or under the common law. All rights in this regard are fully reserved.
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