Last updated: 16.09.2025
This Privacy Policy ("Privacy Policy") tells you ETREXIO DIGITAL SOLUTIONS BİLİŞİM VE İLETİŞİM TEKNOLOJİLERİ TİCARET LİMİTED ŞİRKETİ ("Etrexio", "Company", "we", "us" or "our") policies and procedures for the collection, use, and disclosure of personal data through the https://wordberry.app website and mobile application which operates under the name of WordBerry ("App"). It includes websites, features, applications, widgets, or online services owned or controlled by Etrexio and that post a link to this Privacy Policy. It also includes any personal data Etrexio collects offline in connection with the Service provided through the App.
When we refer to "Etrexio" or use the word "we", "our" or "us", we mean the ETREXIO DIGITAL SOLUTIONS BİLİŞİM VE İLETİŞİM TEKNOLOJİLERİ TİCARET LİMİTED ŞİRKETİ that acts as the "controller" of the data we hold about you or the "processor" of the data that a customer has entrusted to us. The contact details of each of these entities are set out at the end of this Policy.
Privacy Policy details the personal data Etrexio receives about you, how we process it and your rights and obligations in relation to your personal data. Etrexio, a company registered at Yeşilbaglar Mah. D100 Bulvari Yan Yol, No: 20/1 Pera Residence, Pendik/Istanbul, Republic of Turkey with the tax number of 3810922381 and tax office of Pendik Vergi Dairesi is the data controller for the purposes of the General Data Protection Regulation ("GDPR"), Protection of Personal Data No. 6698 of Turkey ("KVKK") and any relevant local legislation ("Data Protection Laws").
By using or accessing the Service, you agree to the terms of this Privacy Policy. We may update our Privacy Policy to reflect changes to our Information practices.
If you are a "data subject", please read this Privacy Policy carefully and make sure that you fully understand it. You are not legally required to provide us with any of your personal data and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your personal data, or to have it processed by us or any of our services providers, please simply do not visit or interact with our Sites, nor use our App or Services.
By "you" we mean the individual reading this text, i.e., you as a natural person (and not any company or other organization that you may be associated with).
Some words and phrases in this Privacy Policy are in quotation marks (e.g., "controller", "processor'" and "data subject"). These are legal terms, having the same meanings as given to them in the EU General Data Protection Regulation, i.e., Regulation (EU) 2016/679 ("GDPR").
Etrexio collects Information from you directly, automatically through its Service, and from third parties. Each collection mechanism is described in more detail in this Privacy Policy.
If you contact with us for demanding technical support or notify us about an error or any reason, we require you
As with most websites and mobile applications, certain data are automatically collected when you visit a website or use a service application. We also automatically collect the data which includes; services metadata, log data, device Information, previously visited pages, last used service, session data, browsing data, IP addresses and third-party data and cookie Information.
When you enter the Website, we collect certain Information from your browser using cookies. The cookies used by our Service includes both first party and third-party cookies. First party cookies allow us to collect analytics data, remember your settings, learn your last visited page and last used service, and perform other useful functions that help simplify your user experience. Third party cookies are used by third parties for advertising, retargeting, analytics, marketing, and tracking.
Cookies vary by nature and purpose. For instance, a "session cookie" only exists in the temporary memory of your device, i.e., while your Service session or visit to a Website lasts, and is usually deleted when your web browser is closed. A "persistent cookie", on the other hand, has a longer lifespan: it remains on your device until you delete it (i.e., instruct your browser to do so) or until it expires. A "secure cookie" can only be sent over a "secure" (encrypted) connection, making it harder for others to intercept Information. A "first-party cookie" belongs to us, and a "third-party cookie" belongs to someone other than Etrexio, e.g., a company providing us with Service or Website analysis services or delivering our messages (such as advertisements) across the internet.
We only use Google Analytics and Yandex Metrica which are web analytics tools that helps us understand how users engage with the Website. Like many services, Google Analytics and Yandex Metrica use first-party cookies to track user interactions as in our case, where they are used to collect Information about how users use our site. This Information is used to compile reports and to help us improve our Website. The reports disclose website trends without identifying individual visitors. You can opt out of Google Analytics and Yandex Metrica without affecting how you visit our site.
Please note that we do not change our practices in response to a "Do Not Track" signal in the HTTP header from a browser or mobile application, however, most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or to block or remove cookies altogether.
Third-party cookies can usually be managed by the tools provided by those parties. Some of such tools are available here:
You can find more Information about cookies and how to manage them at http://www.allaboutcookies.org.
We receive from you such Information as you provide us when filling in forms (e.g., applications or questionnaires) on a Website or via the Service or when you participate in our Service-related campaigns or programmes, sign up to receive notifications, newsletters or other communications from us, request support for the Service, interact with our social media accounts or correspond or otherwise communicate with Etrexio within the scope of WordBerry Website or App. If you email us or send us a letter or a message, we may retain a record of such communication, including your name, email address or telephone number (as applicable or as placed in the messages/e-mails), the content of your communication and our response. We may complement these data with other Information.
The purposes for which Information is processed and the legal grounds for such processing are varied and depend on the nature of the Information. If Information is anonymous or de-identified, we may collect, use, disclose and otherwise process it for any purpose. Our processing of Personal Data, however, is limited to the purposes set out in this Policy.
Most commonly, we will process your Personal Data in the following circumstances: (a) if we need to perform an agreement you have with us or it is necessary to take pre-contractual steps at your request before entering into such an agreement (we shall refer to these grounds as "Contractual"); (b) where we need to comply with a legal obligation, e.g., one arising from a law or regulation concerning taxation, accounting, financial reporting, prevention of terrorism or money laundering, or judicial or administrative process (this would be a "Legal" ground); (c) if it is warranted by our legitimate interests or those of a third party and such interests are not overridden by yours or your fundamental rights and freedoms (here, the processing would be based on "Interest"); (d) where we have your unambiguous consent before processing your Personal Data in that specific situation (thus allowing us to process these data on the grounds of "Consent").
We use your information:
We use cookies:
Please note that if you enter payment details into the Service when purchasing a Paid Service (including any subscription), Etrexio itself does not receive or store such payment information, and as such information is received, it is stored and used by our payment service providers for the purpose of completing the order, subscription, or purchase.
This part of the Policy describes the circumstances in which we may disclose or transmit your Personal Data to third parties. Please note that the sections below only address the disclosures and transmissions of Personal Data and not, for example, anonymous or de-identified Information (which we may transmit and disclose at any time to anyone anywhere, in any manner and for any purpose).
Etrexio shares your personal data only when it is necessary to offer the Service, legally required, or permitted by you.
We will provide personal data to hosting providers such as Amazon Web Services, payment integrators such as RevenueCat, and analytics providers such as Google and Yandex.
These data processors help us bring you the Service. For example, we may share your information in order to detect where or how you encountered a bug when using our mobile application. In connection with these operations, our service providers will have access to personal data for a limited time. When we utilize service providers for processing any personal data, we implement contractual protections limiting the use of that personal data to the provision of services to Etrexio.
We will be required to access and disclose personal data in response to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. Additionally, we will access and share account or other personal data when we believe it is necessary to comply with law, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the Service or using the Etrexio name, or to prevent imminent harm. This will include accessing and sharing personal data with other companies, lawyers, agents, or government agencies.
We may share your Personal Data with our corporate subsidiaries and outside accountants, legal counsels, and auditors.
If we engage in or are subject to a merger, acquisition, division, transformation, public offering of our securities, obtaining financing, divestiture of all or substantially all of our assets or a significant part of such assets, transfer of the enterprise or a part of the enterprise to which your agreement with us pertains, or a similar transaction or proceeding, or if we take steps in contemplation of such activities (e.g., submit to due diligence), your Personal Data may, subject to standard confidentiality arrangements, be shared with, or transferred to, our counterparties or other relevant participants in the respective transaction or proceeding.
We shall disclose your Personal Data at your request (unless legally prohibited, impracticable or involving unreasonable effort or expense) or may do so upon your Consent.
We only store your Personal Data for as long as necessary in the light of, or compatible with, the purposes for which the data were collected (e.g., enjoying our rights and performing our obligations under the contract you have with us, if that was the sole purpose) and such additional period as may be required by law.
Legal retention periods vary depending on the type of Information concerned, and they can be quite long. For instance, Personal Data relevant to our contract with you (which is likely to be the case upon some of the Personal Data categories and may also apply to some other Personal Data) must be retained for at ten years after the primary purpose for their processing ceases to apply (e.g., ten years following our business relationship with you terminated.)
The Service may contain links to other websites. We are not responsible for the privacy practices of other websites. We encourage users to be aware when they leave the Service to read the privacy statements of other websites that collect personally identifiable information. This Privacy Policy applies only to Information collected by Etrexio via the Service.
Etrexio has implemented administrative and technical safeguards it believes are appropriate to protect the confidentiality, integrity, and availability of your personal data. However, please be aware that no security measure is perfect. Our efforts notwithstanding, we cannot guarantee that your Personal Data, during transmission over the internet or while stored in our systems or those of our service providers or while otherwise in our care, will be absolutely safe from unauthorized or unlawful processing or accidental loss, alteration, or destruction, or that they will indeed be intact and confidential at all times or shortly available after any Service incident. Note also that we cannot control, and are not responsible for, the actions of other parties with whom you share (or instruct us to share) your Personal Data.
As data subject, you have legal rights which are regulated under the GDPR and other local legislations. This part of the Policy aims to give you a general understanding of these rights and we encourage you to deepen this understanding by studying the GDPR yourself.
You have the right to enquire and get a confirmation from us as to whether or not we process any of your Personal Data. Where we do, you may request access to those data and have us give you a copy of them. Please use the contact details at the end of this Policy to exercise your "right of access".
If the Personal Data we have about you is incorrect, you have the right to request that we correct those data, and, in some circumstances, you may have the right to require that your incomplete Personal Data be completed (but in each of these cases we may need to verify the accuracy of the information you provide to us).
You have the right to request that we delete or remove the Personal Data we have on you where there is no good reason for us continuing to process them. Please note that we may not always be able to comply with your request as there may be specific legal reasons which warrant the processing. Should this be the case, we shall inform you accordingly at the time of your request.
You have the right to object to our processing of your Personal Data where the processing is based on Interest and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts your interests or fundamental rights and freedoms. There may, however, be occasions where we demonstrate that we have compelling legitimate grounds to process your Personal Data (i.e., that our legitimate interests or those of a third party override yours and your fundamental rights and freedoms) and thus dismiss your objection. In case we are processing your Personal Data for direct marketing purposes, you may object to that processing at any time, and we shall no longer process your Personal Data for such purposes.
You have the right to request that we suspend the processing of your Personal Data where any of the following applies: (a) you have contested the accuracy of the data and the same needs to be verified; (b) the processing is unlawful but you do not want us to erase the data that we are processing; (c) you need us to maintain the data even though we no longer require them as they are necessary for your establishment, exercise or defense of legal claims; or (d) you have objected to processing as described under GDPR Article 17 but we need to verify whether we have overriding legitimate grounds for processing.
If our processing of your Personal Data which you have provided us is based on a Contractual ground or on Consent and the processing is carried out by automated means, you are entitled to have us make those data available to you in a structured, commonly used, and machine-readable format so that you could transmit them to someone else (another "controller"). You may also ask us to transmit these data to that other "controller" directly, and we shall do so, if technically feasible.
If we are processing your Personal Data based on Consent, you may withdraw that consent at any time (but this will not affect the lawfulness of any processing activities carried out based on your consent before its withdrawal).
We aim to respond to any legitimate request within a month of its receipt, but it may take us longer if your request is particularly complex or you have made several requests. If that is the case, we shall let you know and keep you updated.
We shall not charge you any fee for exercising the above rights unless your requests are clearly unfounded or excessive (e.g., because of their repetitive character), in which case we may charge a reasonable fee. Alternatively, we may decline your request in such circumstances.
Residents of California have the right to:
To make such a request, please send an email to privacy@etrexio.com
We may revise and change this Policy from time to time to reflect changes to the Service, Websites, applicable laws, regulations or standards or other changes that may occur in our business. We shall post the revised Policy (or, as the case may be, our new privacy policy) on the same webpage where we published this Policy or on such other webpage as we then may habitually use for publishing materials such as the Policy. We may also use the Service, email, or other means for notifying Users of such policy changes. The revised Policy (or, as applicable, the new one) will be effective when posted as described unless the document itself specifies a later time for its entry into force.
Feel free to get in touch with us if you have any questions about this Policy or our data processing practices or if you would like to exercise any of your "data subject" rights with respect to the Personal Data we maintain on you.
Email us: privacy@etrexio.com
Call us: +90 507 264 48 36
Write to Etrexio:
Yeşilbaglar Mah. D100 Bulvari Yan Yol, No: 20/1 Pera Residence,
Pendik/Istanbul, Republic of Turkey