PAIA Manual

Published in terms of section 51 of the Promotion of Access to Information Act, 2000. Effective 26 August 2026. Issued by our legal advisers and published here because the Act requires this manual to be publicly available.

PAIA SECTION 51 MANUAL

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

Fit4 Padel (Pty) Ltd (Trading as F4 Padel)

Effective Date: 26 August 2026

1. INTRODUCTION

This PAIA Manual is published in accordance with Section 51 of the Promotion of Access to Information Act, 2000 (PAIA). It provides guidance on how to request access to records held by Fit4 Padel (Pty) Ltd, trading as F4 Padel, a sports-technology company that develops and operates Padel Vista, a mobile application providing padel analytics, AI-powered performance insights, and video-based analysis through features including RallyStat, StatMe, Pongel, and MoveMe.

This Manual explains:

• What information the company holds
• How to request access to records
• How personal information is processed and protected
• Contact details of the Information Officer

2. CONTACT DETAILS

Information Officer

Email: admin@f4padel.co.za

This email address serves as the single point of contact for all PAIA and POPIA matters.

3. GUIDE ON HOW TO USE PAIA

A guide on how to use PAIA is available from the Information Regulator. It explains how to request information and exercise your rights under PAIA.

Information Regulator Contact Details:

Website: https://www.inforegulator.org.za

Email: PAIAComplaints@inforegulator.org.za / POPIAComplaints@inforegulator.org.za

4. RECORDS AVAILABLE IN TERMS OF OTHER LEGISLATION

Fit4 Padel (Pty) Ltd may hold records required under the following legislation, including but not limited to:

• Companies Act 71 of 2008
• Income Tax Act 58 of 1962
• VAT Act 89 of 1991
• Basic Conditions of Employment Act 75 of 1997
• Labour Relations Act 66 of 1995
• POPIA (Protection of Personal Information Act 4 of 2013)
• Electronic Communications and Transactions Act 25 of 2002

5. ACCESS TO RECORDS HELD BY FIT4 PADEL (PTY) LTD

Records may be requested in terms of PAIA. Access will be granted only if:

• The requester complies with PAIA requirements
• The record is not subject to refusal grounds
• The requester has the right to access the information

Categories of Records Held

5.1 Internal Records

• Company registration documents
• Policies and procedures
• PAIA and POPIA compliance documentation
• Internal correspondence

5.2 Personnel Records

• Employee contracts
• Payroll and HR records
• Training and performance records

5.3 Client / User Records

• User account information (email, display name, Google identifier)
• Consent records (terms acceptance, and POPIA s69 direct-marketing consent where given)
• Analytics and performance data uploaded by users
• AI-generated analysis results (shot counts, technique scores, summaries)
• Communication records

5.4 Financial Records

• Invoices and statements
• Tax records
• Financial reports

5.5 Technology & Platform Records

• Software development documentation
• System architecture and security protocols
• Data processing logs
• Operator agreements
• Technical logs generated by Cloudflare

6. RECORDS AUTOMATICALLY AVAILABLE

The following records are automatically available and do not require a PAIA request:

• Public website content
• Published policies (Privacy Policy, Terms of Use)
• Marketing material
• App information and feature descriptions

7. REQUEST PROCEDURE

Requests for access to records must be made using Form 2 (Request for Access to Record of Private Body) as prescribed by the Information Regulator.

Submission of Requests

Requests may be submitted to:

Email: admin@f4padel.co.za

Fees

Request and reproduction fees may apply as prescribed by PAIA regulations.

Decision Process

The Information Officer will:

• Acknowledge receipt of the request
• Evaluate the request against PAIA requirements
• Notify the requester of approval or refusal
• Provide access if approved

8. GROUNDS FOR REFUSAL

Access may be refused if the record:

• Contains personal information of a third party
• Contains confidential commercial information
• Would prejudice the company’s commercial interests
• Is privileged (legal privilege)
• Would endanger life or physical safety
• Is prohibited from disclosure by law

9. POPIA COMPLIANCE

Fit4 Padel processes personal information in accordance with POPIA. Key principles include:

• Lawful processing
• Purpose specification
• Information quality
• Security safeguards
• Data subject participation

Data Subject Rights

Data subjects may request:

• Access to their personal information
• Correction or deletion of personal information
• Withdrawal of consent (including s69 direct marketing consent)

Requests must be directed to admin@f4padel.co.za.

10. AVAILABILITY OF THE MANUAL

This Manual is available:

• On the company website
• In electronic format upon request
• At the company’s registered office

11. UPDATES TO THIS MANUAL

This Manual will be updated as required to comply with legislative changes or operational updates.

Approved by:

Information Officer: Fit4 Padel (Pty) Ltd

Date: 26 August 2026