PERSONAL DATA RETENTION AND DISPOSAL POLICY

1. PURPOSE OF THE POLICY

The purpose of this policy; 5 and 6 of the Regulation (Regulation) on the Deletion, Destruction or Anonymization of Personal Data, which was issued based on the Law (Law) on the Protection of Personal Data No. 6698 and published in the Official Gazette No. 30224 on 28.10.2017. To determine all the rules, roles and responsibilities to be applied throughout MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ in order to fulfill the obligations regarding the storage and destruction of personal data and other obligations specified in the Regulation.

 

2. KAPSAMI POLITICIAN

Policy MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ Personal data defined by the Law No. 6698 and kept throughout (within) ……………… , all MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ employees and personal managers, In all cases where data sharing is in question, it includes its affiliates, external service providers and natural and legal persons with which MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ has other legal relations.

Policy covers personal data in systems where data is processed by fully or partially automated or non-automated means provided that it is a part of any data recording system, as specified in the Law.

Unless otherwise stated in this Policy, it will be generally referred to as "Personal Data" together with personal data and sensitive personal data.

 

3. DEFINITIONS

  • Anonymization: Making personal data impossible to associate with an identified or identifiable natural person under any circumstances, even if it is matched with other data,

  • Destruction: Deletion, destruction (destruction) of personal data,

  • Personal Data: Any information relating to an identified or identifiable natural person,

❖ Personal Data Retention Table (Terms): The table showing the periods during which personal data will be kept before MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ …,

  • Personal Data Processing Inventory: Personal data processing activities carried out by data controllers depending on their business processes; The inventory they have created by associating the personal data with the purposes of processing, the data category, the transferred recipient group and the data subject group, explaining the maximum time required for the purposes for which the personal data is processed, the personal data to be transferred to foreign countries and the measures taken regarding data security,

  • Deletion of Personal Data: The process of making personal data inaccessible and unusable for the relevant users,

  • Destruction (Destruction) of Personal Data: The process of making personal data inaccessible, unrecoverable and unusable by anyone in any way,

  • Special Qualified Personal Data: Data related to the race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, disguise and dress, membership to associations, foundations or unions, health, sexual life, criminal convictions and security measures, and biometric data. and genetic data,

  • Periodic destruction: The deletion, destruction or anonymization process, which will be carried out ex officio at repetitive intervals and specified in the personal data storage and destruction policy, in case all the conditions for processing personal data in the law are eliminated,

  • Data registration system: The registration system in which personal data is processed and structured according to certain criteria,

  • Direct identifiers: identifiers that , by themselves, directly reveal, disclose and distinguish the person with whom they are in a relationship,

  • Indirect Identifiers: Identifiers that come together with other Identifiers to reveal, disclose and distinguish the person they are in a relationship with,

  • Law: Law on Protection of Personal Data No. 6698 published in the Official Gazette dated 07.04.2016 and numbered 29677,

  • Regulation: Regulation on the Deletion, Destruction or Anonymization of Personal Data published in the Official Gazette dated 28.10.2017 and numbered 30224 ,

  • Board: Personal Data Protection Board,

  • Recording medium : Any medium containing personal data that is fully or partially automated or processed by non-automatic means, provided that it is a part of any data recording system,

  • Personal Data Protection and Processing Policy: ” www.masculini.com

The policy that determines the procedures and principles regarding the management of personal data held by "MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ",

  • Data recording system: It refers to the recording system in which personal data is processed and structured according to certain criteria.

 

4. RECORDING MEDIA REGULATED BY POLICY

Any medium containing personal data that is fully or partially automated or processed by non-automatic means, provided that it is a part of any data recording system, is within the scope of the recording medium.

 

4.1. ENVIRONMENTS WHERE PERSONAL DATA IS STORED

Personal data stored at “MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ  are kept in a recording environment in accordance with the nature of the relevant data and our legal obligations within the scope of ISMS (ISO 27001:2013).

The recording media used for the storage of personal data are generally listed below. However, some data may be found and kept in a different environment than the ones shown here, due to their special qualities or our legal obligations. “ MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ .. “ acts as a data controller, in accordance with the KVK Law, the Policy on the Protection and Processing of Personal Data, this Personal Data Retention and Disposal Policy and in accordance with the ISMS (ISO 27001:2013). It operates and protects.

 

a) Printed media

They are media where data is kept by printing on paper or microfilms.

b) Local digital environments

“Servers within MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ are other digital media such as fixed or portable disks, optical disks.

c) Cloud environments

Although not within the body of MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ, "MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ " uses cryptographic methods.

 

environments where encrypted internet-based systems are used.

4.2. SECURING ENVIRONMENTS

“ MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ takes all necessary technical and administrative measures within the scope of ISMS (ISO 27001:2013) in accordance with the characteristics of the environment in which the personal data is kept with the relevant personal data in order to keep personal data safe and to prevent unlawful processing and access.

These measures include, but are not limited to, the following administrative and technical measures within the scope of ISMS (ISO 27001:2013) to the extent that they comply with the nature of the personal data and the environment in which it is kept.

4.2.1. Technical Measures

MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ takes the following technical measures in accordance with the characteristics of all environments where personal data is stored and the environment where the data is kept:

  • Only up-to-date and secure systems suitable for technological developments are used in environments where personal data is kept. Security systems are used for environments where personal data is kept.

  • Security tests and research are carried out to detect security vulnerabilities on information systems, and the existing or potential risky issues identified as a result of the tests and researches are eliminated.

  • Access to the data is restricted to the environments where personal data is kept, and only authorized persons are allowed to access this data limited to the purpose of storing personal data.

  • MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ has sufficient technical personnel to ensure the security of the environments where personal data is kept.

 

4.2.2. Administrative Measures

" MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ " takes the following administrative measures within the scope of the KVKK Law in accordance with the characteristics of all environments where personal data is stored and the environment in which the data is kept:

  • Efforts are being made to raise awareness and raise awareness of all “MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ” employees who have access to personal data on information security, personal data and privacy issues.

  • Legal and technical consultancy services are obtained in order to follow the developments in the field of information security, privacy and protection of personal data and to take necessary actions.

  • In the event that personal data is transferred to third parties due to technical or legal requirements, protocols are signed with the relevant third parties in order to protect personal data, and all necessary care is taken to ensure that the relevant third parties comply with their obligations in these protocols.

 

4.2.3. Internal Audit

MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ carries out internal audits in accordance with the KVKK Law regarding the implementation of the provisions of the Law and the provisions of this Personal Data Storage and Disposal Policy and Personal Data Protection and Processing Policy in accordance with Article 12 of the Law.

If deficiencies or defects regarding the implementation of these provisions are detected as a result of internal audits, these deficiencies or faults are immediately corrected.

In case it is understood that the personal data under the responsibility of “MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ” has been obtained illegally by others during the audit or otherwise, “MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ notifies the relevant person and the Board as soon as possible.

5. DUTIES AND AUTHORITIES OF THE PERSONAL DATA PROTECTION COMMITTEE

5.1. The Personal Data Protection Committee is responsible for the announcement of the Policy to the relevant business units and the follow-up of the fulfillment of the requirements by the units of MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ .

5.2. The Personal Data Protection Committee makes the necessary announcements and notifications for the relevant business units to follow up on the legislation changes regarding the protection of personal data, regulatory acts and decisions of the Board, court decisions or changes in the processes, practices and systems, and update their business processes if necessary,

 

5.3. Personal Data Protection Committee; It determines the processes for the examination, evaluation, follow-up and conclusion of the law and its secondary regulations as well as the decisions and regulations of the Board, court decisions and decisions and/or requests of other competent authorities and announces them to the relevant units.

 

6. WHAT TO DO IN CASE THE CONDITIONS FOR THE PROCESSING OF PERSONAL DATA AVOID

6.1. In the event that the purpose factor for the processing of personal data is eliminated, the express consent is withdrawn, or all the conditions for processing personal data in Articles 5 and 6 of the Law are eliminated, or if there is a situation where none of the exceptions in the aforementioned articles can be applied, the processing conditions are eliminated. Personal data is deleted, destroyed (destroyed) or anonymized by the relevant business unit, taking into account business needs, within the scope of Articles 7, 8, 9 or 10 of the Regulation, by explaining the reason for the method applied. However, in case of a finalized court decision, the method of destruction determined by the court decision must be applied.

6.2. All users who process or store personal data and the data owner "MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ " units will review whether the conditions related to processing have been eliminated, within four-month periods at the latest, in the data recording media they use. Upon the application of the personal data owner or the notification of the Board or a court, the relevant users and units will make this review in the data recording media they use, regardless of the period of periodic inspection.

6.3. As a result of periodic reviews or at any time, when it is determined that the data processing conditions have been removed, the relevant user or data owner will decide to delete, destroy (destroy) or anonymize the relevant personal data from the recording medium in his/her own responsibility, in accordance with this policy. In case of hesitation, action will be taken by obtaining the opinion of the relevant data owner business unit. When it is necessary to take a decision regarding the destruction of personal data with multi-stakeholder data ownership in the Central Information Systems, the opinion of the Personal Data Protection Committee will be taken and the personal data in question will be stored or deleted, destroyed (destroyed) or anonymized in accordance with this policy. will be decided by the relevant data owner business unit.

6.4. All transactions regarding the deletion, destruction (destruction) or anonymization of personal data are recorded and these records are kept for at least three years, excluding other legal obligations.

6.5. Pursuant to Article 7.4 of the Regulation, the methods applied for the deletion, destruction (destruction) and anonymization of personal data will be published and announced after the Policy goes into effect.

6.6. In deleting, destroying (destroying) or anonymizing personal data, it is obligatory to act in accordance with the general principles in Article 4 of the Law and the technical and administrative measures to be taken within the scope of Article 12, the provisions of the relevant legislation, Board decisions and court decisions.

6.7. The real person who owns a personal data, pursuant to Article 13 of the Law, "MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ ……………….."When it requests the deletion, destruction or anonymization of its personal data, the relevant data owner business unit examines whether all conditions for processing personal data have been eliminated. If all the processing conditions have disappeared; deletes, destroys or anonymizes the personal data subject to the request. In this case, the details are as determined in the Data Disposal Procedure in the ISO 27001:203 Information Security Management System; The request is finalized within thirty days at the latest from the date of application and the person concerned is informed through the KVKK contact person appointed by the KVKK Officer. If all the conditions for processing personal data have been removed and the personal data subject to the request has been transferred to third parties,

6.8. In cases where the conditions for processing personal data are not completely eliminated, the requests of personal data owners for the deletion or destruction of their data may be rejected by “MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ  by explaining the reason in accordance with paragraph 3 of Article 13 of the Law. The rejection response is notified to the relevant person in writing or electronically within 30 days at the latest.

 

 

6.9. Requests for the deletion or destruction of personal data will only be considered if the identity of the person concerned has been identified. In requests to be made outside of the said channels, the relevant persons will be directed to the channels where identification or verification can be made.

 

7. POLICY IMPLEMENTATION, VIOLATIONS AND SANCTIONS

7.1. This Policy will enter into force by announcing on the website of all employees and Personal data owners of " MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ " and as of its effectiveness, all business units, consultants, customers, insurance companies, external service providers and other MASCULINI TEKSTİL GİYİM GİYİM SANAYİ VE TİCARET TİCARET TİCARET It will be binding on everyone who processes personal data before …………………..

 

7.2.  MASCULINI TEXTILE CLOTHING INDUSTRY AND TRADE LIMITED COMPANY ……….  It will be the responsibility of the supervisors of the relevant employees to monitor whether the employees fulfill the requirements of the Policy. When a violation of the policy is detected, the issue will be immediately reported to a higher supervisor by the supervisor of the relevant employee. If the violation is significant, the Personal Data Protection Committee will be informed without delay by the superior.

 

7.3. Necessary administrative action will be taken against the employee who violates the policy, after the evaluation by Human Resources.

7.4. In order to fulfill the policy requirements, “ MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ . by “ ; All necessary security measures are taken within the scope of KVKK Law.

 

8. PERSONS TO BE INVOLVED IN PERSONAL DATA STORAGE AND DISPOSAL AND THEIR RESPONSIBILITIES

All employees, customers, insurance companies, consultants, external service providers and otherwise " MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET ŞİRKETİ ... . “ Everyone who stores and processes personal data is responsible for fulfilling these requirements.

Each business unit is obliged to store and protect the data it produces in its own business processes; however, if the data produced is only available in information systems outside the control and authority of the business unit, the data in question will be stored by the units responsible for information systems.

Periodic destructions, which will affect business processes and cause data integrity, data loss and results contrary to legal regulations, will be made by the relevant information systems departments, taking into account the type of personal data, the systems in which it is included, and the data owner business unit.

 

8.1. PERSONAL DATA PROTECTION COMMITTEE

MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ “has a Personal

Establishes the Data Protection Committee. The Personal Data Protection Committee is authorized and in charge of taking the necessary actions and supervising the processes for the storage and processing of the data of the persons concerned in accordance with the law, the Personal Data Protection and Processing Policy and the Personal Data Retention and Disposal Policy.

The Personal Data Protection Committee consists of at least three people: a manager, an administrative expert and a technical expert. The titles and job descriptions of the employees of " MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ ……… " who work in the Personal Data Committee are as follows:

 

 

 

Title

Job Description

Personal Data Protection Committee Manager

To direct all kinds of planning, analysis, research and risk determination studies in the projects carried out in the process of compliance with the law; It is obliged to manage the processes that must be carried out in accordance with the Law, the Personal Data Protection and Processing Policy and the Personal Data Storage and Disposal Policy and to decide on the requests received by the relevant persons.

KVK Specialist (Liaison Officer)

(Technical and Administrative)

Reporting the requests of the persons concerned to the Personal Data Committee Manager for review and evaluation; By Personal Data Committee Manager

Fulfilling the transactions regarding the requests of the data subjects that are evaluated and decided in accordance with the decision of the Personal Data Committee Manager; auditing the storage and destruction processes and reporting these audits to the Personal Data Committee Manager; Responsible for the execution of storage and destruction processes.

8.2. REASONS FOR STORAGE AND DISPOSAL

8.2.1. Reasons for Storage

Personal data held within MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ are stored in accordance with the Law and our Personal Data Policy (you can access the relevant policy at www.masculini.com ) for the purposes and reasons stated here.

8.2.2. Reasons for Disposal

Personal data contained in “MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ” is deleted, destroyed (destroyed) or anonymized ex officio in accordance with this destruction policy, upon the request of the person concerned or in case the reasons listed in Articles 5 and 6 of the Law are eliminated. is made. The reasons listed in Articles 5 and 6 of the KVKK Law consist of the following:

  1. expressly stipulated in the law.

  2. It is compulsory for the protection of life or physical integrity of the person or someone else, who is unable to express his consent due to actual impossibility or whose consent is not legally valid.

  3. It is necessary to process the personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract.

  4. It is mandatory for the data controller to fulfill its legal obligation.

  5. Being made public by the person concerned.

  6. Data processing is mandatory for the establishment, exercise or protection of a right.

  7. Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

8.3. DISPOSAL METHODS "

MASCULINI TEXTILE CLOTHING INDUSTRY AND TRADE LIMITED COMPANY …. “Delete, ex officio, upon the request of the person concerned or within the periods specified in this Personal Data Retention and Destruction Policy, in case the reasons requiring the processing of the data disappear, in accordance with the Law and other legislation and the Personal Data Protection and Processing Policy. ) or make it anonymous.

The most used deletion, destruction and anonymization techniques by " MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ " are listed below:

 

 

8.3.1.1 Deletion Methods

Deletion Methods for Personal Data Held in Printed Media

Blackout

Personal data in the printed media are deleted using the blackout method. The blackening process is done by cutting the personal data on the relevant document when possible, and making it invisible by using fixed ink in a way that it cannot be readable with technological solutions, in cases where it is not possible.

Deletion Methods for Personal Data Held in Cloud and Local Digital Environment

Secure deletion from software

Personal data kept in the cloud or local digital environments are deleted with a digital command, irrecoverably. Data deleted in this way cannot be accessed again.

8.3.1.2 Disposal Methods

Destruction Methods for Personal Data Held in Printed Media

physical destruction

Documents kept in printed media are destroyed in a way that they cannot be reassembled with document shredders.

Destruction Methods for Personal Data Held in Local Digital Environment

physical destruction

It is the process of physically destroying optical and magnetic media containing personal data, such as melting, burning or pulverizing. Data is rendered inaccessible by processes such as melting, incinerating, pulverizing, physically cutting and/or drilling optical or magnetic media, or passing it through a metal grinder.

De-magnetizing (degauss)

It is the process of unreadable corruption of the data on the magnetic media by exposing it to a high magnetic field.

overwrite

At least seven on magnetic media and rewritable optical media

Random data consisting of 0 and 1 is written once, preventing the reading and recovery of old data.

Destruction Methods for Personal Data Held in the Cloud

Secure deletion from software

Personal data kept in the cloud is irrecoverably deleted by digital command, and when the cloud computing service relationship ends, all copies of the encryption keys required to make the personal data usable are destroyed. Data deleted in this way cannot be accessed again.

 

8.3.1.3. Anonymization Methods

Anonymization is making personal data incapable of being associated with an identified or identifiable natural person under any circumstances, even by matching it with other data.

Subtracting variables

It is the removal of one or more of the direct identifiers included in the personal data of the data subject and which will help to identify the person concerned in any way.

This method can be used to anonymize personal data, or it can also be used for deletion of personal data if there is information that is not suitable for the purpose of data processing.

Regional hiding

It is the process of deleting the information that may be distinctive about the exceptional data in the data table in which the personal data is collected in an anonymous form.

Generalization

It is the process of bringing together the personal data of many people and turning them into statistical data by removing their distinctive information.

Lower and upper bound coding / Global coding

For a certain variable, the ranges of that variable are defined and categorized. If the variable does not contain a numeric value, then close data in the variable are categorized.

Values ​​within the same category are combined.

Micro-joining

With this method, all the records in the dataset are first meaningfully

 

are arranged in order, and then the whole cluster is divided into a certain number of subsets. Then, by taking the average of the value of each subset of the determined variable, the value of that variable of the subset is replaced with the mean value. In this way, since the indirect identifiers in the data will be corrupted, it is difficult to associate the data with the relevant person.

Data hashing and tampering

Direct or indirect identifiers in personal data are mixed with other values ​​or their relationship with the person concerned is broken and they lose their descriptive qualities.

" MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ " uses one or more of these anonymization methods, depending on the nature of the data, in order to anonymize personal data. MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ “ may use K-Anonymity, L-Diversity and T-Proximity statistical methods while using these anonymization methods.

 

9. PERSONAL DATA STORAGE AND DISPOSAL TIMES

Table showing the Periods of Retention and Disposal of Personal Data is given in Annex: 1. The storage and destruction periods in question will be taken into account in the periodic destruction or on-demand destruction processes. The Table Showing the Periods of Storage and Disposal of Personal Data will be updated by the business units that own the processes to be included in the personal data inventory of MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ, in case of hesitation, by taking the evaluations of the Personal Data Protection Committee.

 

 

9.1. Personal Data Retention Table (Terms)

DATA OWNER

DATA CATEGORY

DATA STORAGE PERIOD

Worker

With the recruitment documents to the Social Security Institution; Personnel data that is the basis for notifications regarding length of service and wages

It is retained for a period of 50 (fifty) years after the continuation of the service contract and from the end of it.

Worker

With the recruitment documents to the Social Security Institution; Personnel data excluding the personnel data that is the basis for notifications regarding the length of service and wages

It is retained for 10 (ten) years from the beginning of the calendar year following the continuation of the service contract and the end of it.

Worker

Data in the Workplace Personal Health File

It is retained for a period of 30 (thirty) years from the end of the service contract.

Business Partner/Solution Partner/Consultant

Identity information, contact information, financial information regarding the execution of the commercial relationship between the Business Partner/Solution Partner/Consultant and “ ………………… ”, voice recordings of phone calls, Business Partner/Solution Partner/Consultant

During and after the business/commercial relationship of the Business Partner/Solution Partner/Consultant with “ ………………… “, Turkish Code of Obligations Art. 146

10(ten) years pursuant to Article 82 of the Commercial Code

 

 

employee data

stored for a period of time.

Visitor

The name, surname, TCKN, license plate and camera recordings of the Visitor taken at the entrance to the physical space belonging to “………………..”, voice recordings from phone calls

It is stored for 2 (two) years.

Website Visitor

Name, surname, e-mail address, navigational information of the Website Visitor

It is stored for 2 (two) years.

Employee Candidate

Information in the CV and job application form of the Employee Candidate

It is kept for a maximum of 2 (two) years, until the CV loses its currency.

Intern student)

Information in the internship file of the intern

It is retained for 10 (ten) years from the beginning of the calendar year following the end of the internship relationship.

Customer

Customer's name, surname, TCKN, contact information, payment information and methods, navigational movements, voice recordings from phone calls, product/service preferences, transaction history, special day information

It is kept for 10 (ten) years in accordance with Turkish Code of Obligations Art.146 and Turkish Commercial Code Art.82 from the presentation of each product/service purchased by the Customer.

Customer

Camera images, license plate information

It is stored for 2 (two) years.

Potential Customer

Identity information, contact information, financial information obtained during the contract negotiations between the potential customer and MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ ", and voice recordings of phone calls

It is stored for 2 (two) years.

“MASCULINI TEXTILE CLOTHING INDUSTRY AND TRADE LIMITED COMPANY

“In Collaboration of

Institution/

………… (Supplier,

Contract Manufacturer,

Bayi/Franchise

“……………….. with the Institutions/Companies Collaborating with “  ……………. “ Identity information, contact information, financial information regarding the execution of the commercial relationship between “ 

“…………………. “The Institutions/Firms That Are Cooperating With, “  ……………….“

It is kept for 10 (ten) years in accordance with Turkish Code of Obligations Art.146 and Turkish Commercial Code Art.82 during and after the end of the business/commercial relationship.

 

* If it has been issued for a longer period in accordance with the legislation, or in accordance with the legislation, the statute of limitations, foreclosure period, retention periods, etc. If a longer period is foreseen for the storage period, the periods in the provisions of the legislation are considered as the maximum storage period.

 

3.3.2. Disposal Times

“MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ”, the date on which the obligation to delete, destroy (destroy) or anonymize personal data for which it is responsible in accordance with the Law, relevant legislation, Personal Data Protection and Processing Policy and this Personal Data Storage and Destruction Policy arises. deletes, destroys or anonymizes personal data in the first subsequent periodical destruction process.

When the person concerned applies to “MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ” pursuant to Article 13 of the Law and requests the deletion or destruction of his/her personal data;

  1. If all the conditions for processing personal data have disappeared; “MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ ………….. ” deletes, destroys or anonymizes the personal data subject to the request, by explaining the reason within 30 (thirty) days from the day it receives the request. In order for MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ to be deemed to have received the request, the person concerned must have made the request in accordance with the Personal Data Protection and Processing Policy. " MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ ", in any case, informs the person concerned about the transaction.

  2. If all the conditions for processing personal data have not been eliminated, this request may be rejected by " MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ ..... " by explaining the reason in accordance with the third paragraph of Article 13 of the Law, and the refusal can be answered in writing or electronically within thirty days at the latest. reported in the environment.

10. PERIODIC DISPOSAL TIMES

In the event that all the conditions for processing personal data in the KVKK Law No. 6698 disappear; “MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ” processing conditions have been removed.

It deletes, destroys (destroys) or anonymizes the personal data that is within the scope of this Personal Data Retention and Disposal Policy, with an action to be carried out ex officio at repetitive intervals.

Periodic destruction processes start for the first time on 30.09.2019 and repeat every 6 (six) months.

 

 

 

10.1. AUDIT OF LEGAL COMPLIANCE OF DISPOSAL

MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ ………….. “, in accordance with the Law, other legislation, Personal Data Protection and Processing Policy and this Personal Data Retention and Disposal Policy, the destruction processes carried out ex officio, both upon request and during periodic destruction processes. it does.

MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ takes a number of administrative and technical measures to ensure that the destruction processes are carried out in accordance with these regulations.

10.1.1. Technical Measures

  • MASCULINI TEXTILE CLOTHING INDUSTRY AND TRADE LIMITED COMPANY ……. “provides technical tools and equipment suitable for each disposal method in this policy.

  • MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ “ ensures the safety of the place where destruction operations are made.

  • MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ “ keeps the access records of the persons who carry out the destruction process.

  • “MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ” employs competent and experienced personnel to carry out the destruction process or receives service from competent third parties when necessary.

10.1.2. Administrative Measures

MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ " " works to raise awareness and raise awareness of its employees about information security, personal data and privacy of private life.

  • MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ takes legal and technical consultancy services to follow the developments in the field of information security, privacy, protection of personal data and safe destruction techniques and to take necessary actions.

  • MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ "signs protocols with relevant third parties for the protection of personal data in cases where it has third parties to destroy due to technical or legal requirements, and takes all necessary care to ensure that the relevant third parties comply with their obligations in these protocols.

  • MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ regularly checks whether the destruction processes are carried out in accordance with the law and the conditions and obligations set forth in this Personal Data Storage and Disposal Policy, and takes the necessary actions.

All transactions regarding the deletion, destruction and anonymization of personal data are recorded and these records are kept for at least three years, excluding other legal obligations.

11. ENFORCEMENT

    1. The policy will enter into force as of the date of publication.

    2. It is the responsibility of the Personal Data Protection Committee to announce the policy throughout MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ and to make the necessary updates.

12. UPDATE and COMPLIANCE

“ MASCULINI TEKSTİL GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ …………….. “, due to the changes made in the Law, in accordance with the decisions of the Institution or in line with the developments in the sector or in the field of information, Personal Data Protection and Processing Policy or this Personal Data Retention and Destruction It reserves the right to make changes in its policy.

Changes made in this Personal Data Retention and Disposal Policy will be processed in the text without delay and explanations regarding the changes are announced at the end of the policy.