Privacy Policy
This Privacy Policy explains how Reonr collects, uses, stores, shares, protects, and otherwise processes personal data for hosting, domains, billing, security, support, websites, servers, and related infrastructure services.
Legal Review Notice
Prepared as a business legal draft. Review with qualified legal counsel before publication or formal reliance.
1. Introduction
This Privacy Policy explains how Reonr Limited, trading as Reonr, collects, uses, stores, shares, protects, and otherwise processes personal data when you use Reonr websites, client area, hosting services, domain services, support services, billing systems, email services, DNS services, server services, and related products.
This Policy is intended to support compliance with applicable privacy and data protection laws, including the Nigeria Data Protection Act, 2023, where that law applies to Reonr's processing activities.
This Policy applies to customers, prospective customers, account users, administrators, domain registrants, billing contacts, technical contacts, support contacts, website visitors, and any other person whose personal data is processed in connection with Reonr services.
2. Controller Information
The data controller for Reonr account, billing, domain, support, security, website, and service administration data is Reonr Limited, trading as Reonr.
Business address: Port Harcourt, Rivers, Nigeria. Privacy contact: [email protected]. Legal contact: [email protected]. Support contact: [email protected]. Abuse contact: [email protected].
Where Reonr processes personal data on behalf of a customer, such as data stored inside a customer's hosted website, application, database, email mailbox, server, or backup, Reonr may act as a data processor or service provider for that customer. In those cases, the customer remains responsible for determining the purpose, instructions, lawful basis, notices, and compliance requirements for that data.
3. Scope of This Policy
This Policy covers personal data processed in connection with Web Hosting, cPanel Hosting, WordPress Hosting, VPS Hosting, Dedicated Servers, Cloud Hosting, Reseller Hosting, Plesk and DirectAdmin control panel licenses, Domain Registration, Domain Transfer, DNS Management, Email services, SSL, Backups, Website migration, Support services, billing, fraud prevention, account administration, and service communications.
This Policy does not control the privacy practices of customer websites hosted on Reonr infrastructure. Customers are responsible for their own privacy policies, cookie notices, data collection practices, and legal compliance for websites, applications, email lists, stores, forms, and systems they operate.
4. Personal Data We Collect
Reonr may collect account data, including name, company name, username, password hash, email address, phone number, billing address, country, account status, login history, account preferences, and authorized user details.
Reonr may collect billing and transaction data, including invoices, payment status, payment method reference, currency, billing cycle, tax details, credit balance, transaction identifiers, fraud-screening information, chargeback records, and payment gateway responses.
Reonr may collect domain data, including domain names, registrant name, organization, address, email address, phone number, administrative contact, technical contact, nameservers, DNS records, authorization codes where applicable, domain verification information, transfer status, renewal status, and registry or registrar responses.
When you use Domain Appraisals, Reonr records the searched domain, result status, estimate or range, display currency, model version, selected scoring factors, and response time. The dedicated appraisal log does not record your IP address, account ID, email address, session ID, or browser details.
Reonr may collect service data, including hosting package, server IP address, control panel username, assigned resources, service configuration, DNS zones, SSL status, backup status, migration records, support history, product settings, add-ons, and technical logs.
Reonr may collect support data, including tickets, live chat messages, emails, call notes, screenshots, attachments, access credentials voluntarily provided for support, diagnostic reports, and communications with Reonr staff.
Reonr may collect technical and security data, including IP addresses, browser type, device type, operating system, user agent, login attempts, API requests, firewall logs, email logs, access logs, error logs, abuse reports, malware scan results, spam reports, fraud signals, and audit records.
5. Data You Provide Through Hosted Services
Customers may upload, store, transmit, or process personal data through websites, databases, email accounts, applications, servers, backups, and reseller accounts hosted by Reonr.
Reonr does not decide what personal data customers place inside their websites, applications, mailboxes, databases, or servers. Customers are responsible for ensuring they have a lawful basis to collect and process that data, providing privacy notices to their users, responding to data subject requests, and complying with applicable data protection laws.
6. How We Collect Personal Data
We collect personal data directly from you when you create an account, place an order, pay an invoice, register or transfer a domain, submit a ticket, request migration, configure DNS, subscribe to services, contact support, or update account information.
We collect personal data automatically through server logs, cookies, security systems, analytics, fraud-prevention tools, payment systems, client area sessions, control panels, monitoring systems, and email systems.
We may receive personal data from third parties such as payment gateways, domain registrars, domain registries, fraud-prevention providers, data centers, control panel vendors, SSL providers, security vendors, software vendors, support tools, resellers, and abuse reporters.
7. Lawful Bases for Processing
Depending on the jurisdiction and processing activity, including where the Nigeria Data Protection Act, 2023 applies, Reonr may rely on one or more lawful bases, including performance of a contract, compliance with legal obligations, legitimate business interests, consent, protection of vital interests, public-interest or regulatory requirements where applicable, or another lawful basis recognized under applicable data protection law.
Contractual processing includes account creation, order processing, hosting provision, domain registration, DNS management, SSL issuance, support, billing, renewals, migrations, backups, and service administration.
Legal obligation processing may include tax records, accounting, fraud prevention, law enforcement requests, regulatory compliance, domain authority requirements, sanctions screening, and dispute handling.
Legitimate interest processing may include service security, abuse prevention, network protection, fraud detection, customer support, service improvement, business records, internal administration, and enforcement of legal rights, provided those interests are not overridden by applicable data protection rights.
Consent-based processing may apply to optional marketing, non-essential cookies, certain communications, or processing activities where consent is legally required.
8. Purposes of Processing
Reonr processes personal data to provide services, create and manage accounts, process orders, issue invoices, receive payments, register domains, transfer domains, manage DNS, issue SSL certificates, provide hosting, provision servers, perform migrations, maintain backups, provide support, prevent abuse, detect fraud, secure systems, communicate service notices, comply with law, resolve disputes, and improve services.
We may also process data to investigate malware, spam, phishing, unauthorized access, network attacks, copyright complaints, domain abuse, server abuse, email abuse, payment abuse, chargebacks, policy violations, or suspicious activity.
Reonr uses appraisal search records to check result quality, find model errors, measure coverage, and improve later appraisal models.
9. Domain Registrant Data
Domain registration and transfer services require the processing of domain registrant data. This may include registrant name, organization, address, email address, phone number, administrative contact, technical contact, nameservers, and other information required by registrars, registries, ICANN, NiRA, or other domain authorities.
Domain registrant data may be shared with registrars, registries, escrow providers, verification providers, WHOIS/RDAP systems, domain dispute providers, and domain authorities where required to register, renew, transfer, verify, maintain, investigate, or recover domain names.
Some registrant data may be published or made available through WHOIS, RDAP, registry systems, registrar systems, or lawful disclosure processes depending on the domain extension, registry rules, privacy/proxy availability, and applicable law.
10. Payment and Billing Data
Reonr may use third-party payment gateways to process payments. Reonr does not need to store full card numbers where a payment gateway processes card payments directly. Payment gateways may process card details, bank details, wallet details, authentication data, fraud data, and transaction information under their own terms and privacy policies.
Reonr may store transaction references, invoice status, payment method type, gateway response, billing history, credit balance, refund status, tax records, fraud review data, and dispute records.
11. Support and Migration Access
When you request technical support, migration, troubleshooting, malware review, or configuration assistance, you may provide Reonr with access credentials, screenshots, database exports, files, admin panel details, DNS access, control panel access, or server access.
Reonr will use such information only for the support or service purpose for which it was provided, unless additional processing is required for security, abuse investigation, legal compliance, or dispute resolution.
You should avoid sending unnecessary sensitive information. Where possible, create temporary access for support and revoke it after the support task is complete.
12. Server Logs and Security Records
Hosting and server services generate logs. Logs may include IP addresses, request URLs, timestamps, email metadata, login attempts, system events, firewall events, control panel activity, DNS activity, error reports, bandwidth records, and abuse indicators.
Reonr uses logs to operate services, troubleshoot issues, detect abuse, prevent attacks, investigate incidents, measure performance, enforce limits, and protect customers and infrastructure.
14. Marketing Communications
Reonr may send service-related communications, including invoices, renewal notices, suspension notices, security alerts, support updates, domain notices, maintenance notices, and policy updates. These are operational communications and may be necessary to provide services.
Reonr may send marketing communications where permitted by law or where you have opted in. You may unsubscribe from marketing communications, but you may still receive service, billing, legal, security, and account-related messages.
15. Fraud Prevention and Risk Screening
Reonr may process personal data to detect and prevent fraud, payment abuse, identity misuse, chargebacks, spam orders, domain abuse, server abuse, account takeover, sanctions risk, and other harmful activity.
This may include review of IP address, billing details, payment signals, email reputation, order pattern, device data, location information, account history, domain choices, and third-party fraud-screening responses.
Reonr may reject, delay, suspend, or manually review orders where fraud or abuse risk is detected.
16. Abuse Investigation
Reonr may process personal data when investigating spam, phishing, malware, network attacks, copyright complaints, illegal content, domain abuse, server compromise, email abuse, payment abuse, or policy violations.
This may include account data, service data, server logs, email logs, DNS records, domain records, support communications, abuse reports, screenshots, files, malware scan results, and third-party evidence.
18. Third-Party Provider Responsibilities
Third-party providers may process personal data under their own terms and privacy policies. Examples include registrars, registries, payment gateways, SSL certificate authorities, control panel vendors, data centers, security vendors, and software providers.
Reonr is not responsible for the independent privacy practices of third parties where they act as separate controllers, but Reonr will take reasonable steps to use reputable providers appropriate for the service.
19. International Transfers
Because hosting, domains, payment processing, security tools, registrars, registries, data centers, software vendors, and support systems may operate across borders, personal data may be transferred to or processed in countries outside your country of residence.
Where required by applicable law, Reonr will rely on appropriate transfer mechanisms, contractual safeguards, lawful exceptions, adequacy decisions, customer instructions, or other recognized legal bases for international transfers.
20. Data Retention
Reonr keeps personal data only as long as reasonably necessary for the purposes described in this Policy, including service delivery, account management, billing, tax, accounting, legal compliance, fraud prevention, abuse handling, security, domain management, dispute resolution, and enforcement of agreements.
Account and billing records may be retained for tax, accounting, audit, and legal purposes after account closure. Support records may be retained to maintain service history and resolve disputes. Security and abuse logs may be retained to investigate incidents and protect infrastructure.
Raw Domain Appraisal search records are kept for up to 12 months, unless a longer period is required by law.
Customer-hosted data may be deleted after service cancellation, suspension, termination, non-payment, migration, or expiry according to the applicable service process. Backup copies may remain for a limited period until overwritten or purged.
21. Data Deletion
You may request deletion of personal data where applicable. Reonr may decline or limit deletion where data is required for legal compliance, accounting, fraud prevention, abuse investigation, domain obligations, dispute handling, security, or enforcement of contractual rights.
Deletion of account data may require cancellation of active services. Deletion of domain registrant data may not be possible while a domain remains active or where registry, registrar, escrow, or legal obligations require retention.
22. Customer Control of Hosted Data
Customers are responsible for managing, exporting, correcting, deleting, securing, and backing up personal data stored inside their hosted services, websites, applications, servers, mailboxes, databases, and reseller accounts.
Reonr may not be able to search, edit, export, or delete customer-controlled hosted data unless the customer provides access, the request is technically feasible, and the request is within the scope of support or legal obligations.
23. Data Security
Reonr uses appropriate technical, administrative, and organizational measures intended to protect personal data against unauthorized access, loss, misuse, alteration, disclosure, or destruction.
These measures may include access controls, password hashing, firewalls, monitoring, malware scanning, backups, encryption where appropriate, audit logs, staff access restrictions, account verification, and security review processes.
No internet, hosting, email, payment, DNS, or server system can be guaranteed to be completely secure. Customers must also secure their own accounts, passwords, websites, applications, devices, plugins, themes, databases, servers, and users.
24. Security Incidents
If Reonr becomes aware of a security incident affecting personal data, Reonr will assess the incident and take reasonable steps to contain, investigate, remediate, and notify affected parties or authorities where required by applicable law.
Customers must promptly notify Reonr at [email protected] or [email protected] if they suspect unauthorized access, malware, phishing, compromised credentials, exposed data, or abuse involving their services.
25. Data Subject Rights
Depending on applicable law, including the Nigeria Data Protection Act, 2023 where applicable, you may have rights to access, correct, delete, restrict, object to processing, withdraw consent, request portability, lodge a complaint with a data protection authority, or request information about processing.
Requests should be sent to [email protected]. Reonr may need to verify your identity before responding. Some rights may be limited by legal obligations, contractual obligations, domain rules, security needs, fraud prevention, abuse investigation, or technical feasibility.
26. Consent Withdrawal
Where processing is based on consent, you may withdraw consent at any time. Withdrawal does not affect processing that occurred before withdrawal and does not affect processing based on contract, legal obligation, legitimate interest, or another lawful basis.
Withdrawing consent for optional marketing or non-essential cookies will not stop necessary service communications or essential service processing.
27. Accuracy of Information
You are responsible for keeping account, billing, domain registrant, administrative, technical, and support contact information accurate and current.
Failure to maintain accurate information may result in failed renewals, failed domain verification, suspension, loss of domain rights, inability to receive notices, failed support verification, billing issues, or account restrictions.
28. Children's Data
Reonr services are intended for business, professional, and adult users. Reonr does not knowingly sell services directly to children.
Customers must not use Reonr services to collect children's personal data unless they have a lawful basis, proper consent where required, and appropriate safeguards under applicable law.
29. Reseller and Customer End Users
If you are a reseller or operate services for your own users, you are responsible for privacy notices, lawful processing, consent management, data subject requests, security, and compliance for your customers and end users.
Reonr may process limited data relating to reseller sub-accounts or end users where necessary to provide infrastructure, support, security, abuse handling, billing, or legal compliance.
30. Business Transfers
If Reonr is involved in a merger, acquisition, financing, restructuring, sale of assets, transfer of services, or similar transaction, personal data may be transferred as part of that transaction, subject to reasonable confidentiality and continuity protections.
31. Legal Requests and Disclosure
Reonr may disclose personal data where it believes disclosure is required or permitted by law, court order, regulatory request, law enforcement request, domain authority request, tax obligation, payment dispute, abuse investigation, or to protect rights, safety, security, infrastructure, customers, or third parties.
Where legally permitted and appropriate, Reonr may challenge, narrow, or request clarification of disclosure requests.
32. Automated Processing
Reonr may use automated or semi-automated systems for fraud detection, order screening, spam filtering, malware detection, rate limiting, security monitoring, payment risk review, domain lookup, and abuse detection.
Where an automated result materially affects an order or service, Reonr may conduct manual review where appropriate and feasible.
33. Links to Third-Party Websites
Reonr websites, support materials, invoices, emails, or client area pages may link to third-party websites. Reonr is not responsible for the privacy practices, security, content, or policies of third-party websites.
34. GDPR: EEA and UK Visitors
This section applies only where the EU General Data Protection Regulation (GDPR) or the UK GDPR applies to Reonr's processing of your personal data, for example because you are located in the European Economic Area or the United Kingdom and Reonr offers services to you or monitors your behavior.
Where GDPR or UK GDPR applies, Reonr processes personal data on the lawful bases described in "Lawful Bases for Processing" above, including performance of a contract, compliance with a legal obligation, legitimate interests, and consent where required.
Where GDPR or UK GDPR applies, you have the right to request access to your personal data, correction of inaccurate data, erasure, restriction of processing, data portability, and an objection to processing based on legitimate interests or direct marketing. Where processing relies on consent, you may withdraw consent at any time without affecting processing carried out before withdrawal. Requests should be sent to [email protected] and may require identity verification.
Where personal data is transferred outside the EEA or UK, Reonr will rely on an adequacy decision, standard contractual clauses, or another transfer mechanism recognized under GDPR or UK GDPR, consistent with the "International Transfers" section above.
If you are located in the EEA or UK and believe your rights under GDPR or UK GDPR have not been respected, you have the right to lodge a complaint with your local supervisory authority, in addition to contacting Reonr directly using the details in the "Contact and Complaints" section below.
35. Changes to This Policy
Reonr may update this Privacy Policy from time to time to reflect legal, operational, technical, or business changes. The updated version will be posted with a revised Last Updated date.
Where required by law or where changes are material, Reonr may provide additional notice through the website, client area, email, or other reasonable method.
36. Contact and Complaints
Business address: Port Harcourt, Rivers, Nigeria.
Privacy questions and requests should be sent to [email protected]. Legal notices should be sent to [email protected]. Support issues should be sent to [email protected]. Abuse reports should be sent to [email protected].
If you believe your privacy rights have been violated, you may contact Reonr first so the issue can be reviewed. Depending on applicable law, you may also have the right to contact the Nigeria Data Protection Commission or another competent data protection authority.