Clarification Notice

Clarification Notice

Clarification Notice

Last updated: October 15, 2026

1. Data Controller and Purpose of This Document

This Privacy Notice has been prepared in accordance with Article 10 of the Law on the Protection of Personal Data No. 6698 ("KVKK") and the Communiqué on the Principles and Procedures to Be Followed in Fulfilling the Obligation to Inform. Its purpose is to inform you about who processes your personal data, the purposes and legal grounds for processing, the methods used to collect it, the parties to whom it may be transferred, and your rights under the KVKK.

Data Controller: Vibseen Medikal Teknoloji Ticaret A.Ş. (“Vibseen”)
Address: Hamidiye Mah. Anadolu Cad. No:40/1 Kağıthane, Istanbul, Türkiye
Email: hello@vibseen.com

This document applies to users seeking health information and healthcare professionals publishing content across the Vibseen mobile application (iOS and Android), the vibseen.com website, and related services. It also covers website visitors and anyone who contacts us.

Vibseen is a video-based health information platform. It does not provide medical diagnoses, treatment, or telehealth services.

2. Personal Data We Process

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Data Category

Personal Data

Data Subject Category

Identification Details

First name, last name, and profile picture; for healthcare professionals, also national ID number, copy of ID, and date of birth

Patients and healthcare professionals

Contact Information

Email address, mobile phone number, billing address

Patients and healthcare professionals

Professional Experience

Medical degree, board certification, professional license number, specialty, affiliated institution, title

Healthcare Professionals

Audiovisual recordings

Uploaded videos, video-generated captions and summaries, and profile photos

Healthcare Professionals

Customer Transaction Details

Purchased plan, payment amount and date, billing information, subscription status, support requests

Patients and healthcare professionals

Procedure Safety Information

Password hash, SMS verification code, IP address, login records, device identifiers, push notification token, and session information

Patients and healthcare professionals

Usage Data

Search queries, viewed videos and watch history, likes, saved videos, followed healthcare professionals, and playlists

Patients and healthcare professionals

Contact Resources

In-app messages, comments, inquiries and attachments; emails sent to us

Patients and healthcare professionals

Marketing Information

Notification and email communication preferences, consent history

Patients and healthcare professionals

Sensitive Personal Data (Health Information)

Health information inferred from search queries and viewing history (see Section 5)

Users

Vibseen does not collect contacts, photo gallery data, payment card details, medical records, lab results, or diagnostic information.

3. Purposes of Processing Personal Data

In accordance with the general principles outlined in Article 4 of the Personal Data Protection Law (KVKK), your personal data is processed strictly and proportionately for the following purposes:

  • Creating user accounts, verifying identity, and enabling secure account login,

  • Verifying the identity and professional credentials of healthcare professionals; ensuring only verified professionals can publish content,

  • Discovering and delivering relevant video content using AI-powered search tailored to user queries,

  • Publishing videos, generating subtitles and summaries, and curating playlists,

  • Facilitating seamless in-app communication between users and healthcare professionals,

  • Sending notifications regarding account activity, new content, and messages,

  • Processing sales of paid subscription plans, managing billing, and maintaining accounting records,

  • Ensuring platform security and preventing fraud, abuse, and unauthorized access,

  • Monitoring service performance, troubleshooting errors, and optimizing platform features using anonymized data,

  • Managing customer support inquiries and resolving user feedback and complaints,

  • Sharing updates on new educational content and promotions, subject to your explicit consent,

  • Complying with statutory obligations, providing disclosures to authorized regulatory authorities, and exercising legal defense rights in disputes.

We do not sell your data to third parties for advertising purposes, nor do we create profiles to target you with ads.

4. Methods of Data Collection and Legal Grounds

Collection Method: Your personal data is collected electronically through automated and semi-automated methods, including registration, application, payment, and contact forms on our mobile app and website; automated tracking during your use of the application (such as search queries, activity logs, device details, and session records); SMS verification and notification services; emails and messages you send to us; and transaction confirmations returned by payment service providers.

Legal grounds: Your personal data is processed without requiring your explicit consent, based on the following legal grounds set forth in Article 5/2 of the Turkish Personal Data Protection Law (KVKK):

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Legal basis (Turkish Data Protection Law / KVKK Art. 5/2)

For which procedures

(c) It is directly related to the establishment or performance of an agreement

Account creation, identity verification, video publishing, secure messaging, notifications, premium plan subscriptions, and dedicated support

(c) Compliance with a legal obligation to which the data controller is subject

Invoicing and accounting records, internet traffic logs under Law No. 5651, and fulfilling requests from authorized public institutions

(e) It is necessary for the establishment, exercise, or defense of a legal right

Retention of Dispute and Complaint Records

(f) Legitimate interests of the data controller

Healthcare professional credential verification, platform security, fraud prevention, and service enhancement through anonymized data

The following processing activities are carried out solely on the basis of your explicit consent (LPPD Art. 5/1 and Art. 6/2), which you may withdraw at any time:

  • Processing your search queries and viewing history to recommend relevant videos (as this may constitute special category data; see Section 5),

  • Sending notifications regarding new content and campaigns,

  • Transferring your personal data to overseas service providers when a legal basis other than standard contractual clauses is required (see Section 6).

5. Special Categories of Personal Data

Vibseen never requests your medical records, diagnoses, or lab test results. However, your search queries and viewing history may reveal insights about your health status and are therefore considered special categories of personal data under Article 6 of the KVKK (Personal Data Protection Law). In line with the Personal Data Protection Board's guidelines on adequate measures for processing special categories of personal data, this information is processed strictly with your explicit consent.

Your explicit consent is collected separately from this text on an in-app prompt prior to your first use of the search feature. If you choose not to provide consent, you can still explore the app by browsing categories; you can withdraw your consent at any time through the app settings or by contacting hello@vibseen.com.

Additional measures we take to protect this data:

  • Search queries are kept separate from account information and stored under a pseudonym,

  • Raw search queries are anonymized after 90 days,

  • Search queries, email addresses, and phone numbers are never recorded in system logs or analytics tools,

  • Access to this data is strictly limited to authorized personnel subject to non-disclosure agreements,

  • Data is transmitted and stored in a fully encrypted environment.

6. Transfer of Personal Data

In accordance with Articles 8 and 9 of the Law on the Protection of Personal Data (KVKK), your personal data is transferred to our service providers for the following purposes:

Cross-Border Data Transfers: Your data is transferred abroad because our servers are hosted in Germany and our notification infrastructure is located in the United States. In the event of a transfer that cannot be covered by standard contractual clauses, the transfer will only take place with your explicit consent—duly informed of potential risks—pursuant to Article 9/6 of the LPPD (KVKK).

7. Data Retention Periods

Your personal data is retained for the duration required by its processing purpose and the retention periods stipulated by relevant legislation. Once this period expires, it is securely deleted, destroyed, or anonymized in accordance with Article 7 of the Personal Data Protection Law (KVKK) and the Regulation on the Deletion, Destruction, or Anonymization of Personal Data.

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Data

Shelf Life

Account, contact, and usage data

For the duration of the membership, and for 30 days following account deletion

Raw search queries

Retained for 90 days, followed by anonymization

In-app messages

During the membership term, once deleted by both parties

Videos and Educational Resources

Until deleted by the professional or until the account is closed

Physician credential verification documents (ID, medical diploma)

[12 months] upon completion of verification; verification results valid for 3 years

Notification Token

Until notifications are disabled or the app is uninstalled

Billing and Accounting Records

10 years (pursuant to Tax Procedure Law No. 213 and Turkish Commercial Code No. 6102)

Traffic and Access Logs

1 year (pursuant to Law No. 5651)

Support Correspondence

2 years after request closure

Data Subject Requests and Responses

3 years

Disputed records

Pending dispute resolution

For details on how to delete your account and the account deletion process, please refer to our Account Deletion Policy: https://vibseen.com/hesap-silme

8. Your Legal Rights Under Article 11 of the LPPD (KVKK)

As a data subject, you are entitled to the following rights under Article 11 of the Personal Data Protection Law (KVKK):

  • (a) Learn whether your personal data is being processed,

  • (b) Request information if your personal data has been processed,

  • (c) Learn the purpose of processing your personal data and whether it is being used in accordance with that purpose,

  • (d) Know the third parties to whom your personal data is transferred, whether domestically or internationally,

  • (e) Request the correction of your personal data if it is incomplete or incorrectly processed,

  • (f) Request the deletion or destruction of your personal data within the framework of the conditions stipulated in Article 7 of the LPPD,

  • (g) Request that notifications regarding the transactions carried out in accordance with sub-paragraphs (e) and (f) be made to the third parties to whom your personal data was transferred,

  • (h) Object to any outcome that works against you resulting from the analysis of processed data exclusively through automated systems,

  • (i) Claim compensation for damages if you suffer harm due to the unlawful processing of your personal data.

Application method: You may submit your requests regarding your rights through the following channels, in accordance with the Communiqué on the Principles and Procedures for the Request to the Data Controller:

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Method

Address

Note

Email

This must be sent from the email address registered to your account.

Written application

Vibseen Medical Technology Inc., [Hamidiye Mah. Anadolu Cad. No:40/1 Kagithane, Istanbul

A physically signed written request, accompanied by the necessary identification details

In-App

Profile > Settings > Personal Data

Request Form

Your application must include your full name, signature (for written requests), Turkish Republic ID number (or passport number for foreign nationals), notification address, and, if available, your email address, phone number, and the specific details of your request. Requests are processed free of charge within a maximum of 30 days; however, if the procedure incurs an additional expense, a fee set by the Personal Data Protection Board may apply. If your application is rejected, deemed insufficient, or not answered within the statutory timeframe, you may lodge a complaint with the Personal Data Protection Board within 30 days of receiving the response, and in any event, within 60 days of the original application date.

9. Updates and Contact Information

This Privacy Notice is updated whenever there are changes to our services or applicable legislation. The current version is always published with the “Last updated” date within the app and at vibseen.com; material changes will be announced via in-app notifications or email.

Vibseen Medical Technology Inc.
Email: hello@vibseen.com