Legal

Privacy Policy

Formal privacy policy for the Book Rion ecosystem.

1. Introduction

1.1 This Privacy Policy (“Policy”) explains how Book Rion Ltd (“Book Rion”, “the Company”, “we”, “us”, or “our”) collects, uses, stores, processes, shares, protects, transfers, and otherwise handles personal data in connection with the Book Rion platform.

1.2 This Policy applies to all users and participants within the Book Rion ecosystem, including readers, young readers, parents, guardians, authors, publishers, bookstores, sellers, lessors, lessees, exchange participants, content providers, logistics participants, and any other person or entity that accesses or uses Book Rion’s products, services, applications, websites, portals, dashboards, APIs, or related systems.

1.3 The Book Rion ecosystem includes, without limitation:

  • (a)Rion Prime, being the main mobile reading experience for general users;
  • (b)Young Rion, being the curated reading experience for children and young readers;
  • (c)Rion Studio, being the backend system for authors, publishers, bookstores, sellers, and other content providers;
  • (d)marketplace features for book sale, lease, exchange, payment, logistics, settlement, and fulfilment;
  • (e)community features, reading tools, recommendations, streak tracking, reviews, ratings, analytics, subscriptions, and any other product or service operated by Book Rion.

1.4 By accessing, registering on, browsing, using, uploading content to, purchasing from, leasing through, exchanging through, listing on, or otherwise participating in the Book Rion platform, you acknowledge that you have read and understood this Policy.

1.5 Where consent is required under applicable law, your continued use of the platform or express action through the platform shall constitute your consent to the collection and processing of your personal data in accordance with this Policy.

2. Purpose of this Policy

2.1 The purpose of this Policy is to:

  • (a)inform you of the types of personal data we collect;
  • (b)explain why and how we process personal data;
  • (c)identify the lawful bases for processing personal data;
  • (d)explain when and with whom we may share personal data;
  • (e)state your rights in relation to your personal data;
  • (f)explain how we protect and retain personal data; and
  • (g)provide contact details for privacy-related questions, requests, or complaints.

3. Applicable Data Protection Framework

3.1 Book Rion shall process personal data in accordance with applicable data protection and privacy laws in the Federal Republic of Nigeria, including the Nigeria Data Protection Act, 2023, and any regulations, guidelines, directives, or successor laws issued by competent authorities.

3.2 Where Book Rion processes personal data of persons located outside Nigeria, Book Rion may also be required to comply with other applicable privacy or data protection laws in the relevant jurisdiction, to the extent such laws apply.

4. Definitions

In this Policy, unless the context otherwise requires:

“Account” means a registered profile created by a user on the Book Rion platform.

“Applicable Law” means any statute, regulation, rule, order, directive, guideline, code, or other law applicable to Book Rion’s processing of personal data.

“Child” or “Young Reader” means a user below the age threshold requiring parental or guardian oversight under applicable law or Book Rion’s product rules.

“Controller” means the person or entity that determines the purposes and means of processing personal data.

“Data Subject” means an identified or identifiable natural person to whom personal data relates.

“Personal Data” means any information relating to an identified or identifiable natural person, including identity, contact, device, transaction, usage, location, profile, preference, and account information.

“Platform” means all Book Rion mobile applications, websites, APIs, portals, dashboards, databases, systems, community features, marketplace features, and related services.

“Processor” means a person or entity that processes personal data on behalf of Book Rion.

“Processing” means any operation performed on personal data, including collection, storage, use, access, recording, organisation, analysis, disclosure, transfer, deletion, or destruction.

“Sensitive Personal Data” means any personal data classified as sensitive under applicable law, including information relating to children, health, biometric data, precise location data, or any other protected category.

“User” means any person who accesses, registers on, or uses Book Rion.

5. Interpretation

5.1 In this Policy:

  • (a)words in the singular include the plural and vice versa;
  • (b)references to “including” shall be interpreted as “including without limitation”;
  • (c)headings are for convenience only and shall not affect interpretation;
  • (d)references to any law shall include any amendment, re-enactment, replacement, or subsidiary legislation made under it.

6. Who We Are

6.1 Book Rion is a multi-sided digital reading and book marketplace platform designed to support book discovery, reading habits, book sales, reading access, book leasing, book exchange, content distribution, reader engagement, and related services across different age groups.

6.2 Book Rion provides services to:

  • (a)general readers through Rion Prime;
  • (b)children and young readers through Young Rion;
  • (c)parents, guardians, and educators through child-account oversight tools;
  • (d)authors, publishers, bookstores, and sellers through Rion Studio and related listing portals;
  • (e)marketplace participants involved in sale, lease, exchange, logistics, payment, and fulfilment.

6.3 For the purpose of this Policy, Book Rion shall generally act as the controller of personal data processed through the platform. In certain circumstances, Book Rion may act as a processor or joint controller where required by law or by agreement with commercial partners.

7. Categories of Personal Data We Collect

7.1 Book Rion may collect and process the following categories of personal data:

7.1.1 Identity Data

This may include full name, username, profile name, date of birth, age bracket, gender, account type, parent/guardian details, seller identity details, publisher or bookstore representative details, and verification information.

7.1.2 Contact Data

This may include email address, phone number, billing address, shipping address, delivery address, business address, and other communication details.

7.1.3 Account Data

This may include account credentials, user profile information, subscription plan, account settings, reading preferences, saved books, wishlists, library selections, parental-control settings, and dashboard configurations.

7.1.4 Device and Technical Data

This may include IP address, device identifier, mobile device ID, operating system, browser type, browser version, app version, time zone, device settings, crash logs, diagnostic data, and technical usage information.

7.1.5 Transaction and Payment Data

This may include purchase history, lease history, exchange history, order details, delivery status, payment confirmation, invoices, refunds, wallet balances, payout records, royalty payments, seller settlements, subscription payments, and payment-processing references.

Book Rion does not intend to store full card details where payments are processed through regulated payment providers. Payment details may be processed by third-party payment processors in accordance with their own security and compliance standards.

7.1.6 Profile, Reading, and Usage Data

This may include reading history, books accessed, reading time, reading streaks, reading goals, reading progress, notes, highlights, reviews, ratings, recommendations, gamification statistics, reading credits, community interactions, and engagement patterns.

7.1.7 Location Data

This may include delivery location, shipping location, bookstore proximity data, location selected by the user, and, where permitted, device-derived approximate or precise location data for delivery, marketplace, or location-based discovery purposes.

7.1.8 Uploaded Content and Personal Library Data

This may include user-uploaded PDFs, notes, summaries, reading lists, documents, excerpts, saved materials, and other files stored in personal libraries or user-controlled spaces.

7.1.9 Marketing and Communication Data

This may include newsletter preferences, notification preferences, campaign opt-ins, opt-outs, customer support messages, survey responses, feedback, and communication history.

7.1.10 Children’s Account Data

Where Young Rion or child-focused services are used, Book Rion may collect limited personal data relating to children or young readers, subject to parental or guardian consent, oversight, and applicable legal requirements.

7.1.11 Aggregated and Anonymised Data

Book Rion may collect, generate, and use aggregated or anonymised data for analytics, product development, research, reporting, and business intelligence. Such data shall not ordinarily identify any individual user.

8. How We Collect Personal Data

8.1 Book Rion may collect personal data in the following ways:

8.1.1 Directly from You

We collect data when you register, create an account, subscribe, upload content, list books, make purchases, lease books, exchange books, provide delivery details, contact support, submit forms, participate in community features, or update your profile.

8.1.2 Through Your Use of the Platform

We collect data when you browse, read, review, rate, save, lease, exchange, purchase, upload, search, interact with recommendations, use streak tracking, join challenges, use marketplace features, or otherwise engage with the platform.

8.1.3 From Content Providers and Marketplace Participants

We collect data when bookstores, authors, publishers, sellers, or lessors upload inventory, manage orders, update listings, provide fulfilment information, or submit payout details.

8.1.4 Through Automated Technologies

We may collect data through cookies, pixels, software development kits, app analytics tools, device logs, server logs, crash reports, tracking technologies, and similar technical mechanisms.

8.1.5 From Third Parties

We may receive data from payment processors, logistics partners, analytics providers, verification providers, cloud service providers, customer support tools, ISBN-related service providers, and other service providers required for platform operations.

9. Lawful Bases for Processing Personal Data

9.1 Book Rion may process personal data on one or more of the following lawful bases:

  • (a)consent, where you have given clear permission for a specific purpose;
  • (b)performance of a contract, where processing is necessary to provide services or fulfil obligations to you;
  • (c)compliance with legal obligations;
  • (d)legitimate interests pursued by Book Rion or a third party, provided such interests are not overridden by your rights and freedoms;
  • (e)protection of vital interests, where necessary in limited circumstances;
  • (f)performance of a task carried out in the public interest, where applicable under law.

9.2 Where consent is relied upon, you may withdraw consent at any time, subject to any legal or contractual limitations.

10. How We Use Personal Data

10.1 Book Rion may use personal data for the following purposes:

10.1.1 Account Registration and Management

To create accounts, verify users, authenticate access, maintain profiles, manage settings, and provide user support.

10.1.2 Platform Operation and Service Delivery

To provide access to Rion Prime, Young Rion, Rion Studio, marketplace features, reading tools, community features, subscriptions, and related platform services.

10.1.3 Payment, Billing, Wallets, and Settlements

To process subscriptions, purchases, leases, exchanges, refunds, commissions, logistics charges, seller settlements, wallet credits, withdrawals, and related financial records.

10.1.4 Book Discovery and Personalisation

To recommend books, authors, genres, reading plans, communities, and content based on user preferences, usage data, reading history, behaviour, and selected interests.

10.1.5 Reading Habit Support and Analytics

To support reading streaks, goals, calendar reminders, gamification, progress tracking, reading insights, and user-facing analytics.

10.1.6 Marketplace Fulfilment and Logistics

To process physical book orders, coordinate delivery, route logistics, calculate delivery charges, confirm delivery, manage returns, and resolve fulfilment disputes.

10.1.7 Content Provider Operations

To enable bookstores, authors, publishers, and other content providers to upload inventory, manage listings, track sales, receive settlements, access analytics, and respond to operational issues.

10.1.8 Customer Support and Dispute Resolution

To respond to enquiries, investigate complaints, verify claims, resolve disputes, enforce policies, and communicate with users.

10.1.9 Security, Fraud Prevention, and Compliance

To detect, prevent, investigate, or respond to fraud, unauthorised access, piracy, infringement, account misuse, payment abuse, policy breaches, or security incidents.

10.1.10 Marketing and Communications

To send newsletters, promotional offers, service updates, app notifications, campaigns, product announcements, and marketing communications, where permitted by law or based on your preferences.

10.1.11 Legal, Regulatory, and Administrative Purposes

To comply with legal obligations, tax requirements, accounting obligations, regulatory requests, court orders, law enforcement requests, audit requirements, and contractual obligations.

10.1.12 Product Improvement and Research

To analyse platform performance, improve user experience, develop new features, conduct internal research, generate aggregated insights, and improve recommendation systems.

11. Cookies and Tracking Technologies

11.1 Book Rion may use cookies and similar tracking technologies to:

  • (a)enable platform functionality;
  • (b)remember user preferences;
  • (c)authenticate users;
  • (d)analyse usage patterns;
  • (e)improve app and website performance;
  • (f)support security and fraud detection;
  • (g)measure marketing and campaign performance.

11.2 Users may disable cookies through browser settings where available. However, certain features may not function properly where cookies or tracking technologies are disabled.

11.3 Where required by applicable law, Book Rion shall request user consent before using non-essential cookies or similar technologies.

12. Disclosure and Sharing of Personal Data

12.1 Book Rion may share personal data with the following categories of recipients:

12.1.1 Internal Personnel

Employees, contractors, officers, support staff, operations staff, product teams, technical teams, compliance personnel, and authorised personnel who require access for legitimate business purposes.

12.1.2 Payment and Financial Service Providers

Payment processors, banks, escrow providers, wallet service providers, fraud-detection services, and related financial infrastructure providers.

12.1.3 Logistics and Delivery Partners

Courier companies, delivery partners, fulfilment partners, and logistics providers for the purpose of processing pickups, deliveries, returns, proof of delivery, and fulfilment disputes.

12.1.4 Technology and Infrastructure Providers

Cloud hosting providers, database services, analytics tools, app performance tools, customer support platforms, error reporting services, communication tools, cybersecurity providers, and other technical vendors.

12.1.5 Content Providers and Marketplace Participants

Where necessary for fulfilment, settlement, dispute resolution, order processing, listing management, or rights management.

12.1.6 Professional Advisers

Lawyers, auditors, accountants, consultants, insurers, and other professional advisers where necessary for legal, financial, audit, compliance, or business purposes.

12.1.7 Regulatory, Legal, and Public Authorities

Courts, regulators, law enforcement agencies, tax authorities, data protection authorities, or other public bodies where disclosure is required by law or necessary to protect rights, safety, security, or lawful interests.

12.2 Book Rion does not sell or rent personal data to advertisers or unrelated third parties.

12.3 Where Book Rion shares personal data with third-party service providers, Book Rion shall take reasonable steps to ensure that such providers process personal data securely and only for authorised purposes.

13. Children’s Privacy and Young Rion

13.1 Young Rion is intended to provide a curated reading environment for children and young readers under appropriate adult oversight.

13.2 Book Rion does not knowingly collect personal data from children in a manner that is inconsistent with applicable law.

13.3 Child or young-reader accounts must be created, authorised, supervised, or managed by a parent, guardian, educator, or authorised adult, as required by Book Rion’s product rules and applicable law.

13.4 Book Rion may collect limited personal data relating to children for purposes including account setup, reading progress, content curation, parental oversight, safety, and age-appropriate recommendations.

13.5 Parents or guardians may contact Book Rion to request access, correction, restriction, or deletion of a child’s personal data, subject to legal retention requirements and verification.

14. Uploaded Files and Personal Libraries

14.1 Users may upload personal PDFs, notes, summaries, reading materials, or related content to personal libraries, where such feature is enabled.

14.2 Book Rion may process uploaded content to provide storage, access, summaries, recommendations, analytics, or other user-requested services.

14.3 Uploaded personal content is intended to remain private to the relevant user unless the user chooses to share it or unless disclosure is required by law, necessary for support, or required for security, abuse prevention, or policy enforcement.

14.4 Users are responsible for ensuring that any uploaded content does not infringe the rights of any third party or violate Book Rion’s policies.

15. Marketing Communications

15.1 Book Rion may send users marketing messages, newsletters, product updates, promotional offers, reading recommendations, creator content, or campaign communications.

15.2 Users may opt out of marketing communications at any time through available unsubscribe links, account settings, notification preferences, or by contacting Book Rion.

15.3 Book Rion may still send non-marketing communications, including account notices, security alerts, transaction confirmations, subscription notices, policy updates, delivery notices, and service-related messages.

16. Push Notifications and In-App Communications

16.1 Book Rion may send push notifications, in-app messages, email notifications, or SMS communications relating to reading streaks, orders, subscriptions, book recommendations, delivery updates, wallet activity, security notices, app updates, or other platform activities.

16.2 Users may manage notification preferences through device settings, app settings, or such other mechanisms as Book Rion may provide.

17. Data Security

17.1 Book Rion shall implement reasonable technical, organisational, and administrative measures designed to protect personal data against accidental loss, unauthorised access, misuse, alteration, disclosure, or destruction.

17.2 Such measures may include encryption, access controls, authentication procedures, secure hosting, monitoring, audit logs, role-based access, regular reviews, and incident-response procedures.

17.3 Notwithstanding the foregoing, no digital platform, transmission method, or storage system can be guaranteed to be completely secure.

17.4 Users are responsible for safeguarding their account credentials and for promptly reporting suspected account compromise.

18. Data Retention

18.1 Book Rion shall retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including service delivery, account management, legal compliance, accounting, audit, dispute resolution, fraud prevention, and enforcement.

18.2 Retention periods may vary depending on the nature of the data, transaction type, legal obligations, operational needs, and risk considerations.

18.3 Where personal data is no longer required, Book Rion may delete, anonymise, archive, or securely destroy it.

18.4 Where a user requests deletion of personal data, Book Rion may retain certain information where required by law, necessary for legitimate business purposes, dispute resolution, fraud prevention, accounting, enforcement, or compliance.

19. International Data Transfers

19.1 Book Rion may transfer, store, or process personal data outside Nigeria where its service providers, hosting infrastructure, technical vendors, analytics providers, payment processors, or operational partners are located outside Nigeria.

19.2 Where personal data is transferred internationally, Book Rion shall take reasonable steps to ensure that appropriate safeguards are in place in accordance with applicable data protection law.

19.3 Such safeguards may include contractual protections, data protection agreements, adequacy considerations, technical controls, or other lawful transfer mechanisms.

20. Your Data Protection Rights

20.1 Subject to applicable law, you may have the right to:

  • (a)request access to your personal data;
  • (b)request correction of inaccurate or incomplete personal data;
  • (c)request deletion of your personal data;
  • (d)request restriction of processing;
  • (e)object to processing in certain circumstances;
  • (f)withdraw consent where processing is based on consent;
  • (g)request data portability where applicable;
  • (h)object to direct marketing;
  • (i)lodge a complaint with a competent data protection authority.

20.2 To exercise any of these rights, you may contact Book Rion at support@bookrion.com.

20.3 Book Rion may require verification of your identity before responding to any request.

20.4 Book Rion may decline or limit a request where permitted or required by law, including where fulfilling the request would affect the rights of others, conflict with legal obligations, compromise security, interfere with fraud prevention, or disrupt unresolved transactions.

21. Account Deactivation and Deletion

21.1 Users may request account deactivation or deletion through available platform tools or by contacting Book Rion.

21.2 Account deletion may result in loss of access to reading history, saved books, subscription benefits, wallet features, community content, and other account-related services.

21.3 Book Rion may retain limited information after account deletion where necessary for legal compliance, fraud prevention, dispute resolution, accounting, enforcement, or legitimate operational purposes.

22. Third-Party Links and Services

22.1 The platform may contain links, integrations, or references to third-party services, including payment providers, logistics partners, analytics tools, external websites, or content providers.

22.2 Book Rion is not responsible for the privacy practices, security standards, content, or policies of third-party services not controlled by Book Rion.

22.3 Users should review the privacy policies of any third-party services they interact with.

23. Automated Processing, Recommendations, and Analytics

23.1 Book Rion may use automated tools, analytics, machine learning, recommendation systems, and behavioural insights to personalise reading recommendations, improve platform experience, identify content trends, detect misuse, and support marketplace operations.

23.2 These systems may analyse reading activity, preferences, search behaviour, purchases, ratings, reviews, usage patterns, and other relevant data.

23.3 Book Rion shall not use automated processing in a manner that unlawfully denies users rights or access without reasonable review or applicable safeguards.

24. Data Accuracy

24.1 Users are responsible for ensuring that personal data submitted to Book Rion is accurate, complete, and current.

24.2 Users may update certain account details through their account settings or by contacting support.

24.3 Book Rion shall not be liable for errors, delays, failed deliveries, failed payments, or other issues resulting from inaccurate or outdated user information.

25. Security Incidents

25.1 Where Book Rion becomes aware of a personal data breach or security incident affecting personal data, Book Rion shall take reasonable steps to investigate, contain, remediate, and notify affected parties or competent authorities where required by applicable law.

25.2 Users shall promptly notify Book Rion of any suspected unauthorised access, account compromise, fraud, or privacy concern.

26. Changes to this Policy

26.1 Book Rion may amend, revise, or replace this Policy from time to time.

26.2 Any updated version shall take effect from the date stated in the revised Policy or upon publication on the platform.

26.3 Where changes are material, Book Rion may notify users through email, in-app notification, platform message, website notice, or any other reasonable communication method.

26.4 Continued use of the platform after publication or notification of changes shall constitute acknowledgement of the updated Policy.

27. Governing Law

27.1 This Policy shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria.

28. Dispute Resolution

28.1 Any privacy-related complaint, concern, or dispute should first be directed to Book Rion through the contact details provided in this Policy.

28.2 Book Rion shall use reasonable efforts to review and respond to privacy complaints within a commercially reasonable period.

28.3 Where a dispute cannot be resolved amicably within fourteen (14) days of written notice, the dispute may be referred to mediation in Lagos State, Nigeria.

28.4 Where mediation fails or is declined, the dispute shall be submitted to the competent courts of Lagos State, Nigeria, unless a separate agreement between the parties provides for arbitration or another dispute resolution mechanism.

28.5 Nothing in this clause shall prevent Book Rion from seeking urgent interim or protective relief before any court of competent jurisdiction.

29. Contact Details

29.1 For privacy enquiries, data protection requests, complaints, or concerns, please contact Book Rion through: hello@bookrion.com

Registered Address: NOVABASE, ADMIRALTY WAY, LEKKI PHASE 1, ETI-OSA, LAGOS STATE.