Privacy Policy

We are Libro Publishing Limited (trading as Libraro or Libraro.com and hereinafter referred to as ‘we’, ‘our’ or ‘us’), a company registered in England and Wales under company registration number 14602616. Our registered office is at C/O Solid Ltd, Eagle House, 163 City Road, London, England, EC1V 1NR.

Libraro is registered with the Information Commissioner’s Office with registration number ZB861769.

We are the controller of personal data obtained via our website Libraro.com, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).

Acknowledgment

By using the Libraro platform, you acknowledge that you have read, understood, and agree to this Privacy Policy. If you do not agree, please do not use our services.

General

The Libraro platform is not intended for individuals under 18 years of age. We do not knowingly collect data from children. If you are aware that any personal data of children has been shared on the Libraro platform please let us know so that we can delete that data.

What this policy applies to

This privacy policy relates to your use of our website and the Libraro platform, such as writers who submit work on the Libraro platform, readers who create accounts on the Libraro platform, visitors to the website and all other users regardless of geographic location.

Throughout our website we may link to other websites owned and operated by certain trusted third parties to make parts of our service available to you. Those third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third party websites, please consult their privacy policies as appropriate.

Personal data we collect about you

The personal data we collect about you depends on the particular activities carried out through our website.

We will collect and use the following personal data about readers:

your name
username
email address
age verification
reader bio and preferences (optional)

We will collect and use the following personal data about writers:

your name
display name
pseudonym
email address
at your option you may choose to provide us your address and telephone number and where relevant, company details
information to check and verify your identity, e.g., date of birth (the standard sign in process only requires the age group)
your gender, optional, only if you choose to give this to us
your activities on, and use of, and preferences on the Libraro platform
your personal or professional interests
your professional online presence, e.g. LinkedIn profile – in the case of writers only we may collect biographical information, literary works and associated metadata

For all users we collect:

your contact history, purchase history and saved items
your interactions with the content on the Libraro platform, which may include telemetry data encompassing identifiers and log in information
information about how you use our website, the Libraro platform and other technology systems
your responses to surveys, competitions and promotions
if at all applicable, your billing information, transaction and payment card or other payment method information
bank account and payment details
details of any information, feedback or other matters you give to us by phone, email, post or via social media

Sometimes you can choose if you want to give us your personal data and let us use it. Where that is the case we will tell you and give you the choice before you give the personal data to us. We will also tell you whether declining to share that personal data will have any effect on your use of the website / Libraro.com platform or any part of them.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

How your personal data is collected

We collect personal data from you:

directly, when you enter or send us information, such as when you sign up for an account or login to the website, and
indirectly, such as your browsing activity while on our website; we will usually collect information indirectly using the technologies explained in our Cookies Policy.

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

where you have given consent
to comply with our legal and regulatory obligations, e.g. to prevent fraud
for the performance of a contract with you or to take steps at your request before entering into a contract, or
for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The table below explains what we use your personal data for and why.

What we use your personal data for	Our reasons
Creating and managing your account with us	To perform our contract with you or to take steps at your request before entering into a contract
Providing the website and services to you	To perform our contract with you or to take steps at your request before entering into a contract
Enforcing legal rights or defend or undertake legal proceedings	Depending on the circumstances: — to comply with our legal and regulatory obligations — in other cases, for our legitimate interests, ie to protect our business, interests and rights
Customising our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website	Depending on the circumstances: —your consent as gathered by the trusted third party providers we use to collect and analyse data on the website—see Cookie Policy—where we are not required to obtain your consent and do not do so, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price If you have provided such a consent you may withdraw it at any time by changing the settings on the cookie tool available on the home page of Libraro.com (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn)
Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended	Depending on the circumstances: —your consent as gathered using our trusted third party providers —see Cookie Policy —where we are not required to obtain your consent and do not do so, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you. If you have provided such a consent you may withdraw it at any time by (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn)
Communications with you not related to marketing, including about changes to our terms or policies or changes to the services or other important notices	Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best services to you.
Protecting the security of systems and data used to provide the services	To comply with our legal and regulatory obligations We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
Statistical analysis to help us understand our customer base	For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you.
Updating and enhancing customer records	Depending on the circumstances: —to perform our contract with you or to take steps at your request before entering into a contract —to comply with our legal and regulatory obligations —where neither of the above apply, for our legitimate interests, eg making sure that we can keep in touch with our customers about existing orders and new products
Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, eg to record and demonstrate evidence of your consents where relevant	To comply with our legal and regulatory obligations
Marketing our services to existing and former customers	For our legitimate interests, ie to promote our business to existing and former customers See ‘Marketing’ below for further information
To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. In such cases information will be anonymised where possible and only shared where necessary	Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets

How and why we use your personal data—in more detail

More details about how we use your personal data and why are set out in the table below

Purpose	Processing operation	Lawful basis relied on under the UK GDPR	Relevant categories of personal data
Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or other important notices	Addressing and sending communications to you as required by data protection laws, ie: the UK GDPR or Data Protection Act 2018	Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b))	your name, address and contact information, including – email address and telephone number and company details —your account details (username)
	Addressing and sending communications to you as required by applicable law	Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b))	—your name, address and contact information, including – email address and telephone number and company details
	Addressing and sending communications to you about changes to our terms or policies or changes to the products or other important notices (other than those addressed above)	Our legitimate interests (Article 6(1)(f)), which is to be as efficient as we can so we can deliver the best service to you	your name, address and contact information, including email address and telephone number and company details, your account details (username)

How and why we use your personal data sharing

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

What data other Libraro users see

Libraro platform is designed to help you share information with the Libraro community. Any personal information that you voluntarily choose to include in a publicly accessible area of the Libraro Platform will be available to anyone who has access to that content (including other Libraro users), such as your username, name, the profile description you create, picture, and your location, as well as the messages you post, whether on your profile or to other users, and the lists you create, people you follow, stories you write, and links to your other sites.

We may use this information to improve your experience of the Libraro platform and to customise the content we show you.

Submissions recorded on blockchain

The Libraro platform is designed to securely record every manuscript submission, providing an immutable, time-stamped proof of authorship and a permanent record of rights for the author. We do this through patented blockchain technology. It is important to note that files recorded on blockchain are immutable and permanent. In the event that you may wish to delete or amend data from the Libraro systems, you may exercise your rights in accordance with applicable law, however there are limitations as to what extent this can be done in respect of the permanent blockchain records which is beyond Libraro’s control. It is important to note that a person with the relevant access tools may be able to discover the submission on blockchain at a future date notwithstanding that all records may have been deleted within the Libraro platform.

Marketing

We will use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

contacting us; or
using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts,

We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

Who we share your personal data with

We routinely share personal data with:

third parties we use to help deliver our services to you, e.g. payment service providers;
other third parties we use to help us run our business, e.g. marketing agencies or website hosts and website analytics providers; and
our bank.

With respect to authors only, we may share personal data with publishing partners.

We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.

We or the third parties mentioned above occasionally also share personal data with:

our and their external auditors, e.g. in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations
our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations

The data you submit to the Libraro platform (e.g. reading preferences, comments) are anonymised and aggregated before being used in research, analytics, and commercial data services. No personally identifiable information (PII) will be shared or sold. Anonymised and aggregated data may be provided to third-party companies, research institutions, and other partners for analytics, insights, and commercial purposes

Who we share your personal data with further information

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

How long your personal data will be kept

We will not keep your personal data for longer than we need it for the purpose for which it is used.

If you stop using your account we will delete or anonymise your account data after two years. Following the end of the relevant retention period, we will delete your personal data unless otherwise dictated by applicable law and/or regulation.

Certain legal and compliance obligations may require that we retain a degree of information for up to 6 or 7 years (for instance tax requirements).

Transferring your personal data out of the UK and EEA

The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.

It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.

Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:

in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available on this link. We rely on adequacy regulations for transfers to the countries in the EEA;
in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. A list of countries the European Commission has currently made adequacy decisions in relation to is available here;
there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
a specific exception applies under relevant data protection law.

Libraro will take such measures as are necessary to ensure that any transfer is in compliance with the applicable law. Such measures may include (without limitation) entering into the UK’s International Data Transfer Agreement or the UK Addendum to the EU’s Standard Contractual Clauses.

If you would like further information about data transferred outside the UK/EEA, please contact us (see ‘How to contact us’ below).

Privacy law of California and other US states (if at all applicable)

Libraro operates in the United Kingdom, and it does not directly market to California residents. However, if you are a resident of California, the California Consumer Privacy Act (as amended by the CPRA) gives you additional rights in relation to personal information collected.

If “personal information” is collected and this information is “sold” or “shared” under the CCPA/CPRA (for example, in connection with certain advertising technologies), we will:

Disclose the categories of personal information collected, the purposes for which they are used, and the categories of third parties to whom they are disclosed, sold, or shared, in our Cookies Policy and/or this Privacy Policy.
Provide a clear and accessible “Do Not Sell or Share My Personal Information” mechanism (for example, via a link in the website footer or within the cookie banner), allowing California residents to opt out of the sale or sharing of their personal information.
Honour browser or device‑based Global Privacy Control (GPC) signals, where required, as an opt‑out request.

We may also apply similar opt‑out mechanisms to residents of other US states that have comparable privacy laws, where appropriate.

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with:

the Information Commissioner in the UK
a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA.

The UK’s Information Commissioner may be contacted using the details at ICO Complaints Form or by telephone: 0303 123 1113.

For a list of EEA data protection supervisory authorities and their contact details see the list of EU national data protection authorities.

How to contact us

Please contact us if you have any questions about this privacy policy or the information we hold about you.

You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

If you wish to contact us please send an email to [email protected].

Changes to this policy

We may change this policy from time to time to reflect usage or changes in applicable law and regulation. When we do we will inform you via email or placing a notice on the website.

This policy was published on 14.11.2023 and last updated on 1 January 2026 (version 2.0).

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