LEGAL NOTICE

It is forbidden to copy, reproduce, use, publish and distribute all content contained in this Policy text, in whole or in part, without permission, except for individual use. Legal action will be taken against those who do not comply with this prohibition in accordance with the Law No. 5846 on Intellectual and Artistic Works. All rights of the product are reserved.

1.INTRODUCTION

1.1 Objective

Personal Data Storage and Destruction Policy (“Policy”) has been prepared in line with the decisions of the Personal Data Protection Board and the Personal Data Protection Law No. 6098 in order to determine the procedures and principles regarding the works and transactions regarding the storage and destruction activities carried out by “Karayel Arge Dış Ticaret Hizmetleri” (“Karayel Arge” or “Institution”). The Company has prioritized the processing of personal data belonging to its employees, employee candidates, suppliers, service providers, visitors and other third parties in accordance with the Constitution of the Republic of Turkey, international conventions, the Law No. 6698 on the Protection of Personal Data (“Law”) and other relevant legislation and ensuring that the relevant persons effectively exercise their rights.

The works and transactions regarding the storage and destruction of personal data are carried out in accordance with the Policy prepared by the Company in this direction.

1.2 Scope

Personal data belonging to Company employees, employee candidates, service providers, visitors and other third parties are within the scope of this Policy and this Policy is applied in all recording environments where personal data owned or managed by the Company are processed and in activities for personal data processing.

1.3 Abbreviations and Definitions

2.DISTRIBUTION OF RESPONSIBILITIES AND TASKS

All units and employees of the Company actively support the responsible units in taking technical and administrative measures to ensure data security in all environments where personal data is processed in order to prevent unlawful processing of personal data, to prevent unlawful access to personal data and to ensure that personal data is stored in accordance with the law, with the proper implementation of the administrative and technical measures taken by the responsible units within the scope of the Policy, training and awareness of the unit employees, monitoring and continuous supervision. In cases where it is not possible to employ within the Company, the Company provides such support through service providers.

3.RECORDING MEDIA

Personal data is securely stored by the Company in accordance with the law in the environments listed in Table 2.

Archive, Physical Recording, Manual Recording

4.EXPLANATIONS ON STORAGE AND DISPOSAL

Personal data belonging to employees, employee candidates, visitors and employees of third parties, institutions or organizations with whom the Company has a relationship as a service provider are stored and destroyed in accordance with the Law.

In this context, detailed explanations on retention and destruction are given below respectively:

4.1 EXPLANATIONS ON CUSTODY

Article 3 of the Law defines the concept of “Processing of Personal Data”, Article 4 states that the personal data processed must be relevant, limited and proportionate to the purpose for which they are processed and must be retained for the period stipulated in the relevant legislation or required for the purpose for which they are processed, and Articles 5 and 6 list the conditions for processing personal data.

Accordingly, within the framework of the Company's activities, personal data are stored for the period stipulated in the relevant legislation or in accordance with our processing purposes.

4.1.1 Legal Grounds for Retention

Personal data processed within the framework of the Company's activities are retained for the period stipulated in the relevant legislation. In this context, personal data;

• Turkish Constitution
• Law No. 6698 on the Protection of Personal Data,
• Turkish Code of Obligations No. 6098,
• Turkish Commercial Code No. 6102,
• Tax Procedure Law and related secondary legislation,
• Law No. 5510 on Social Security and General Health Insurance,
• Law No. 6361 on Occupational Health and Safety,
• Labor Law No. 4857,
• Regulation on Health and Safety Measures to be Taken in Workplace Buildings and Annexes, Law No. 5651 on the Regulation of Publications on the Internet and Combating Crimes Committed through These Publications,
• They are retained for the retention periods stipulated under other secondary regulations in force pursuant to these laws.

4.1.2 Processing Purposes Requiring Retention

The Company stores the personal data it processes within the framework of its activities for the following purposes.

• To carry out human resources processes.
• To ensure corporate communication.
• Ensuring company security,
• To be able to do statistical studies.
• To be able to perform works and transactions as a result of signed contracts and protocols.
• Within the scope of VERBIS, to determine the preferences and needs of employees, data controllers, contact persons, data controller representatives and data processors, to organize the services provided accordingly and to update them if necessary.
• To ensure that legal obligations are fulfilled as required or mandated by legal regulations.
• To liaise with real/legal persons who have a business and service relationship with the Company.
• Making legal reports.
• Managing call center processes.
• The burden of proof as evidence in future legal disputes.

4.2 REASONS REQUIRING DESTRUCTION

Personal data;

• Amendment or abolition of the relevant legislation provisions that constitute the basis for processing,
• The purpose requiring processing or storage disappears,
• In cases where the processing of personal data is carried out only on the basis of explicit consent, the data subject may withdraw his/her explicit consent,
• Pursuant to Article 11 of the Law, in cases where the Company accepts the application made by the data subject regarding the deletion and destruction of his/her personal data within the framework of his/her rights, the Company rejects the application made by the data subject with the request for the deletion, destruction or anonymization of his/her personal data, finds the answer insufficient or does not respond within the period stipulated in the Law, he/she makes a complaint to the Data Protection Board and this request is approved by the Board,
• In the event that the maximum period required for the retention of personal data has expired and there are no conditions that justify the retention of personal data for a longer period of time, it is deleted, destroyed or ex officio deleted, destroyed or anonymized by the Company upon the request of the person concerned.

5.TECHNICAL AND ADMINISTRATIVE MEASURES

Technical and administrative measures are taken by the Company within the framework of adequate measures determined and announced by the Board for special categories of personal data in accordance with Article 12 of the Law and Article 6, paragraph four of the Law for the safe storage of personal data, prevention of unlawful processing and access and destruction of personal data in accordance with the law.

5.1 TECHNICAL MEASURES

The technical measures taken by the Company regarding the personal data it processes are listed below:

• Through penetration tests, risks, threats, vulnerabilities and vulnerabilities, if any, against the Company's information systems are revealed and necessary measures are taken.
• Risks and threats that will affect the continuity of information systems are continuously monitored as a result of real-time analysis with information security incident management.
• Access to information systems and authorization of users are carried out through access and authorization matrix and security policies through the corporate active directory.
• Necessary measures are taken for the physical security of the Company's information systems equipment, software and data.
• In order to ensure the security of information systems against environmental threats, hardware (access control system that allows only authorized personnel to enter the system room, 24/7 monitoring system, ensuring the physical security of the edge switches that make up the local area network, fire extinguishing system, air conditioning system, etc.) and software (firewalls, attack prevention systems, network access control, malware prevention systems, etc.) measures are taken.
• Risks to prevent unlawful processing of personal data are identified, technical measures are taken in accordance with these risks and technical controls are carried out for the measures taken.
• Access procedures are established within the Company and reporting and analysis studies are carried out regarding access to personal data.
• Access to storage areas containing personal data is recorded and inappropriate access or access attempts are kept under control.
• The Company takes necessary measures to ensure that deleted personal data is inaccessible and non-reusable for the relevant users.
• In the event that personal data is unlawfully obtained by others, an appropriate system and infrastructure has been established by the Company to notify the relevant person and the Board.
• Security vulnerabilities are monitored, appropriate security patches are installed and information systems are kept up-to-date.
• Strong passwords are used in electronic environments where personal data is processed.
• Secure logging systems are used in electronic environments where personal data is processed.
• Data backup programs are used to ensure that personal data is stored securely.
• Access to personal data stored in electronic or non-electronic media is restricted according to access principles.
• Access to the company website is encrypted with SHA 256 Bit RSA algorithm using secure protocol (HTTPS).
• Separate policy has been determined for the security of sensitive personal data.
• Trainings on special categories of personal data security were provided for employees involved in special categories of personal data processing processes, confidentiality agreements were made, and the authorizations of users authorized to access data were defined.
• Electronic media where sensitive personal data are processed, stored and/or accessed are maintained using cryptographic methods, cryptographic keys are kept in secure environments, all transaction records are logged, security updates of the environments are constantly monitored, necessary security tests are regularly carried out / conducted, and test results are recorded,
• Adequate security measures are taken for the physical environments where special categories of personal data are processed, stored and/or accessed, and unauthorized entry and exit are prevented by ensuring physical security.
• If sensitive personal data needs to be transferred via e-mail, it is transferred encrypted with a corporate e-mail address or using a KEP account. If it needs to be transferred via media such as portable memory, CD, DVD, etc., it is encrypted with cryptographic methods and the cryptographic key is kept on different media. If transfer is carried out between servers in different physical environments, data transfer is performed by setting up a VPN between servers or using the sFTP method.
• If the document must be transferred via paper media, necessary precautions are taken against risks such as theft, loss or unauthorized viewing of the document and the document is sent in “confidential” format.

5.2 ADMINISTRATIVE MEASURES

The administrative measures taken by the Company regarding the personal data it processes are listed below:

• In order to improve the quality of employees, trainings are provided on preventing unlawful processing of personal data, preventing unlawful access to personal data, ensuring the protection of personal data, communication techniques, technical knowledge skills, Law No. 6698 and other relevant legislation.
• Confidentiality agreements are signed by employees and service providers regarding the activities carried out by the Company.
• A disciplinary procedure has been prepared for employees who do not comply with safety policies and procedures.
• Before starting to process personal data, the Company fulfills its obligation to inform the data subjects.
• Person-based and unit-based personal data processing inventory was prepared.
• Internal periodic and random audits are conducted.
• Information security trainings are provided for employees.

6.PERSONAL DATA DESTRUCTION TECHNIQUES

At the end of the period stipulated in the relevant legislation or at the end of the retention period required for the purpose for which they are processed, personal data shall be destroyed by the Company ex officio or upon the application of the person concerned by the following techniques in accordance with the provisions of the relevant legislation.

6.1 DELETION OF PERSONAL DATA

6.2 DESTRUCTION OF PERSONAL DATA

6.3 ANONYMIZATION OF PERSONAL DATA

Anonymization of personal data is the process of making personal data impossible to associate with an identified or identifiable natural person under any circumstances, even if the personal data is matched with other data.

In order for personal data to be anonymized, personal data must be rendered unrelated to an identified or identifiable natural person, even through the use of techniques appropriate for the recording medium and the relevant field of activity, such as the reversal of personal data by the data controller or third parties and/or the matching of data with other data. Therefore, in practice, data sets are rendered “irreversible” through the methods of “obfuscation”, “de-identification”, “interruption and prevention of connection with the person” used for the anonymization of personal data. With the anonymization of the data, the Company prevents access to the data of the real person with one or more information.

7.STORAGE AND DESTRUCTION PERIODS

Regarding the personal data processed by the Company within the scope of the Company's activities;

• All personal data (personal data, special categories of personal data) within the scope of the activities carried out depending on the processes and the retention periods on the basis of personal data in the Personal Data Processing Inventory of the Company,
• Retention periods based on data categories are recorded in VERBIS,
• Process-based retention periods are included in the Personal Data Retention and Destruction Policy.
• Such retention periods shall be updated by the Company as and when required.
• Ex officio deletion, destruction or anonymization of personal data whose retention periods have expired shall be carried out by the Company and the company employee or a representative of the company who has been authorized to represent the destruction of data in accordance with the law and signed a confidentiality agreement.

8. STORAGE PERIODS

9.PERIODIC DESTRUCTION PERIOD

Pursuant to Article 11 of the Regulation on Deletion, Destruction or Anonymization of Personal Data, the Company has determined the periodic destruction period as 6 months. Accordingly, the Company performs periodic destruction in December of the year in which it registers to the Data Controllers Registry Information System (VERBIS), and in June and December of each subsequent year.

10.PUBLICATION AND STORAGE OF THE POLICY

The Policy is published in two different media, wet signed (printed paper) and electronic media, and disclosed to the public on the website. Everyone has the right to obtain information on how their data is processed, stored, security measures and destruction policies within the limits stipulated by the Law. In this way, all groups of persons receiving services from our Company can access our Company's “Data Processing Policy” and “Data Storage and Destruction Policy”. The printed paper copy is also kept under record in the Company's Archive Documentation System.

11.PERIOD FOR UPDATING THE POLICY

The Policy is reviewed at regular intervals and the necessary sections are updated in line with the decisions of the Data Protection Board and to ensure data security.

12.ENFORCEMENT AND REPEAL OF THE POLICY

The Policy shall be deemed to have entered into force upon its publication on the Company's website. In the event that the Company decides to amend, update or repeal the Policy, the old wet-signed copies of the Policy shall be signed by the Company by stamping or writing cancellation.

The Application to the Data Controller is kept under record in the Company's Archive Documentation System for at least 5 (five) years in order to be submitted in case of audit, request or investigation by the Data Protection Board.