In order to use the service, we will ask you to enter information about your reading preferences, name, email. We also automatically collect from your device language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and other unique identifiers (such as IDFA and AAID). We need this data to provide our services, analyze how our customers use the service, to serve ads.

For improving our service and serving ads, we use third party solutions. As a result, we may process data using solutions developed by Amazon, Facebook, Google, Twitter, Appsflyer, Amplitude, Firebase, Snapchat, Pinterest, Apple, BigQuery, Sendios, TikTok. Some of the data is stored and processed on servers of such third parties. This enables us to: (1) analyze different interactions (how often users make subscriptions, what is the most popular users’ reading goal, what is the average time spent by users on reading); (2) serve ads (and are able to show them only to a particular group users, for example, to subscribers). Consequently, we, in particular, better understand in what of our features and content you see the most value and are able to focus on them to enhance your experience and increase the quality of our products.

Please read our Privacy Policy below to know more about what we do with data (Section 2), what data privacy rights are available to you (Section 5), who will be the data controller (Section 12), and how to influence personalized advertising (Subsection 2.7). If any questions will remain unanswered, please contact us at support@get-headway.com.


This Privacy Policy explains what personal data is collected when you use the Headway: Books’ Key Ideas mobile application (the “App”), our Headway website (the “Website”) and the services provided through them (together with the App and the Website, the “Service”), how such personal data will be used, shared.

BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 16 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU). If you do not agree, or are unable to make this promise, you must not use the Service. In such case, you must (a) delete your account using the functionality found in “Settings” in the App or the Website, or contact us and request deletion of your data; (b) cancel any subscriptions depending on how you subscribed (using the functionality provided by Apple or Google if you subscribed via an app store; or the functionality of our Website if you purchased subscription via the Website); and (c) delete the App from your device(s).

“GDPR” means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

“EEA” includes all current member states to the European Union and the European Economic Area. For the purpose of this policy EEA shall include the United Kingdom of Great Britain and Northern Ireland.

“Process”, in respect of personal data, includes to collect, store, and disclose to others.



    We collect data you give us voluntarily (for example, when you enter your reading preferences, name, email). We also may receive data about you from third parties (for example, when you sign in via Google). We also collect data automatically (for example, your IP address) and use third-party service providers for such collection.

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    1. Data you give us

      You provide us information about yourself when you register for and/or use the Service. For example, reading preferences, name, email address.

    2. Data provided to us by third parties

      When you decide to log in using Google, we get personal data from your Google account. This includes your email, name, profile image, and Google ID.

      You can revoke access provided to us on Apps Permissions page. To know more about how Google processes your data, visit its Privacy Policy. When you use Sign in with Apple to register an account in the App, we get personal data from your Apple ID account. This data may include, in particular, your name and verified email address. You may choose to share your real email address or an anonymous one that uses the private email relay service. Apple will show you their detailed privacy information on the Sign in with Apple screen. Find more about Sign in with Apple here. Apple lets you revoke access provided to the App in your Apple ID settings by following the next steps.

    3. Data we collect automatically:

      1. Data about how you found us

        We collect data about your referring app or URL (that is, the app or place on the Web where you were when you tapped on our ad).

      2. Device and Location data

        We collect data from your device. Examples of such data include: language settings, IP address, time zone, type and model of a device, device settings, operating system and its version, Internet service provider, mobile carrier, hardware ID, and Facebook ID.

      3. Usage data

        We record how you interact with our Service. For example, we log your taps/clicks on certain areas of the interface, the features, and content you interact with, how often you use the Service, how long you are in the Service, and your subscription orders. We also record the ads in our App or Website with which you interact (and the Internet links to which those adds lead).

      4. Advertising IDs

        We collect your Apple Identifier for Advertising (“IDFA”) or Google Advertising ID (“AAID”) (depending on the operating system of your device). You can typically reset these numbers through the settings of your device’s operating system (but we do not control this).

      5. Transaction data

        When you make payments through the Service, you need to provide financial account data, such as your credit card number, to our third-party service providers. We do not collect or store full credit card number data, though we may receive credit card-related data, data about the transaction, including: date, time and amount of the transaction, the type of payment method used.

      6. Cookies

        A cookie is a small text file that is stored on a user's computer for record-keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our Service. A persistent cookie remains on your hard drive for an extended period of time. We also use tracking pixels that set cookies to assist with delivering online advertising.

        Cookies are used, in particular, to automatically recognize you the next time you visit our website. As a result, the information, which you have earlier entered in certain fields on the website may automatically appear the next time when you use our Service. Cookie data will be stored on your device and most of the times only for a limited time period.


    We process your personal data:

    1. To provide our Service

      This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues.

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      To host personal data and enable our Website to operate and be distributed we use Digital Ocean and Google Cloud, which are hosting and backend services.

      We use Firebase Performance Monitoring and Firebase Crash Reporting, which are monitoring services provided by Google. To learn more, please visit Google’s Privacy policy and Privacy and Security in Firebase.

      To monitor infrastructure and the Service’s performance, we use Crashlytics, which is a monitoring service provided by Google. Data Collection Policy.

    2. To customize your experience

      We process your personal data, such as reading preferences, to adjust the content of the Service and make offers tailored to your personal preferences. As a result of such processing, we will show in the App more books from, for example, “Motivation & Inspiration” category.

    3. To manage your account and provide you with customer support

      We process your personal data to respond to your requests for technical support, service information or to any other communication you initiate. This includes accessing your account to address technical support requests. For this purpose, we may send you, for example, notifications or emails about the performance of our Service, security, payment transactions, notices regarding our Terms and Conditions of Use or this Privacy Policy.

    4. To communicate with you regarding your use of our Service

      We communicate with you, for example, by push notifications or by emails. These may include reminders and motivational messages encouraging you to continue reading, or other information about the Service. As a result, you may, for example, receive a push notification every day at a particular time reminding you to read. To opt out of receiving push notifications, you need to change the settings on your device.To opt-out of receiving emails, you should click unsubscribe link in the footer of our email.

      See more

      The services that we use for these purposes may collect data concerning the date and time when the message was viewed by our App’s users, as well as when they interacted with it, such as by clicking on links included in the message.

      To communicate with you we use Firebase Cloud Messaging and Firebase Notifications, which are message sending services provided by Google. Firebase Cloud Messaging allows us to send messages and notifications to users of our App across platforms such as Android and iOS. We integrate Firebase Notifications with Firebase Analytics to create analytics-based audiences and track opening and conversion events. As a result, we can, for example, send encouraging messages to users who have recently installed the App. Google's privacy policy.

    5. To research and analyze your use of the Service

      This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what features and categories of books our users like more, what categories of users use our App. As a consequence, we often decide how to improve the App based on the results obtained from this processing. For example, if we discover that users more often read book summaries from “Productivity & time management” category, we may create and introduce more of book summaries into this category.

      See more

      To perform research and analysis about how users interact with our App we use Appsflyer. Appsflyer enables us to understand, in particular, how users find us (for example, who was the advertiser that delivered an ad to users, which led you to an app store with our App). Appsflyer also provides us with different analytics tools that enable us to research and analyze your use of the Service. Privacy policy. Opt Out.

      We also use Sendios, which is a marketing personalization and retention platform, to deliver tailored email messages to our users.

      We use Facebook Analytics, which is a service provided by Facebook that allows us to use different analytical tools. On Facebook Analytics we get, in particular, aggregated demographics and insights on how many people access the Service, how often users make purchases, and other users’ interactions within the Service. Privacy policy.

      To analyse how visitors use our Service and to measure effectiveness of some ads we use Google Analytics, a web analysis program of Google. In order to provide us with analytics, Google Analytics places cookies on your device. On Google Analytics we get, in particular, aggregated information on the data you enter on our Service and users’ interactions within the Service. Google allows you to influence the collection and processing of information generated by the Google, in particular, by installing a browser plug-in, available here.

      We also use Amplitude, which is an analytics service provided by Amplitude Inc. We use this tool to understand how customers use our Service. Amplitude collects various technical information, in particular, time zone, type of device (phone or tablet), unique identifiers (such as IDFA). Amplitude also allows us to track various interactions (entering your reading goals) that occur on the App or the Website. As a result, Amplitude helps us to decide what features should we focus on. Amplitude is EU-US Privacy Shield certified. Amplitude provides more information on how they process data in its Privacy Policy.

      To track and analyze behavior of our Service’s users (in particular, how they react to changes of the App’s or Website’s structure, text or any other component), we use Firebase Remote Config. Firebase Remote Config is an A/B testing and configuration service provided by Google. Privacy Policy and Privacy and Security in Firebase.

      We also use Firebase Analytics, which is an analytics service provided by Google. In order to understand Google's use of data, consult Google's partner policy. Firebase Privacy information. Google’s Privacy Policy.

    6. To send you marketing communications

      We process your personal data for our marketing campaigns. We may add your email address to our marketing list. As a result, you will receive information about our products, such as for example, special offers. If you do not want to receive marketing emails from us, you can unsubscribe following instructions in the footer of the marketing emails.

      We may also show you advertisements in our App or Website, and send you push notifications for marketing purposes. To opt out of receiving push notifications, you need to change the settings on your device.

    7. To personalize our ads

      We and our partners, including Facebook and Google, use your personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you have installed our App, you might see ads of our products, for example, in your Facebook’s feed.

      How to opt out or influence personalized advertising

      iOS: On your iPhone or iPad, go to “Settings,” then “Privacy” and tap “Advertising” to select “Limit Ad Track”. In addition, you can reset your advertising identifier (this also may help you to see less of personalized ads) in the same section.

      Android: To opt-out of ads on an Android device, simply open the Google Settings app on your mobile phone, tap “Ads” and enable “Opt out of interest-based ads”. In addition, you can reset your advertising identifier in the same section (this also may help you to see less of personalized ads).

      macOS: On your MacBook, you can disable personalized ads: go to System Preferences > Security & Privacy > Privacy, select Apple Advertising, and deselect Personalized Ads.

      Windows: On your laptop running Windows 10, you shall select Start > Settings > Privacy and then turn off the setting for Let apps use advertising ID to make ads more interesting to you based on your app activity. If you have other Windows version, please follow the steps here.

      To learn even more about how to affect advertising choices on various devices, please look at the information available here.

      In addition, you may get useful information and opt out of some interest-based advertising, by visiting the following links:

      Browsers:It is also may be possible to stop your browser from accepting cookies altogether by changing your browser’s cookie settings. You can usually find these settings in the “options” or “preferences” menu of your browser. The following links may be helpful, or you can use the “Help” option in your browser.

      • Cookie settings in Internet Explorer

      • Cookie settings in Firefox

      • Cookie settings in Chrome

      • Cookie settings in Safari web and iOS

      Google allows its users to opt out of Google’s personalized ads and to prevent their data from being used by Google Analytics.

      See more

      We value your right to influence the ads that you see, thus we are letting you know what service providers we use for this purpose and how some of them allow you to control your ad preferences.

      We use Facebook pixelon the Service. Facebook pixel is a code placed on the Service collecting data that helps us track conversions from Facebook Ads, build targeted audience and remarket to people who have taken some actions on the Service (for example, made a purchase).

      We use Facebook Ads Manager together with Facebook Custom Audience, which allows us to choose audiences that will see our ads on Facebook or other Facebook’s products (for example, Instagram). Through Facebook Custom Audience we may create a list of users with certain sets of data, such as an IDFA, choose users that have completed certain actions in the App (for example, installed it). As a result, we may ask Facebook to show some ads to a particular list of users. As a result, more of our ads may show up while you are using Facebook or other Facebook’s products (for example, Instagram). You may learn how to opt out of advertising provided to you through Facebook Custom Audience here.

      Facebook also allows its users to influence the types of ads they see on Facebook. To find how to control the ads you see on Facebook, please go here or adjust your ads settings on Facebook.

      Google Ads is an ad delivery service provided by Google that can deliver ads to users. In particular, Google allows to us to tailor the ads in way that they will appear, for example, only to users that have conducted certain actions with our App (for example, show our ads to users who have purchased a subscription). Some other examples of events that may be used for tailoring ads include, in particular, installing our App. Google allows its users to opt out of Google’s personalized ads and to prevent their data from being used by Google Analytics.

      We also use Twitter Ads provided by Twitter to deliver advertising. Twitter Ads allows us to choose specific audiences based on geographic areas or user’s interests. As a result, we may ask Twitter to deliver our ads to certain list of users. Twitter allows you to opt-out its internet-based advertising. Privacy Policy.

      We use Pinterest Ads to deliver group-based advertisements. For example, you may see our ads if you are interested in specific services, information, or offers. For more information, please refer to the Pinterest Privacy Policy.

      TikTok Ads is the service provided by TikTok that can deliver ads to its users. The ads can be tailored to specific categories of users (for instance, based on their geographical location). For more information, please refer to TikTok’s Privacy Policy.

      We also use Snapchat Advertising Platform together with Snapchat Audience Based Match, which is an ad delivery service provided by Snapchat that can link the activity of some users of our Service with the Snapchat advertising network and show some of our ads to them. As a result, you may see more of ads on Snapchat in case you use our Service. Snapchat allows you to Opt Out of their audience based ads. Privacy Policy.

    8. To process your payments

      We provide paid products and/or services within the Service. For this purpose, we use third-party services for payment processing (for example, payment processors). As a result of this processing, you will be able to make a payment for a subscription and we will be notified that the payment has been made.

      We will not store or collect your payment card details ourselves. This information will be provided directly to our third-party payment processors.

      We use Stripe to process your payments on the Website. Privacy Policy.

    9. To enforce our Terms and Conditions of Use and to prevent and combat fraud

      We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms and Conditions of Use).

    10. To comply with legal obligations

      We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.


    In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 2. This section applies only to EEA-based users.

    We process your personal data under the following legal bases:

    1. 3.1 your consent;
    2. Under this legal basis we will send you marketing emails. You have the right to withdraw your consent at any time by clicking on unsubscribe link in the footer of our marketing emails.

    3. 3.2 to perform our contract with you;

      Under this legal basis we:

      • Provide our Service (in accordance with our Terms and Conditions of Use)
      • Customize your experience
      • Manage your account and provide you with customer support
      • Communicate with you regarding your use of our Service
      • Process your payments
    4. for our (or others') legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data;

      We rely on legitimate interests:
      • to communicate with you regarding your use of our Service
      This includes, for example, sending you push notifications proposing you to read a new book summary. The legitimate interest we rely on for this purpose is our interest to encourage you to use our Service more often. We also take into account the potential benefits to you of reading more of book summaries, which may help you to advance in life and career.

      • to research and analyze your use of the Service
      Our legitimate interest for this purpose is our interest in improving our Service so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the use of the App easier and more enjoyable, or to introduce and test new features).

      • to send you marketing communications
      The legitimate interest we rely on for this processing is our interest to promote our Service in a measured and appropriate way.

      • to personalize our ads
      The legitimate interest we rely on for this processing is our interest to promote our Service in a reasonably targeted way.

      • to enforce our Terms and Conditions of Use and to prevent and combat fraud
      Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorised use of the Service, non-compliance with our Terms and Conditions of Use.

    5. to comply with legal obligations.

    We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular, for purposes indicated in Section 2 of this Privacy Policy. The types of third parties we share information with include, in particular:

    1. Service providers

      We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We share your personal information with the following types of service providers:
      • cloud storage providers (Google, Digital Ocean)
      • data analytics providers (Facebook, Google, Appsflyer, Firebase, Amplitude)
      • measurement partners
      • marketing partners (in particular, social media networks, marketing agencies, email delivery services, Facebook, Google, Twitter, TikTok, Snapchat, Pinterest, Sendios)
      • payment processing providers(Stripe)
      • communication services providers

    2. Law enforcement agencies and other public authorities

      We may use and disclose personal data to enforce our Terms and Conditions of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

    3. Third parties as part of a merger or acquisition

      As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.


    To be in control of your personal data, you have the following rights:

    Accessing / reviewing / updating / correcting your personal data. You may request a copy of your personal data and request us to update/correct your personal data collected during your use of the Service at support@get-headway.com.

    Deleting your personal data. You can request erasure of your personal data by sending us an email at support@get-headway.com.

    When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases we may be legally required to keep some of the data for a certain time; in such event, we will fulfill your request after we have complied with our obligations.

    Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof by sending a request at support@get-headway.com.

    Additional information for EEA-based users

    Additional information for EEA-based users.

    If you are based in the EEA, you have the following rights in addition to the above:

    The right to lodge a complaint with supervisory authority. We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or where the alleged infringement has taken place.

    The right to data portability. If you wish to receive your personal data in a machine-readable format, you can send respective request at support@get-headway.com


    We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us at support@get-headway.com.


    We do business globally. We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms and Conditions of Use and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards.

    In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details available here), or (ii) the EU-U.S. Privacy Shield Framework (details available here), or (iii) the European Commission adequacy decisions about certain countries (details available here).


    We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified through our Service or by other available means and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.


    California’s Shine the Light law gives California residents the right to ask companies once a year what personal information they share with third parties for those third parties' direct marketing purposes. Learn more about what is considered to be personal information under the statute.

    To obtain this information from us, please send an email message to support@get-headway.com which includes “Request for California Shine the Light Privacy Information” on the subject line and your state of residence and email address in the body of your message. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

    Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.


    We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Service to you), which includes (but is not limited to) the period during which you have an account with the Service. We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.


    Except as otherwise stipulated in this Privacy Policy, this App does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.


    GTHW App Limited, a company registered in the Republic of Cyprus (with registered office at Florinis 7, Greg Tower, 2nd Floor, 1065, Nicosia, Cyprus) will be the controller of your personal data.


    You may contact us at any time for details regarding this Privacy Policy and its previous versions. For any questions concerning your account or your personal data please contact us at support@get-headway.com.

Effective as of: 20 January 2021