KVKK Data Storage and Destruction Policy

PIMAK PROFESYONEL KITCHEN LTD STI.
PERSONAL DATA STORAGE AND DESTRUCTION POLICY

PART 1: QUALITY AND PURPOSE OF THE DESTRUCTION POLICY

1.1. LOGIN
This disposal policy belongs to PİMAK PROFESYONEL MUTFAK LTD STİ. In short (“PIMAK”), it has been prepared in order to determine the procedures and principles to be applied by PIMAK regarding the deletion, destruction or anonymization of personal data in accordance with the Personal Data Protection Law No.6698 and other legislation.

In this context, the personal data of our employees, employee candidates, customers and all real persons who have personal data with PIMAK for any reason are managed in accordance with the Laws within the framework of the Personal Data Processing and Protection Policy and this Personal Data Storage and Disposal Policy.

1.2. DEFINITIONS
Direct descriptors: Descriptors that directly reveal, reveal and distinguish the person they are in a relationship with,
Indirect identifiers: Descriptors that reveal, reveal and distinguish the person they are in a relationship with by coming together with other descriptors,
Related person: The real person whose personal data is processed,
Destruction: Deletion, destruction or anonymization of personal data,
Law: Personal Data Protection Law No.6698, published in the Official Gazette dated 07.04.2016 and numbered 29677,
Regulation: The Regulation on the Deletion, Destruction or Anonymization of Personal Data published in the Official Gazette dated 28.10.2017 and numbered 30224.
Board: The Personal Data Protection Board
Recording medium: Any medium containing personal data that is fully or partially automated or processed non-automatically provided that it is a part of any data recording system,
Policy on Processing and Protection of Personal Data: The policy that can be accessed at "www.pimak.com", determining the procedures and principles regarding the management of personal data held by PIMAK,
Data recording system: The recording system in which personal data are structured and processed according to certain criteria,
expresses.

CHAPTER 2: ENVIRONMENTS AND SAFETY PRECAUTIONS

2.1. ENVIRONMENTS WHERE PERSONAL DATA IS STORED
Personal data stored by PIMAK are kept in a recording environment in accordance with the nature of the data and our legal obligations. The recording media used for the storage of personal data are generally listed below. However, some data may be kept in a different environment than the ones shown here due to their special characteristics or our legal obligations. In any case, PIMAK acts as a data controller and processes and protects personal data in accordance with the Law, Personal Data Processing and Protection Policy and this Personal Data Storage and Destruction Policy.

a) Printed media: These are the environments in which data are kept by printing on paper or microfilms.
b) Local digital media: These are the servers, fixed or portable discs, and other digital media such as optical discs within PIMAK.
c) Cloud environments: Although not included in PIMAK, they are environments in which Internet-based systems encrypted with cryptographic methods are used, which are used by PIMAK.

2.2. ENSURING THE SECURITY OF THE ENVIRONMENTS
PIMAK takes all necessary technical and administrative measures in accordance with the characteristics of the environment in which it is kept with the relevant personal data in order to keep personal data securely and to prevent unlawful processing and access.
These measures include, but are not limited to, the following administrative and technical measures to the extent that they are in line with the nature of the relevant personal data and the environment in which it is stored.

2.2.1. Technical Measures
PIMAK takes the following technical measures in accordance with the characteristics of the environment where the personal data is stored and the environment where the relevant data is stored:

■ In environments where personal data are kept, only up-to-date and secure systems in line with technological developments are used.
■ Security systems are used for the environments where personal data are kept.
■ Security tests and researches are carried out to detect security vulnerabilities on information systems, and any existing or potentially risky issues identified as a result of the tests and researches are eliminated.
■ By restricting access to the data in the environments where personal data are kept, only authorized persons are allowed to access these data, limited to the purpose of storing personal data, and all access is recorded.
■ PIMAK has sufficient technical personnel to ensure the security of the environments where personal data are kept.

2.2.2. Administrative Measures
PİMAK takes the following administrative measures in accordance with the characteristics of the environment where the relevant data and data are stored in all environments where personal data are stored:

■ The information security, personal data and privacy of all PIMAK employees who have access to personal data