PAIA manual

This is the manual of Tiny Twigs Studio, the publisher of Maatjie Arena, under section 51 of South Africa's Promotion of Access to Information Act 2 of 2000 (PAIA), as amended by the Protection of Personal Information Act 4 of 2013 (POPIA). It says who we are, which records we hold, how to ask for them, and how we handle personal information. Last updated: 13 October 2026.

1. Who we are and how to reach us

Maatjie Arena is a free pet-raising and battling game for children, made and published by Tiny Twigs Studio, a private body in South Africa. Requests under PAIA, and questions about this manual or about personal information, go to our Information Officer.

Tiny Twigs Studio
Head of the private body and Information Officer: Tiny Twigs Studio
South Africa
Email: info@tinytwigsstudio.com
Website: maatjiearena.com

2. The Information Regulator's guide

The Information Regulator has published a guide on how to use PAIA, as section 10 of the Act asks. It explains the right to ask for records, how to make a request, the fees, and what you can do if a request is refused. It is available in every official language from the Information Regulator:

3. Records anyone can read without a request

We have not published a notice under section 52(2) of PAIA. These records are open to everyone, free, on this website, with no request needed:

4. Records we keep because other laws ask for them

We keep records as these laws require, as far as they apply to us: the Income Tax Act 58 of 1962, the Tax Administration Act 28 of 2011, the Value-Added Tax Act 89 of 1991, the Electronic Communications and Transactions Act 25 of 2002, the Consumer Protection Act 68 of 2008, the Protection of Personal Information Act 4 of 2013 and the Promotion of Access to Information Act 2 of 2000. Records that one of these laws makes public are available as that law provides.

5. The records we hold

By subject, these are the records we hold. The privacy policy says how long each is kept.

SubjectRecords
Players' accounts and game data Each account's player number and a scrambled form of its device codes, its nickname, its pets and Pet Album, game progress (care, battles, ratings, badges, rooms, items, outfits and crates), friends, friend requests and blocks, friendly battles, the online, holiday mode and friends and leaderboards settings, the players it hid, the devices on the account and when a grown-up last signed the others out, the day the game was last played, a grown-up's agreement to the Terms of Use, the swap safety code secret, and, if a grown-up saved the pet to Google, Google's number for that Google account.
Purchase records For each Google Play purchase: the product, Google's order number and purchase token, Google's answer when it checked the purchase (with the billing country and a one-way account code), what the purchase gave the account, and any refund.
Swap records Swap offers between friends, and the record of finished swaps: which items changed hands, when, and the player numbers.
Nickname and pet name reports Reports about players' nicknames and their pets' names (the name, when, and a scrambled tag for the reporter), the names that reports hid, and the list of blocked words.
Logs Our game server's logs (a player number, what was asked for, and errors), and counts of tries on our Save to Google page, kept in a scrambled form for one hour.
Emails Messages sent to us, our answers, the requests made (such as to delete an account or to see its information), and what we did about them.
Our own business Accounting and tax records, our agreements with the companies that help us (hosting, email, Google Play), and our Google Play developer account records.

6. How to ask for a record

  1. Fill in the request form, Form 2 (Request for Access to Record) of the PAIA Regulations, 2021, from the Information Regulator's website. If you cannot fill it in yourself, write to us and we will help.
  2. Send it to our Information Officer, by email to info@tinytwigsstudio.com.
  3. Describe the record well enough for us to find it, say how you would like to receive it (for example a copy by email), and give an email or postal address for our answer. For a record about someone else, also say which right you want to use or protect, and why you need the record for it, as section 53 of PAIA asks.

7. How we handle personal information (POPIA)

Why we use it

Whose information, and what

PeopleInformation
Players (mostly children) A scrambled form of the device code, player number, nickname, pets' names, game progress, friends and swaps, the players they hid, nickname and pet name reports, the day the game was last played, purchase records, server logs, and Google's number for a Google account a grown-up saved the pet to.
Parents and guardians A record that they agreed to the Terms of Use, their choice for friends and leaderboards, Google's number for the Google account they saved a pet to, and what they write to us.
People who write to us Their email address, their name if they give it, and what they write.
Visitors to this website The IP address and the short security logs our website's delivery service keeps.
Companies that help us Business contact details and the records of our agreements with them.

We never ask players for a real name, an email address, a phone number, a home address, a photo or a location.

Who receives it

We never sell personal information, and we do not share it for advertising.

Sending it outside South Africa

Our game server and its database are in the European Union. Cloudflare and Google work around the world. When information about players in South Africa is kept or handled outside the country, we use only providers bound to protect it as carefully as POPIA requires, as section 72 of POPIA asks, or where it is needed to provide the game the player and their parent or guardian chose.

How we keep it safe

8. Where to find this manual

This manual is on our website at maatjiearena.com/paia/. We email a copy free to anyone who asks, and give one to the Information Regulator when it asks. We update it when the records we hold or the way we handle personal information change.