Privacy Policy

Effective Date: June 1, 2025

1. Introduction

Vivosel ("we," "us," or "our") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, store, and protect your personal information when you visit our website or interact with our services. We comply with applicable data protection laws, including the European Union General Data Protection Regulation (GDPR), the Turkish Personal Data Protection Law (KVKK), and other relevant international data protection regulations.

2. Data Controller Information

Vivosel acts as the data controller for personal data processed through our website and services. For all privacy-related inquiries, please contact us at the details provided in Section 11.

3. Personal Data We Collect

3.1 Information You Provide Directly

Contact Forms: Name, email address, phone number, organization, and message content
Clinical Trial Inquiries: Contact information, basic demographic data, and relevant medical history (voluntary)
Partnership Inquiries: Professional contact details, organization information, and collaboration interests
Career Applications: Resume/CV, cover letter, contact information, and professional qualifications
Newsletter Subscriptions: Email address and communication preferences

3.2 Information Collected Automatically

Technical Data: IP address, browser type, operating system, device information
Usage Data: Pages visited, time spent on site, referral sources, and interaction patterns
Cookies and Similar Technologies: As detailed in our Cookie Policy

4. How We Use Your Personal Data

4.1 Primary Purposes

Communication: Responding to inquiries, providing requested information, and maintaining correspondence
Clinical Research: Evaluating eligibility for clinical trials, providing study information, and facilitating participation (with explicit consent)
Business Development: Processing partnership inquiries, collaboration opportunities, and professional networking
Recruitment: Reviewing applications, conducting interviews, and managing hiring processes
Website Improvement: Analyzing usage patterns to enhance user experience and site functionality
Compliance: Meeting legal obligations and regulatory requirements

5. Legal Basis for Processing

We process your personal data based on the following legal grounds:

Consent: When you voluntarily provide information through forms or subscribe to communications
Legitimate Interest: For website analytics, security, and business development activities
Contractual Necessity: When processing is necessary for potential agreements or collaborations
Legal Obligation: To comply with applicable laws and regulatory requirements

6. Data Sharing and Disclosure

6.1 Internal Use

Personal data is primarily used internally by authorized Vivosel personnel for the purposes outlined in this policy.

6.2 Third-Party Sharing

We may share your data with:

Service Providers: Technical service providers, hosting companies, and analytics platforms (under strict data processing agreements)
Clinical Partners: Approved medical institutions and research organizations (only with explicit consent for clinical trial purposes)
Legal Requirements: When required by law, court order, or regulatory authorities
Business Transfers: In case of merger, acquisition, or sale of assets (with appropriate safeguards)

7. International Data Transfers

When we transfer personal data outside of Turkey or the EU, we ensure appropriate safeguards are in place, including adequacy decisions, Standard Contractual Clauses, or other legally recognized transfer mechanisms.

8. Data Retention

Contact Inquiries: 3 years from last communication
Clinical Trial Data: As required by regulatory guidelines (typically 15-25 years)
Career Applications: 2 years from application date
Website Analytics: 26 months maximum
Legal Compliance: As required by applicable laws

9. Your Rights

Under GDPR, KVKK, and other applicable data protection laws, you have the following rights:

Access: Request information about your personal data we process
Rectification: Correct inaccurate or incomplete data
Erasure: Request deletion of your personal data (subject to legal limitations)
Restriction: Limit the processing of your data under certain circumstances
Portability: Receive your data in a structured, machine-readable format
Objection: Object to processing based on legitimate interests
Withdraw Consent: Withdraw consent at any time (where consent is the legal basis)

10. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include encryption, access controls, regular security assessments, and staff training.

11. Contact Information

Privacy Officer
Email: info@vivosel.com
Subject Line: "Privacy Inquiry - [Your Request Type]"

For KVKK-related inquiries in Turkey, you may also contact the Turkish Data Protection Authority (Kişisel Verileri Koruma Kurumu).

12. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices or applicable laws. Material changes will be communicated through our website or direct notification. The effective date at the top of this policy indicates the most recent revision.