Markword Privacy Policy
Last updated October 23, 2026
This Privacy Policy explains how Xeplin Yazılım Hizmetleri Anonim Şirketi (“Xeplin,” “we,” “our,” or “us”) collects, uses, and shares information when you use our mobile application “Markword: Daily Vocabulary” (the “App”). This Policy is part of, and incorporated into, our Terms of Use & End-User License Agreement.
Privacy at a glance. The App does not require an account. Your favorites, history, streak, reminders, and custom themes are stored locally on your device. The App does not show third-party ads and does not track you across other companies’ apps or websites. We collect limited technical, diagnostic, analytics, and purchase information to operate, secure, and improve the App.
1. Data Controller
- Legal name: Xeplin Yazılım Hizmetleri Anonim Şirketi
- Address: Fulya Mah. Büyükdere Cad. Torun Center D Blok No: 74D, İç Kapı No: 43, 34394 Şişli/İstanbul, Türkiye
- Trade Registry No: 1058219 · MERSIS No: 0839126685400001
- Contact: [email protected]
2. Information We Do Not Collect
- No account, no profile. The App does not require you to register or sign in, and the App does not ask for your email address, phone number, or other contact information. You may optionally enter a first name or nickname to personalize the App; it is stored only on your device and is not sent to us.
- Your personal content stays on your device. Your favorites, history, streak, reminder schedule, and custom themes (including any photo you choose as a background) are stored locally on your iOS device. We do not operate user accounts and do not keep a copy of this content on our servers.
- No advertising identifier, no cross-app tracking. The App does not show third-party ads, does not request Apple’s App Tracking Transparency permission, and does not collect the Identifier for Advertisers (IDFA).
- No payment information. All purchases and subscriptions are processed by Apple through the App Store. We do not receive your payment card or bank account details.
3. Information We Collect
To operate the App, prevent abuse, measure performance, and improve our Services, we and our third-party service providers collect the following limited categories of information:
3.1 Device and Technical Information
iOS version; device model; language and locale settings; time zone; App version and build; and general technical information necessary for the App to function properly.
3.2 Identifiers
A random, anonymous identifier that the App generates for your installation, and the Identifier for Vendors (IDFV) provided by iOS. These identifiers do not contain your name, email address, or phone number, and they are not used to track you across other companies’ apps or websites.
3.3 Usage and Analytics Data
Information about how you interact with the App, such as features used, screens viewed, in-app events (for example, viewing, saving, or sharing a word, or changing a theme), preferences you select in the App (such as topics or goals), session duration, frequency of use, paywall views, and similar product-analytics events. This data is associated with the anonymous identifier described above, not with your name or contact details.
3.4 Diagnostic and Crash Data
If the App crashes or encounters an error, we collect crash reports, error logs, stack traces, device state at the time of the crash, and performance metrics. This information helps us diagnose and fix problems and improve stability.
3.5 Subscription and Purchase Events
When you start a trial, subscribe, renew, cancel, or have a subscription expire, we and our subscription-management provider receive event-level information from Apple (such as the product purchased, transaction identifier, currency, country, trial start and end events, renewal and cancellation events). We do not receive your payment card details.
3.6 Notifications
Reminders are scheduled locally on your device using iOS notifications. We do not collect a push notification token to deliver them. You can disable notifications at any time in iOS Settings.
3.7 IP Address
Our service providers may automatically collect your IP address when the App communicates with their servers, for security, fraud prevention, and approximate-region inference (country/region level).
3.8 Information You Send Us
If you contact us (for example, by email), we receive the information you choose to provide, such as your email address, your name, and the content of your message. We use it to respond to you and to keep a record of our correspondence.
3.9 Advertising Attribution (Apple Ads)
We may promote the App through Apple Ads. If you install the App after interacting with an Apple Ads advertisement, we and our subscription-management provider may receive campaign attribution information from Apple (such as the campaign or keyword associated with the install) through Apple’s AdServices framework. This information does not include the IDFA and is not used to track you across other companies’ apps or websites.
4. iOS Permissions We Request
| Permission | Purpose |
|---|---|
| Notifications | To deliver the reminders you set up, if you opt in. |
| Photos (add only) | To save a card to your photo library when you choose to. This permission does not let the App read your library. |
If you choose a photo for a custom theme, the iOS photo picker gives the App only the image you select, and that image stays on your device. You can change these permissions at any time in iOS Settings.
5. How We Use Information
We use the information we collect for the following purposes:
- to provide, operate, maintain, and secure the App;
- to process and manage subscriptions, trials, renewals, and entitlements;
- to diagnose and fix bugs, crashes, and performance issues;
- to understand how the App is used and to improve features, design, and user experience;
- to deliver the reminders you schedule;
- to measure the performance of our own advertising (such as Apple Ads campaigns);
- to comply with legal obligations, enforce our Terms, and protect our rights and the rights of others.
6. Third-Party Service Providers (SDKs)
We rely on the following third-party service providers, who act as our processors or as independent controllers for the limited purposes described. These providers may collect information automatically through their software development kits (SDKs) integrated in the App. Their use of information is governed by their own privacy policies.
| Provider | Purpose | Privacy Policy |
|---|---|---|
| Google Firebase (Firebase Analytics and Firebase Crashlytics) | Product analytics, crash reporting, and diagnostics. | firebase.google.com/support/privacy |
| Adapty | Subscription management, paywall configuration, and subscription analytics. | adapty.io/privacy |
| Apple App Store | App distribution, in-app purchases, subscription billing, and refunds. | apple.com/legal/privacy |
From time to time, we may add additional service providers (for example, additional analytics, advertising, or attribution tools such as Mixpanel) to support our business operations. We will update this Policy and the list above when we do so. Where required by law, we will obtain your consent before integrating new tracking technologies.
7. Sharing and Disclosure
We do not sell your personal information. We share information only:
- With service providers listed in Section 6, who process information on our behalf or as independent controllers for the limited purposes described;
- With our affiliates, meaning companies under common ownership or control with Xeplin, for the purposes described in this Policy;
- With Apple, in connection with App distribution and in-app purchases;
- To comply with law, when required by applicable law, court order, or governmental request, or to protect the rights, property, or safety of Xeplin, our users, or others;
- In connection with a corporate transaction, such as a merger, acquisition, financing, reorganization, or sale of assets, in which case information may be transferred to the successor entity, subject to commitments consistent with this Policy.
Refunds and fraud prevention. If a refund request is submitted for an in-app purchase, we may share limited purchase-related information with Apple to help prevent fraud and support refund decision processes. This information may include anonymized account identifiers, app usage activity, subscription status, trial usage, purchase consumption status, total spend amount, and refund history.
We may use and share aggregated or de-identified information that cannot reasonably be used to identify you for any lawful purpose and without restriction.
8. International Data Transfers
Xeplin is based in the Republic of Türkiye. Some of our service providers are located outside Türkiye and outside the European Economic Area (EEA), including in the United States. Where personal data is transferred internationally, we rely on appropriate legal mechanisms, including, where applicable, Standard Contractual Clauses approved by the European Commission, adequacy decisions, and equivalent safeguards under Turkish Personal Data Protection Law No. 6698 (“KVKK”). By using the App, you understand that your information may be processed in countries whose data-protection laws may differ from those in your country of residence.
9. Data Retention
We retain information only for as long as reasonably necessary to fulfill the purposes described in this Policy, to operate and secure the App, to comply with our legal, tax, and accounting obligations, to resolve disputes, and to enforce our agreements. Retention periods depend on the type of information and on the settings and practices of our service providers. When information is no longer needed, it is deleted or anonymized.
10. Security
We use commercially reasonable technical and organizational measures designed to protect the limited information we collect against unauthorized access, alteration, disclosure, or destruction. These measures include encryption in transit (TLS), restricted access to data, and routine security reviews. However, no method of transmission over the internet or method of electronic storage is 100% secure, and we cannot guarantee absolute security. You are responsible for keeping your device secure (for example, by using a strong device passcode and keeping iOS up to date).
11. Your Rights
11.1 Rights Under GDPR (EEA, UK and Switzerland)
If you are located in the European Economic Area, the United Kingdom, or Switzerland, you have the following rights, subject to applicable conditions and exceptions: the right to access your personal data; the right to rectify inaccurate data; the right to erasure (“right to be forgotten”); the right to restrict or object to processing; the right to data portability; the right to withdraw consent at any time (where processing is based on consent); and the right to lodge a complaint with your local supervisory authority.
The legal bases on which we rely are: (a) legitimate interests for operating, securing, and improving the App, for analytics, advertising measurement, and fraud prevention; (b) performance of a contract for processing subscriptions and entitlements; (c) consent for notifications; and (d) legal obligation where we are required to retain certain information.
11.2 Rights Under CCPA/CPRA (California)
If you are a California resident, you have the right to know what personal information we collect, to request deletion, to correct inaccurate information, and to opt out of “sale” or “sharing” of personal information as defined by California law. We do not sell or share personal information as those terms are defined under California law. We do not knowingly collect the personal information of minors under 16 without legally required consent. You may exercise your rights by contacting us at [email protected]. We will not discriminate against you for exercising these rights.
11.3 Other U.S. States
Residents of certain other U.S. states with comprehensive privacy laws (such as Virginia, Colorado, Connecticut, Utah, and Texas) may have the right to confirm whether we process their personal data, to access, correct, or delete it, to obtain a portable copy, and to opt out of targeted advertising, the sale of personal data, and certain profiling. We do not sell personal data and we do not use it for targeted advertising. To exercise these rights, or to appeal a decision we have made about your request, contact us at [email protected]. The scope of these rights varies by state and is subject to exceptions.
11.4 Rights Under KVKK (Türkiye)
If you are located in Türkiye, you have the rights provided under the Personal Data Protection Law No. 6698 (KVKK), including the right to learn whether your personal data is processed, to request information about processing, to request correction or deletion, and to lodge a complaint with the Personal Data Protection Authority (KVKK).
11.5 Exercising Your Rights
To exercise any of the above rights, please contact us at [email protected]. We will respond within the timeframes required by applicable law. Because the App does not require an account, identifying the data associated with you may require additional information (such as the anonymous identifier assigned to your installation of the App). If we cannot verify your identity or locate the data, we may not be able to fulfill your request.
12. Children’s Privacy
The App is not directed to children under 13 years of age (or the equivalent minimum age in the relevant jurisdiction, such as 16 in some EEA countries). We do not knowingly collect personal information from children under that age. If you are a parent or legal guardian and believe that your child has provided us with information without your consent, please contact us at [email protected], and we will take reasonable steps to delete such information.
13. Do Not Track
The App does not respond to browser-based “Do Not Track” signals because such signals are not standardized for mobile applications. The App does not track you across apps or websites owned by other companies and does not request permission to do so.
14. Changes to this Policy
We may update this Privacy Policy from time to time. If we make material changes, we will notify you by posting the updated Policy at markword.app/privacy and updating the “Effective date” above, and, where appropriate, by in-app notice. Your continued use of the App after the effective date of the revised Policy constitutes your acceptance of the changes.
15. Contact
If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:
- Email: [email protected]
- Postal address: Xeplin Yazılım Hizmetleri Anonim Şirketi, Fulya Mah. Büyükdere Cad. Torun Center D Blok No: 74D, İç Kapı No: 43, 34394 Şişli/İstanbul, Türkiye