01About this manual
This manual is published under section 51 of the Promotion of Access to Information Act, 2000 (PAIA). It tells you what records TeeTimes holds and how to ask for access to them. It also contains the information section 51(1)(c) of PAIA requires about how we process personal information under POPIA.
to be confirmed (registration number to be confirmed) is a private body that operates the TeeTimes golf booking platform at teetimes.co.za.
02Contact details
| Details | |
|---|---|
| Head of the private body | to be confirmed, to be confirmed |
| Information Officer | to be confirmed |
| Deputy Information Officer | to be confirmed |
| Email for requests | privacy@teetimes.co.za |
| Telephone | to be confirmed |
| Physical address | to be confirmed |
| Postal address | to be confirmed |
| Website | https://teetimes.co.za |
03The Information Regulator's guide
The Information Regulator has published a guide, in each official language, on how to use PAIA and POPIA to get access to records and exercise your rights. You can read and download it at inforegulator.org.za, or ask the Regulator for a copy:
| Information Regulator | |
|---|---|
| Address | JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001 |
| Postal address | P.O. Box 31533, Braamfontein, Johannesburg, 2017 |
| General enquiries | enquiries@inforegulator.org.za |
| PAIA complaints | PAIAComplaints@inforegulator.org.za |
A copy of the guide is also available from our Information Officer on request, for inspection or copying during office hours.
04Records available without a request
The following are available to anyone without a formal PAIA request (section 52):
- This manual, our privacy notice and our terms of use, on our website;
- information about TeeTimes on our about page;
- clubs' public details, rates and tee times shown on the site.
A golfer can see their own bookings, charges, strikes and profile at any time by signing in, and change their message preferences on their profile.
05Records kept under other legislation
We keep records as required by the following laws, where they apply to us. Some are available only to the persons the law names.
- Companies Act 71 of 2008
- Tax Administration Act 28 of 2011
- Income Tax Act 58 of 1962
- Value-Added Tax Act 89 of 1991
- Basic Conditions of Employment Act 75 of 1997
- Labour Relations Act 66 of 1995
- Employment Equity Act 55 of 1998
- Unemployment Insurance Act 63 of 2001
- Electronic Communications and Transactions Act 25 of 2002
- Protection of Personal Information Act 4 of 2013
- Consumer Protection Act 68 of 2008
- Promotion of Access to Information Act 2 of 2000
06Records we hold, by subject
| Subject | Records |
|---|---|
| Company | Incorporation documents, share register, minutes and resolutions, statutory returns |
| Finance and tax | Financial statements, accounting records, invoices, tax and VAT returns, bank records |
| Employees | Employment contracts, payroll, leave, tax and UIF records, where we employ staff |
| Golfer accounts | Account and sign-in records, profiles, notification preferences, consent and acceptance of terms |
| Bookings (held for clubs) | Bookings, players and guests, prices, cancellation policies shown, check-ins, cancellations |
| Payments (held for clubs) | Counter payments recorded by club staff, and reversals |
| Club rules (held for clubs) | Rates, schedules, cancellation policies, charges, strikes and suspensions |
| Clubs | Club registration, settings, staff accounts and roles, invitations, imports, audit log |
| Messages | Emails and WhatsApp messages sent, delivery status, unsubscribe and bounce records |
| Suppliers | Agreements and correspondence with hosting, email and messaging providers |
| Technical | Hosting and security logs, system configuration |
07How to request access
- Complete Form 2 (Request for Access to Record) from the PAIA Regulations. It is available on the Information Regulator's website and from our Information Officer.
- Send it to the Information Officer by email to privacy@teetimes.co.za or by post to to be confirmed.
- Describe the records clearly, say how you want access (copy, inspection, electronic), and give an address or email for our reply. If you ask on behalf of someone else, include proof of your authority.
- You must show which right you want to exercise or protect and why the record is needed for it (section 53(2)(d)).
Fees
A requester other than a personal requester may have to pay a request fee before we process the request, and an access fee for searching, preparing and copying the records. The amounts are set in the PAIA Regulations as amended from time to time; we will tell you the fee that applies before we start.
If you ask for your own personal information, no request fee is payable.
Timelines
We will decide your request within 30 days of receiving it. We may extend this once by up to 30 days where the request is for a large number of records, needs a search of records elsewhere, or needs consultation, and we will tell you why. If we do not respond in time, the request is regarded as refused.
Grounds for refusal
PAIA requires or allows us to refuse access to protect, among other things:
- the privacy of another person (section 63);
- another party's commercial information, including a club's (section 64);
- information given in confidence (section 65);
- the safety of people and property (section 66);
- records privileged from production in legal proceedings (section 67);
- our own commercial information and research (sections 68 and 69).
If we refuse, we will give our reasons. Where part of a record is protected, we will give access to the rest.
Remedies
TeeTimes has no internal appeal procedure. If you are unhappy with our decision, you may complain to the Information Regulator within 180 days, or apply to a court with jurisdiction.
08Processing of personal information (POPIA)
Purposes
Running golfer accounts; making and managing tee time bookings for clubs; applying clubs' rates, access and cancellation rules; sending booking messages; keeping financial and audit records; securing the platform; and meeting legal obligations. Our privacy notice sets out the lawful basis for each.
Categories of data subjects and information
| Data subjects | Information |
|---|---|
| Golfers with accounts | Name, email, password hash, cell number, GolfRSA number, bookings, preferences, charges and strikes |
| Club members without accounts | Name, contact details, member number, tier and status, other fields a club keeps |
| Guests | Name, and cell number or email if provided |
| Club staff | Name, email, role, activity in the audit log |
| Supplier contacts and employees | Names, contact and employment details |
Recipients
The clubs a golfer books with or belongs to; our operators (Supabase Inc., Resend and, only with opt-in, Meta Platforms (WhatsApp Business)); and authorities where the law requires.
Planned transfers across borders
Our database is hosted in Australia (Amazon Web Services, ap-southeast-2, Sydney); email is sent through United States of America; WhatsApp messages, when opted into, pass through Meta's systems outside South Africa. We rely on section 72 of POPIA, as the privacy notice explains.
Security measures
Encryption in transit, row-level security separating each club's data, role-based staff permissions, an audit log of staff changes, hashed passwords, and automatic clearing of message content after 30 days.
09Availability of this manual
This manual is available on our website at teetimes.co.za/paia, and free of charge from our Information Officer by email or at our address. We will update it when our records or processing change, and the version and dates above show the current edition.