Privacy policy

HEADWAY MEDIA

IMPORTANT PRIVACY INFORMATION

We use personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you have accessed our website, we may automatically collect your IP address and advertising IDs. As a result, you might see our ads, for example, in your Facebook’s feed. Our partners may also tailor the ads for you on our website using cookies and similar technologies.

For improving our service and to measure and serve ads, we use third party solutions. As a result, we may process data using solutions developed by Facebook, Google, Twitter, Amplitude, Firebase, Hotjar, Tableau. Some of the data is stored and processed on servers of such third parties.

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.

PRIVACY POLICY

This Privacy Policy explains what personal data is collected when you use the Headway Media website available at https://headway.media/ (the “Website”) and the services provided through it (together with 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.

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.

EU/EEA” includes all current member states to the European Union and the European Economic Area.

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. CALIFORNIA PRIVACY RIGHTS
  10. DATA RETENTION
  11. HOW “DO NOT TRACK” REQUESTS ARE HANDLED
  12. PERSONAL DATA CONTROLLER
  13. CONTACT US

1.  CATEGORIES OF PERSONAL DATA WE COLLECT

We collect data you give us voluntarily (for example, your email). We also collect data automatically (for example, your IP address) and use third-party service providers for such collection.

1.1.  Data you give us

We do not require you to provide us with any personal information directly to use our Service. However, we may ask you to provide, for example, your email address if you wish to subscribe to our newsletter or when contacting us for any inquiries.

1.2.  Data we collect automatically:

1.2.1.  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).

1.2.2.  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.

1.2.3.  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. We also record the ads on the Website with which you interact (and the Internet links to which those ads lead).

1.2.4.  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).

1.2.5.  Cookies and other similar technologies

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.

2.  FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA

We process your personal data:

2.1.  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.

To host personal data and enable our Service 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  .

2.2.  To customize your experience

We process your personal data, such as your browsing history, to adjust the content of the Service and make offers tailored to your personal preferences. For example, if we see that you have viewed articles about any particular book, might show you more of the similar articles.

2.3.  To 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. 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.

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

We communicate with you, for example, by emails. These may include emails with information about the Service. To opt out of receiving emails, you need to use unsubscribe link in the footer of the emails.

The services that we use for these purposes may collect data concerning the date and time when the message was viewed by our Website’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 useFirebase 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 Website. 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 visited the Website. Google’s privacy policy.

2.5.  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 of Website our users like more, what categories of users visit our Website. As a consequence, we often decide how to improve the Website based on the results obtained from this processing.

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 .

We use Facebook pixel on the Website. Facebook pixel is a code placed on the Website collecting data that helps us track conversions from Facebook ads, build targeted audience and remarket to people who have taken some action on the Website (for example, purchased a meal plan).

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 Hotjar, a behavior analytics tool that analyses Website use, providing feedback through tools such as heatmaps, session recordings, and surveys.  Hotjar’s Privacy Policy  .

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 Website. As a result, Amplitude helps us to decide what features should we focus on. 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 .

To perform our Website analysis, we also use Tableau, a company providing interactive data visualization products focused on business intelligence.  Tableau Software Privacy Policy. 

2.6.  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 Website, and send you push notifications for marketing purposes.

2.7.  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 visited our Website, 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 “Tracking” to turn off “Allow Apps to Request to 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).

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:

When you opt out of personalized advertising, you may continue to see online advertising on the Service and/or our ads on other Internet websites and online services.

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.

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 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 Website (for example, visited 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 Website. Some other examples of events that may be used for tailoring ads include, in particular, visiting our Website. 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.

2.8.   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).

2.9.  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;

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
  • Provide you with customer support
  • Communicate with you regarding your use of our Service

3.3. 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 emails proposing you to read a new article. 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 articles, 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 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 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.

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.

3.4. to comply 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 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:

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
  • data analytics providers (Facebook, Google, Firebase, Amplitude)
  • measurement partners
  • marketing partners (in particular, social media networks, marketing agencies, email delivery services, Facebook, Google, Twitter)
  • communication services providers

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 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.

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.

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 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 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 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.

9.  CALIFORNIA PRIVACY RIGHTS

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.

10.  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 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.

11.  HOW “DO NOT TRACK” REQUESTS ARE HANDLED

Except as otherwise stipulated in this Privacy Policy, this Website 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.

12.  PERSONAL DATA CONTROLLER

GTHW App Limited , a company registered in the Republic of Cyprus (with mailing address at ) will be the controller of your personal data.

13.  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.

Effective as of: Oct 2021