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HEADWAY: FUN & EASY GROWTH

In order to use the services, 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 ourservice and serving ads, we use third party solutions. As a
result, we may process data using solutions developed by Facebook, Google,
Twitter, Appsflyer, Amplitude, Firebase, Snapchat, Pinterest, Apple, Digital
Ocean, Vercel, Iterable, Zendesk, PayPal, Stripe, Microsoft, Tableau, 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 to show them only to a
particular group of 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 14), and how to influence personalized
advertising (Subsection 2.8). If any questions will remain unanswered, please
contact us at support@get-headway.com.


PRIVACY POLICY

This Privacy Policy explains what personal data is collected when you use the
Headway: Fun & Easy Growth mobile application (“App”), our website located at
https://makeheadway.com/ (the “Website”) and related services (together with App
and the Website, the “Services”), how such personal data will be used, shared or
otherwise processed.

BY USING THE SERVICES, 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 Services.
In such case, you must (a) delete your account using the functionality found in
“Settings” in 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 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.

Table of contents

 1.  CATEGORIES OF PERSONAL DATA WE COLLECT

 2.  FOR WHAT PURPOSES WE PROCESS PERSONAL DATA

 3.  UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (Applies only to
     EEA-based users)

 4.  WITH WHOM WE SHARE YOUR PERSONAL DATA

 5.  HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS

 6.  AGE LIMITATION

 7.  INTERNATIONAL DATA TRANSFERS

 8.  CHANGES TO THIS PRIVACY POLICY

 9.  SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

 10. SUPPLEMENTAL NOTICE FOR VIRGINIA RESIDENTS

 11. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS

 12. DATA RETENTION

 13. HOW “DO NOT TRACK” REQUESTS ARE HANDLED

 14. PERSONAL DATA CONTROLLER

 15. CONTACT US


1. CATEGORIES OF PERSONAL DATA WE COLLECT

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.

SEE MORE


2. FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA

We process your personal data:

2.1 To provide our Services

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

SEE MORE

2.2 To customize your experience

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

2.3 To manage your account

We process your personal data to secure your accessing personal account and send
you technical notifications or emails about the performance of our Services,
security, payment transactions, notices regarding our Terms and Conditions of
Use or this Privacy Policy.

2.4 To communicate with you regarding your use of our Services

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 Services. 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

2.5 To provide you with customer support

We process your personal data to respond to your requests for technical support.

SEE MORE

2.6 To research and analyze your use of the Services

This helps us to better understand our business, analyze our operations,
maintain, improve, innovate, plan, design, and develop the Services 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
Services. As a consequence, we often decide how to improve the Services based on
the results obtained from this processing. For example, if we discover that
users more often read book summaries from “Productivity” category, we may create
and introduce more of book summaries into this category.

SEE MORE

2.7 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 send you push notifications for marketing purposes. To opt out of
receiving push notifications, you need to change the settings on your device.

SEE MORE

2.8 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 > Privacy & Security > Apple
Advertising and deselect Personalized Ads.

Android: To opt-out of ads on an Android device, go to Settings > Privacy > Ads
and enable Opt out of Ads personalization. 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.

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)



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:

 * Network Advertising Initiative – http://optout.networkadvertising.org/

 * Digital Advertising Alliance – http://optout.aboutads.info/

 * Digital Advertising Alliance (Canada) – http://youradchoices.ca/choices

 * Digital Advertising Alliance (EU) – http://www.youronlinechoices.com/

 * DAA AppChoices page – http://www.aboutads.info/appchoices



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

2.9 To process your payments

We provide paid products and/or services within the Services. 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.

SEE MORE

2.10 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).

2.11 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.


3. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (APPLIES ONLY TO
EEA-BASED USERS)

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.

3.1 Your consent

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.

3.2 Performing our contract with you

Under this legal basis we:

 * Provide our Services (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 Services; and

 * Process your payments.



3.3 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 Services
   
   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 Services 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 Services
   
   Our legitimate interest for this purpose is our interest in improving our
   Services so that we understand users’ preferences and are able to provide you
   with a better experience (for example, to make the use of App or the Website
   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 Services 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 Services 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 Services,
   non-compliance with our Terms and Conditions of Use



3.4 Compliance with legal obligations


4. WITH WHOM WE SHARE YOUR PERSONAL DATA

We share information with third parties that help us operate, provide, improve,
integrate, customize, support, and market our Services. 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:

4.1 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, Vercel, Namecheap);

 * data analytics providers (Facebook, Google, Appsflyer, Firebase, Amplitude,
   Tableau);

 * measurement partners (RevealBot, Clarity, Sentry, CookieYes);

 * marketing partners (in particular, social media networks, marketing agencies,
   Facebook, Google, Twitter, TikTok, Snapchat, Pinterest, Microsoft, LinkedIn);

 * payment processing providers (Stripe, Solidgate, PayPal); and

 * communication services providers (Iterable, Zendesk).



4.2 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.

4.3 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.


5. HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS

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

Accessing / reviewing / updating / correcting your personal data. You may
review, edit, or change the personal data that you had previously provided on
the Services.

Deleting your personal data. You can request erasure of your personal data as
permitted by law.

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.

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 to us as described
below.

To exercise any of your privacy rights, please send a request to
support@get-headway.com.


6. AGE LIMITATION

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.


7. INTERNATIONAL DATA TRANSFERS

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
Services 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 European Commission adequacy
decisions about certain countries (details available here).


8. CHANGES TO THIS PRIVACY POLICY

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
Services or by other available means and will have an opportunity to review the
revised Privacy Policy. By continuing to access or use the Services after those
changes become effective, you agree to be bound by the revised Privacy Policy.


9. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

This Supplemental California Privacy Notice only applies to our processing of
personal information that is subject to the California Consumer Privacy Act of
2018 (the “CCPA”). The CCPA provides California residents with the right to know
what categories of personal information we have collected about them and whether
we disclosed that personal information for a business purpose (e.g., to a
service provider) in the preceding twelve months. California residents can find
this information below.

Category of Personal Information Collected

Categories of Third Parties Personal Information is Disclosed to for a Business
Purpose

Identifiers

Service providers

Users or third parties you share with

Advertising partners

Personal information categories listed in Cal. Civ. Code § 1798.80(e)

Service providers

Users or third parties you share with

Commercial information

Payment solutions partners

Internet or other electronic network activity

Service providers

Users or third parties you share with

Advertising partners

Geolocation data

Service providers

Advertising partners

Inferences drawn from other personal information to create a profile about a
consumer

Service providers

Advertising partners

The categories of sources from which we collect personal information and our
business and commercial purposes for using personal information are set forth
above.

“Sales” of Personal Information under the CCPA. For purposes of the CCPA, we do
not “sell” personal information, nor do we have actual knowledge of any “sale”
of personal information of minors under 16 years of age.

Non-Discrimination. California residents have the right not to receive
discriminatory treatment by us for the exercise of their rights conferred by the
CCPA.

Authorized Agent. Only you, or someone legally authorized to act on your behalf,
may make a verifiable consumer request related to your personal information. To
designate an authorized agent, please contact us as set forth below.

Verification. When you make a request, we will ask you to provide sufficient
information that allows us to reasonably verify you are the person about whom we
collected personal information or an authorized representative, which may
include confirming the email address associated with any personal information we
have about you.

If you are a California resident and would like to exercise any of your rights
under the CCPA, please contact us as at support@get-headway.com. We will process
such requests in accordance with applicable laws.


10. SUPPLEMENTAL NOTICE FOR VIRGINIA RESIDENTS

This Supplemental Virginia Privacy Notice only applies if you reside in the
Commonwealth of Virginia. Where applicable, it describes how we use and process
your personal data and explains your particular rights under Virginia Consumer
Data Privacy Act (“VCDPA”).

Disclosures about the use of your personal data

We may collect and use certain information about you, some of which may be
personal data (such as your name, email address, IP address, or other
information which may be reasonably linked to you), in order to operate the
Services and to maximize your experience.

If you would like more information about the categories of your personal data we
collect or the purposes for which we collect them, please read Section 1 and
Section 2. To learn more about sharing of your personal data with our business
partners and other third parties, please read Section 4.

Data Rights

Section 5 of our Privacy Policy describes the data rights we offer to all users
and how to execute these rights. This includes the right to access, review,
correct, update your data, obtain a portable copy of your data, or delete data
related to your stored preferences and your use of the Services. Before
completing your request, we may require some information sufficient to
authenticate your identity.

Additionally, VCDPA provides Virginia residents with these data rights:

Opt out of the Processing of your Personal Data for Targeted Advertising. In
order to exercise your choice as a Virginia resident, please contact us at
support@get-headway.com with the subject line “Virginia Do Not Sell Request”. We
will process such requests in accordance with applicable laws.

Please note that we do not process personal data for purposes of (1) the sale of
personal data, as defined by the VCDPA, or (2) profiling in furtherance of
decisions that produce legal or similarly significant effects concerning the
consumer.

Confirm whether your Personal Data is being Processed. You may confirm whether
your personal data is being processed by emailing us at support@get-headway.com.

Appeal a Case with regard to your Request. In the case where we declined to take
action on your data rights request or have rejected your request, you may
contact us at support@get-headway.com to initiate an appeal of this decision.
Please use the subject line “Appeal of Refusal to Take Action on Privacy
Request” and provide the relevant information in the email. Once we receive your
appeal, we will notify you in writing within 60 days of any action taken or not
taken in response to the appeal, including a written explanation of the reasons
for the decisions.

If your appeal is denied, you may contact the Office of the Virginia Attorney
General by these means:

Office of the Attorney General | Virginia.gov
www.virginia.gov/agencies/office-of-the-attorney-general/#vagov
202 North Ninth Street
Richmond, VA 23219


11. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS

If you are a resident of Nevada, you have the right to opt-out of the sale of
certain personal information to third parties who intend to license or sell that
personal information. You can exercise this right by contacting us at
support@get-headway.com with the subject line “Nevada Do Not Sell Request” and
providing us with your name and the email address associated with your account.
Please note that we do not currently sell your personal information as sales are
defined in Nevada Revised Statutes Chapter 603A.


12. DATA RETENTION

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
Services to you), which includes (but is not limited to) the period during which
you have an account with the Services. We will also retain and use your personal
data as necessary to comply with our legal obligations, resolve disputes, and
enforce our agreements.


13. HOW “DO NOT TRACK” REQUESTS ARE HANDLED

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.


14. PERSONAL DATA CONTROLLER

GTHW App Limited, a company registered and acting under the laws of the Republic
of Cyprus with registration number HE 395742, having its registered address at
24 Peiraios Str., 1st floor, Strovolos, 2023 Nicosia, Cyprus, will be the
controller of your personal data.


15. CONTACT US

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.

Last Update: 28 March 2023

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©2024, GTHW App Limited, 24 Peiraios Street, 1st floor, Strovolos, Nicosia,
2023, Cyprus support@get-headway.com