PAIA Manual

This manual is published in terms of Section 51 of the Promotion of Access to Information Act 2 of 2000 ("PAIA"). PAIA gives effect to the constitutional right of access to any information held by the State, and any information held by another person that is required for the exercise or protection of any right.

Every private body is required to compile a manual that describes the records it holds, how those records may be requested, and the grounds on which access may be refused. This manual serves that purpose for LIVE Legacy (Pty) Ltd.

The Information Officer is responsible for receiving and processing requests for access to records submitted under PAIA.

LIVE Legacy holds the following categories of records:

User and account records

• Account registration information (name, email address)
• Subscription and billing status
• Account activity and check-in logs
• Profile preferences and settings

Vault content records

• Video files uploaded by vault owners
• Video metadata (titles, descriptions, upload timestamps)
• Recipient and executor nominations
• Release instructions and status

Death verification records

• Death certificates or verification documents uploaded by executors
• Timestamps and identities of confirming executors

Partner and commercial records

• Partner organisation details and contact information
• Referral and commission records
• Partner application records

Technical and operational records

• Server logs and access logs (retained for up to 90 days)
• Security incident records
• Support correspondence

Financial records

• Payment transaction references and subscription history (held for 5 years as required by South African tax law)
• Payment records are processed by PayFast — raw payment data is not held by LIVE Legacy

Corporate records

• Certificate of incorporation and company registration documents
• Shareholder and director information
• Financial statements
• Employment and contractor agreements

Any person wishing to access records held by LIVE Legacy must submit a written request to the Information Officer. Requests may be submitted by email to privacy@livelegacy.ai.

Your request must include:

• Your full name and contact details
• A description of the record(s) you are requesting
• The form in which you require access (e.g., copy, inspection)
• If you are requesting records about another person, the capacity in which you are making the request and proof of that capacity
• Any other information that may assist us in identifying the records

We will acknowledge receipt of your request within 5 business days and respond substantively within 30 days. We may request clarification or additional information if necessary to process your request.

The prescribed Form C under PAIA is available from the South African Information Regulator at www.inforegulator.org.za. Use of the form is encouraged but not mandatory — a written request containing the required information is sufficient.

LIVE Legacy does not charge a request fee for data subjects seeking access to their own personal information. For requests relating to third-party records or extensive reproductions, a fee may be charged in accordance with the Regulations under PAIA. We will notify you of any applicable fee before processing your request.

No fee will be charged where the requestor is seeking access to records that are required for the protection of a right and the requestor is unable to pay.

LIVE Legacy may refuse a request for access to records on the following grounds, as set out in PAIA:

• The record contains personal information about a third party who has not consented to disclosure, and disclosure would constitute an unreasonable invasion of that person's privacy
• The record is protected by legal professional privilege
• The record contains commercially sensitive or confidential third-party information
• Disclosure would endanger the life or safety of an individual
• The record does not exist or cannot be found despite all reasonable efforts
• The request is frivolous or vexatious, or is made in bad faith
• Disclosure would result in a breach of a duty of confidence owed by LIVE Legacy to a third party

Where access is refused, we will inform you in writing of the refusal and the grounds for it, as well as your right to appeal or complain to the Information Regulator.

In addition to PAIA rights, South African data subjects have rights under the Protection of Personal Information Act 4 of 2013 ("POPIA"). These include the right to:

• Be notified when personal information about you is collected
• Access personal information we hold about you
• Request correction of inaccurate, irrelevant, excessive, out-of-date, incomplete, misleading, or unlawfully obtained personal information
• Request deletion or destruction of personal information we are no longer authorised to retain
• Object to the processing of your personal information on reasonable grounds
• Lodge a complaint with the Information Regulator

To exercise these rights, please visit our Data Subject Request page or email privacy@livelegacy.ai.

Complaints about the processing of personal information or refusals of access under PAIA may be lodged with the Information Regulator of South Africa:

This manual will be updated as required when there are material changes to the records held by LIVE Legacy, the structure of the company, or the applicable legal framework. The effective date at the top of this page reflects the most recent update.