This manual is prepared under section 51 of the Promotion of Access to Information Act, 2000 (PAIA), and also covers what section 51(1)(c) asks about the processing of personal information under the Protection of Personal Information Act, 2013 (POPIA). It explains how to ask ASM for access to records it holds. Words such as "ASM", "the Services" and "wallet" mean what the "Words we use" table on the About ASM page says.
1. About ASM
ASM (Anti Social Media) is an independent creative project run from South Africa by its founder: a clothing and art brand with digital wearables on the XRP Ledger, a 3D web game (the Offline District) and a collector community at https://asmedia.co.za. At the time of writing ASM is not a registered company. It is a private body for PAIA purposes.
2. Head of the private body and Information Officer
| Head of the private body | The ASM founder (known publicly as TheOak), who runs ASM |
| Information Officer | The ASM founder. ASM has not appointed a Deputy Information Officer. |
| How to contact them | DM the_oak_ on Discord (ASM server: https://discord.gg/g8uKfBPHGX), or message @0xASMedia on X |
| Website | https://asmedia.co.za |
| Physical and postal address | ASM is online-only and has no public office. If you need a physical or postal address to deliver a written request, ask through the channels above and we'll give you one. |
3. The Information Regulator's guide
The Information Regulator publishes a guide on how to use PAIA and POPIA (section 10 of PAIA). You can get it from the Regulator:
- website: https://inforegulator.org.za
- the guide is available in South Africa's official languages, on the website and at the Regulator's office
4. Records available without a request
These records are published on https://asmedia.co.za and you can read them without a PAIA request:
- Terms of Use, Digital Collectible Purchase Terms, Crate Rules and Odds, Privacy Policy, Cookies and Local Storage Notice, IP and Holder Licence, Community Guidelines, Quests and Promotions Rules, Project Disclaimer and Risks, Merch and VIP Claim Terms, About ASM, and this manual
- crate odds, prices, mint fees and royalty rates for each release, shown in the Shop
- news, dev logs and credits for third-party assets
- public Community profiles that their owners have chosen to make public
Records on the XRP Ledger (transactions and NFTs) and on IPFS (item artwork and descriptions) are public by design and anyone can read them directly.
ASM has not yet published a notice under section 52(2) of PAIA.
5. Records kept under other laws
ASM keeps records where other laws require it, which may include:
- the Consumer Protection Act, 2008 (consumer agreements and promotional competitions)
- the Electronic Communications and Transactions Act, 2002
- the Income Tax Act, 1962, and the Tax Administration Act, 2011 (sales and tax records)
- the Protection of Personal Information Act, 2013
- the Copyright Act, 1978, and the Trade Marks Act, 1993
6. Records ASM holds
| Subject | Categories of records |
|---|---|
| Operations | Item and release configurations, crate releases and their published odds, prize pools and frozen terms, Shop listings, merch batches, VIP release settings, quest settings, Admin audit logs |
| Sales and claims | Shop, mint, crate, starter, merch and VIP orders and claims, with wallet addresses, prices, mint fees, XRP Ledger transaction references and status; refund lists; unattached-payment logs |
| Users | Wallet addresses, sign-in records and sessions, Terms acceptances and age confirmations, Community profiles and uploaded images, saved looks, game progress, quest entries and points, privacy requests |
| Intellectual property | ASM artwork, 3D models, animations, game code, and the licences of third-party assets |
| Suppliers | Records of the services ASM uses (hosting, content delivery, IPFS storage, wallet sign-in and backups) and their terms |
| Finance and tax | Records of XRP received and paid, and the related ledger transactions |
| Communications | Messages with users and partners on Discord and X |
7. How ASM processes personal information (POPIA)
7.1 Why we process it
To run the Services: wallet sign-in, profiles and the Community, the Wardrobe and game, Shop and crate sales, deliveries and claims, quests and promotions, preventing fraud and abuse, keeping the Services secure, answering requests, and keeping the records the law requires. The Privacy Policy explains each purpose in detail.
7.2 Whose information and what information
| Data subjects | Information |
|---|---|
| Visitors | Technical information needed to deliver web pages, such as IP address and browser details, handled by our hosting and content-delivery providers |
| Wallet users and buyers | Wallet address, sessions, orders, claims, XRP Ledger transaction references, Terms acceptance and age confirmation |
| Profile owners | Display name, bio, X and Instagram handles, banner and profile images, character look and pose, showcase, rough location (optional), sharing choices |
| Quest participants | Linked X handle, the post links submitted, check results, points and prize records |
| Merch customers | Merch code redemptions linked to a wallet |
| People who contact us | Discord or X usernames and the content of their messages |
| Suppliers and partners | Business contact details |
ASM doesn't ask for names, ID numbers, email addresses, phone numbers or bank details through the Services. It doesn't knowingly process information about children.
7.3 Who receives it
- service providers that process information for ASM: our hosting provider (Vultr, server in Amsterdam, the Netherlands), our content-delivery and security provider (Cloudflare), our off-site backup storage provider (which receives only encrypted files), wallet sign-in providers (Xaman and, for Joey wallet, the WalletConnect network run by Reown)
- the public XRP Ledger, for every transaction a user signs
- X, when we read public quest posts through X's public embed service
- authorities, only when the law requires
7.4 Information sent outside South Africa
ASM's server is hosted in the European Union (Amsterdam, the Netherlands), so most personal information is stored there. Some providers above are based in the United States and elsewhere. ASM transfers personal information abroad only as section 72 of POPIA allows. The Privacy Policy, section 10, gives more detail.
7.5 How it is protected
HTTPS everywhere, sign-in cookies that page scripts can't read, internal services that can't be reached from the internet, a separate signing service for ASM's issuing wallet, metadata removed from uploaded photos, encrypted backups, limited Admin access with typed confirmations and audit logs. The Privacy Policy, section 12, gives more detail.
8. How to request access to a record
- Fill in Form 2 ("Request for access to record") prescribed under PAIA. You can get it from the Information Regulator's website, or ask us for a copy.
- Send it to the Information Officer through a channel in section 2. If you'd like to deliver it another way, ask us first.
- Give enough detail for us to find the record, say which form of access you want (for example a copy or an electronic file), and explain which right you want to exercise or protect and why you need the record for it (PAIA section 53).
- If you ask for records about your own ASM account, we'll ask you to prove that you control the wallet, usually by signing a sign-in request in your wallet. We will never ask for your secret key or recovery phrase.
- If you're asking for someone else, include proof that you're allowed to act for them.
Fees. PAIA allows a private body to charge a request fee and an access fee, at the amounts in the PAIA Regulations. A person asking for their own personal information doesn't pay a request fee. We'll tell you about any fee before we process the request.
Time. We'll decide within 30 days of receiving a complete request. We may extend this once, by up to 30 more days, where PAIA allows, and we'll tell you why.
Refusals. We may refuse access only on the grounds in Chapter 4 of Part 3 of PAIA, for example to protect someone else's privacy, commercial information of a third party or ASM, or the security of the Services. If we refuse, we'll give our reasons.
If you disagree. You can complain to the Information Regulator or apply to a court, as PAIA sections 77A and 78 allow.
9. Your POPIA rights
You can ask ASM what personal information it holds about you, ask us to correct or delete it, and object to its use, as the Privacy Policy, section 13, explains. Use the channels in section 2. You can also complain to the Information Regulator at https://inforegulator.org.za.
10. Where to find this manual
This manual is on https://asmedia.co.za with the other legal documents. You can also ask the Information Officer for a copy at no charge.