Home / PAIA manual
PAIA manual
How to ask us
for a record
The manual we publish in terms of section 51 of the Promotion of Access to Information Act: what we hold, how to request it, and what we do with personal information.
Effective 26 August 2026. This is the version of the manual currently in force. Earlier versions are available on request.
Who we are
This manual is published by Average Kids (Pty) Ltd, trading as The Magic Pixel, registration number 2018/620888/07, which runs UGCZA (Ultimate Gaming Championships South Africa). It is the same entity named in the privacy notice and the terms of use.
Head of the private body and Information Officer: Umar Bradlow.
Postal and street address: 4 Bolton Rd, Parkwood, Johannesburg, 2192.
Telephone: +27 76 934 1288.
Email: info@themagicpixel.co.za.
Website: ugcza.com.
We do not operate a fax line. Section 51 lists one, so we say so rather than leave the line blank.
The Regulator’s guide
The Information Regulator publishes a guide, in terms of section 10 of PAIA, on how to use the Act. It explains how to make a request to any public or private body, and it is more general than this manual. It is available free of charge from the Regulator, in each of the official languages.
Information Regulator (South Africa), Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191. Their website is inforegulator.org.za and general enquiries go to enquiries@inforegulator.org.za.
Records we hold
The subjects we keep records on, and the categories of record under each. Listing a category here does not mean every record in it is available on request - the Act sets out grounds on which access must or may be refused, and those apply to this manual as they do to any other.
- The company itself - registration documents, statutory records and the registers a company is required to keep.
- Finance and tax - invoices, statements, returns and supporting records.
- This website and its content - the copy on each page, and the records behind it: partner and sponsor entries, testimonials, profiles of the people named on the site, tournament listings, press kit assets and news articles.
- Enquiries sent through the contact form - the sender’s name, email address, organisation, chosen topic and message, which inbox it was routed to, and whether the notification email was accepted. These are deleted twelve months after the message is sent.
- Events we run - planning and production records, and the photographs, video and audio captured at them.
- Agreements - with partners, sponsors, suppliers and venues.
What we do not hold. Tournament entries are handled by start.gg and that data never reaches our web server, so entrant lists, seeding and results sit with them rather than with us. We keep no analytics records, no advertising or tracking data, and no marketing or newsletter list, because the site collects none of it. The server logs that record visits are kept by our host rather than by us, for six months.
Records under other laws
Some of the records above are kept because other legislation requires it, and where a specific Act gives you a right of access, that route applies rather than this one. The Acts that bear on our records include the Companies Act 71 of 2008 and the Income Tax Act 58 of 1962, together with any other legislation that applies to a private company of our kind.
Available without a request
We have not published a notice under section 52(2) of PAIA listing categories of record that are automatically available. A great deal is published anyway and needs no request at all: everything on this site, including the privacy notice, the terms of use, the cookie notice, tournament information, and the assets offered on the press kit on the terms stated there.
Personal information we process
This section is required by section 51(1)(c), which POPIA inserted into PAIA. The privacy notice says the same things at greater length and is the fuller account.
Why we process it. To answer enquiries sent to us; to run, broadcast, promote and archive our tournaments; to work with partners, sponsors and suppliers; and to meet our own legal and accounting obligations.
Whose information. People who contact us; people who enter or attend our events; people who appear in photographs, video or audio captured at them; representatives of partners, sponsors, suppliers and venues; and the people who work on UGCZA.
What kinds. Names and contact details; the content of messages sent to us; images, footage and audio recorded at events; and the tags, match results and standings that appear in coverage, which are published by start.gg rather than collected by us.
Who else receives it
- Our host, Hostinger (HOSTINGER, UAB, Lithuania), which stores the site, its database and its backups, and keeps the server logs.
- start.gg, which runs entries and brackets, and publishes them.
- Discord and YouTube, where our community and our video sit, on their own terms.
- Professional advisers, such as accountants, where they need it to do their work.
- Authorities, where the law requires us to hand something over.
Transfers outside South Africa
Our host stores the site and its backups on servers in the United Kingdom, and start.gg, Discord and YouTube are all outside South Africa. Where personal information leaves the country, section 72 of POPIA allows it only on specific grounds, and the one we rely on is that the supplier is bound by an agreement that upholds protection substantially similar to POPIA’s.
How we keep it safe
Described in general terms, as the section asks. The site is served over HTTPS. Administrative access is limited to the people who need it and is protected by individual accounts rather than a shared login. The contact form stores no IP address. Enquiries are deleted automatically twelve months after they are sent, so the store does not grow indefinitely. The site sets no cookies, loads no third-party scripts and makes no requests to other services from a visitor’s browser, which removes a large class of exposure rather than managing it.
Making a request
Requests go to the Information Officer, at the address or email address above. Use the form prescribed by the PAIA Regulations; we will send it to you if you would rather not find it yourself, and we will help you put the request together if you need that, including if a disability makes the written form difficult.
Tell us enough to identify the record, say which form of access you want, and give us an address or email address to reply to. If you are asking on someone else’s behalf, say so and show that you are entitled to.
Fees. The Regulations set a request fee, and an access fee for the time and materials involved in finding and preparing a record. We will tell you what is payable before we do the work, and you may ask us to reconsider an amount. There is no fee for asking us for your own personal information.
How long. We will decide within 30 days of receiving the request and tell you in writing. That period can be extended by a further 30 days where the request covers a lot of records or they are held elsewhere, and we will tell you if that happens and why.
If it is your own information you want, the shorter route is usually POPIA rather than PAIA - the privacy notice sets out how to ask, and it is free.
If we refuse
We will tell you in writing which ground in the Act we are relying on, so that you can decide what to do about it. There is no internal appeal against a private body’s decision. You may complain to the Information Regulator, or apply to a court, within the periods the Act allows.
Complaints to the Regulator go to PAIAComplaints@inforegulator.org.za, or to the Woodmead address above.
Where this manual is available
On this page, which is its primary location. At our principal place of business during office hours, for inspection. As a copy, on request, against a reasonable fee for the copying. And with the Information Regulator, as section 51(3) requires.
We update it whenever it stops being accurate rather than on a fixed cycle, and the effective date at the top is the version in force.
