Vibseen Medical Technology Trade Incorporated Company Clarification Text on User Membership, Platform Usage, and Commercial Communication Processes

Last updated: June 17, 2026

1. Data Controller

Your personal data is processed by Vibseen Medikal Teknoloji Ticaret Anonim Şirketi ("Company"), in its capacity as data controller, within the scope of the provisions of the Personal Data Protection Law No. 6698 ("KVKK") and within the framework of this Privacy Notice on Membership, Platform Use, and Commercial Communication Processes for Users ("Privacy Notice").

Our Company operates a video-based health information platform ("Platform") that leverages AI to analyze video content produced by verified health professionals, making it easier for users to access reliable health information. This Privacy Notice explains the scope within which personal data, collected through creating a membership ("User") on the https://vibseen.com website or mobile application and using the services offered on the Platform, as well as the execution of corporate information, promotion, and commercial communication activities, is processed.

Important Note: The Platform does not offer telemedicine, diagnosis, treatment, prescription, or appointment services. The contents on the Platform are of a general health information nature and do not replace a physician's physical examination. Our Company is not a healthcare facility offering telemedicine services under the Regulation on the Delivery of Telehealth Services.

2. Methods of Collecting Personal Data

Your personal data is collected by our Company through fully or partially automated means, or non-automated means provided that they form part of a data recording system; via our Company's https://vibseen.com website and mobile application, electronic forms, e-mail, call channels, request/complaint platforms, Company information technology systems, cookies and similar technologies, and any other channels that may be added to the Platform in the future.

3. Processed Personal Data Categories, Purposes of Processing, and Legal Grounds

The categories of your personal data processed within the framework of your membership relationship with our Company, the purposes of processing, and the legal grounds are explained in the table below.

Important Note: Only natural persons who have completed the age of 18 can create a membership on their own behalf on the Platform.

Personal Data Categories

Data Processing Purposes

Legal Ground

Identity Data (e.g., name-surname), Contact Data (e.g., e-mail address), Customer Transaction Data (e.g., membership and subscription info, billing info), Financial Data (e.g., payment info)

Fulfillment of obligations explicitly stipulated in the laws (e.g., issuing invoices, obtaining commercial electronic communication consents and reporting them to relevant systems); making necessary notifications to authorized institutions and organizations; carrying out retention and archiving activities

KVKK Art. 5/2(a) — explicit provision in the laws

Identity Data, Contact Data, Customer Transaction Data, Transaction Security Data (e.g., membership log records, IP info, OTP info), Legal Transaction Data (e.g., contract info to which you are party)

Establishment and performance of the Membership Agreement; creating a User profile on the Platform, verifying, activating, managing, and terminating membership; conducting communication activities within the scope of the contractual relationship; handling billing, payment, and accounting transactions related to paid services, if any; executing information security processes

KVKK Art. 5/2(c) — necessity for the establishment or performance of a contract

Identity Data, Contact Data, Transaction Security Data, Legal Transaction Data, Request/Complaint Data

Fulfillment of legal obligations; planning and execution of legal affairs, including the management of dispute processes to which our Company is party; making necessary notifications to authorized institutions and organizations; carrying out retention and archiving activities

KVKK Art. 5/2(ç) — necessity for the data controller to fulfill its legal obligation

Identity Data, Contact Data, Customer Transaction Data, Request/Complaint Data, Transaction Security Data

Receiving, evaluating, and concluding requests, complaints, and suggestions; ensuring quality management, including product/service/process improvement and development; execution and auditing of business activities; performing legal and financial due diligence in potential mergers, acquisitions, and restructuring; executing information security processes

KVKK Art. 5/2(f) — necessity for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject

Identity Data, Contact Data, Marketing Data (e.g., cookie records, campaign info, info on content of interest)

Execution of advertising, campaign, promotion, and information activities; planning and conducting commercial electronic communication activities; conducting analysis studies for promotions

KVKK Art. 5/1 — existence of explicit consent

Health Data (e.g., health topic details contained within search queries and watch history associated with the account)

Providing personalized search, watch history, saved content, and recommendation feed features on the Platform; matching content tailored to the User's expectations and needs

KVKK Art. 6 — existence of explicit consent

Health Data (limited to the scope specified above)

Establishment, exercise, and protection of rights in potential dispute proceedings to which our Company is a party; carrying out retention and archiving activities

KVKK Art. 6/3 — necessity for the establishment, exercise, or protection of a right

Explanation regarding health data: The searches you perform on the Platform may relate to health topics. Processing these queries and your watch history by associating them with your account is based solely on your explicit consent. If you do not grant explicit consent, you can still continue using the Platform; however, personalized features (history, saved content, recommendation feed) cannot be provided. Our Company does not create any medical records or patient charts about you.

4. Transfer of Your Personal Data to Third Parties Located Nationally and Internationally

Your personal data processed under each personal data category specified above may be transferred to the following groups of recipients in accordance with Articles 8 and 9 of the KVKK, and provided that the legal grounds specified above for the relevant data category also exist in terms of transfer purposes:

• To our domestic and/or international suppliers who provide information technologies, data hosting (cloud), security, analytics, e-mail/notification, payment, customer support, and AI infrastructure services, for the purposes of operating the Platform, ensuring its security, hosting content, executing user support processes, handling payments/billing, managing e-mail and notification infrastructures, and conducting analytics, product development, and AI-powered content analysis processes (based on adequacy decisions, standard contractual clauses, or other applicable safeguard mechanisms provided in the relevant legislation under KVKK Art. 9 for parties located abroad),

• When necessary, to our domestic and/or international business partners and affiliates/group companies, for the purpose of executing and coordinating Company activities and Platform operations (based on appropriate safeguard mechanisms under KVKK Art. 9 for international transfers),

• To domestic banks and payment institutions to carry out payment transactions regarding paid services, if any,

• To authorized public institutions and organizations for the purposes of fulfilling our legal obligations and following up legal affairs.

5. Your Rights Under the KVKK

As a personal data subject, you hold rights within the scope of Article 11 of the KVKK. Accordingly, you have the right to learn whether your personal data is processed, request information if it has been processed, learn the purpose of processing and whether it is used in line with its purpose, know the third parties to whom it is transferred domestically or abroad, request correction if it is processed incompletely or inaccurately, request its deletion or destruction within the framework of the conditions stipulated in Article 7 of the KVKK, request notification of these transactions to the third parties to whom it is transferred, object to any outcome against you by analyzing it exclusively through automated systems, and demand indemnification of damages in case you suffer damage due to unlawful processing.

You can submit your applications regarding these rights to our Company through the following channels, in accordance with the provisions of the Communiqué on the Procedures and Principles of Application to the Data Controller, along with information and documents verifying your identity. Your applications will be concluded as soon as possible and within thirty days at the latest, depending on the nature of the request.

Postal Address: Atlas Üniversitesi TEKMER, Hamidiye Mah. Anadolu Cad. No:40, Kağıthane / İstanbul

E-Mail Address: kvkk@vibseen.com

The data of Users whose active accounts are closed is retained for the reasonable periods stipulated in the relevant legislation or required for the purpose of processing, limited to what is necessary for our legal obligations, payment/invoice/accounting processes, information security logs, and the protection of our rights in potential disputes. When the reason for retention no longer exists, personal data is deleted, destroyed, or anonymized.

Vibseen Medikal Teknoloji Ticaret Anonim Şirketi Healthcare Professional Privacy Notice

Last updated: June 17, 2026

1. Data Controller

This Privacy Notice explains the personal data processing activities conducted with respect to physicians, dentists, and other healthcare practitioners ("Healthcare Professional") who apply to create content and/or hold a verified account on the video-based health information platform operated by our Company ("Platform").

2. Methods of Collecting Personal Data

Your personal data is collected through the application and profile forms on the Platform, e-mail, call channels, documents and content you upload, and relevant official and/or professional registries consulted for identity and expertise verification, or supporting documents provided by you, through fully or partially automated means, or non-automated means provided that they form part of a data recording system.

3. Processed Personal Data Categories, Purposes of Processing, and Legal Grounds

Personal Data Categories

Data Processing Purposes

Legal Ground

Identity Data (e.g., name-surname, TR Identity Number), Professional Experience Data (e.g., medical specialty, diploma and certificate of expertise info, practicing institution), Contact Data (e.g., e-mail, phone)

Conducting Healthcare Professional identity and medical specialty verification through official or professional records and/or supporting documents; establishing and maintaining the verified membership status

KVKK Art. 5/2(c) — necessity for the establishment or performance of a contract; KVKK Art. 5/2(f) — necessity for the legitimate interests of the data controller to ensure Platform security, protect the verified health professional status, and ensure users can access reliable health information

Identity Data, Contact Data, Professional Experience Data, Visual and Auditory Recording Data (e.g., uploaded video contents, profile photo), Customer Transaction Data (e.g., subscription and bundle info)

Creating, managing, and publicly publishing your profile and channel; hosting uploaded contents, analyzing them with AI, categorizing them by medical branch and specialty, and subjecting them to trust scoring; generating the trust score based on criteria such as academic publications, clinical guidelines, official data, content recency, and specialty alignment; the score's potential effect on visibility on the Platform; the Healthcare Professional's right to appeal the evaluation by submitting additional information, sources, or documents; providing analytical data regarding content performance

KVKK Art. 5/2(c) — establishment or performance of a contract

Identity Data, Financial Data (e.g., invoice and payment info, bank account info)

Handling billing, payment, and accounting transactions for paid services; making statutory disclosures

KVKK Art. 5/2(a) — explicit provision in the laws; Art. 5/2(c) — performance of a contract

Identity Data, Contact Data, Transaction Security Data, Legal Transaction Data, Request/Complaint Data

Fulfillment of legal obligations; ensuring content moderation and compliance with community guidelines; managing dispute processes; retention and archiving activities

KVKK Art. 5/2(ç) and Art. 5/2(f)

Identity Data, Contact Data, Marketing Data

Conducting information, promotion, and commercial electronic communication activities regarding our services

KVKK Art. 5/1 — existence of explicit consent

Explanation regarding profile and tag use: Your verified profile and name/tag field on the Platform are uniquely designated to you; other members cannot tag your name in their own content without your permission. This practice is aimed at protecting your professional reputation and content interaction.

4. Transfer of Personal Data

Your personal data may be transferred, in accordance with Articles 8 and 9 of the KVKK, to our domestic and/or international suppliers, and when necessary, to our business partners and affiliates/group companies, to banks and payment institutions regarding payment processes, and to authorized institutions and organizations within the scope of our legal obligations, for the purposes of operating the Platform, verification, content hosting, AI-powered analysis, security, payment/billing, analytics, user support, and carrying out notification processes. In cases where transfer abroad is required, adequacy decisions, standard contractual clauses, or other appropriate safeguard mechanisms stipulated in the relevant legislation are taken as a basis in accordance with KVKK Art. 9.

Due to the nature of the Platform, your verified profile (name-surname, title, medical specialty, profile photo, and content you upload) is published openly to Platform users.

5. Your Rights Under the KVKK

You can submit your applications regarding your rights under Article 11 of the KVKK through the following channels, along with information and documents verifying your identity. Applications are resolved within thirty days at the latest.

Postal Address: Atlas Üniversitesi TEKMER, Hamidiye Mah. Anadolu Cad. No:40, Kağıthane / İstanbul

E-Mail Address: kvkk@vibseen.com

Personal data related to Healthcare Professional accounts is retained for the reasonable periods stipulated in the relevant legislation or required for the purpose of processing, limited to what is necessary for verification, membership, content publishing, payment/invoice/accounting, information security, and potential dispute processes. When the reason for retention no longer exists, personal data is deleted, destroyed, or anonymized.