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SLEEVE MAKINA INDUSTRY AND TRADE LIMITED COMPANY PERSONAL DATA STORAGE AND DESTRUCTION POLICY

1. INTRODUCTION

1.1 Purpose

This Personal Data Storage and Destruction Policy ("Policy") is applied to the entire SLEEVE MAKİNA SANAYİ VE TİCARET LİMİTED ŞİRKETİ (hereinafter referred to as "Company") within the framework of the applicable legislation and is based on nationally accepted basic principles regarding personal data destruction. It contains the framework and principles for carrying out the necessary destruction activities within the scope of the relevant legislation.

The third paragraph of Article 7 of the Personal Data Protection Law ("Law") contains the provision "The procedures and principles regarding the deletion, destruction or anonymization of personal data are regulated by the regulation." Based on this provision and subparagraph (e) of the first paragraph of Article 22 of the Law, the Regulation on Deletion, Destruction or Anonymization of Personal Data ("Regulation") has been prepared by the Personal Data Protection Board ("Board") and dated 28 October 2017. It was published in the Official Gazette No. 30224.

Based on the above regulation, the purpose of this Policy is to determine the procedures and principles regarding the deletion, destruction or anonymization of personal data processed by the Company in the conduct of its activities, in accordance with the Regulation.

1.2.Scope

Personal data belonging to employees working in the Company, employee candidates, visitors, third parties with whom we cooperate and third party employees are within the scope of this Policy, and this Policy applies to all recording environments where personal data owned or managed by the Company is processed and activities related to personal data processing.

2. RESPONSIBILITIES AND DUTIES DISTRIBUTION

All units and employees of the company will ensure that the technical and administrative measures taken by the responsible units within the scope of the Policy are properly implemented, the training and awareness of the unit employees are increased, their monitoring and continuous supervision are prevented, preventing the unlawful processing of personal data, preventing unlawful access to personal data and preventing personal data from being accessed unlawfully. It actively supports the responsible units in taking technical and administrative measures to ensure data security in all environments where personal data is processed in order to ensure that personal data is stored in accordance with the law.

3. RECORDING MEDIA

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

4. EXPLANATIONS ON STORAGE AND DISPOSAL

By the company; Personal data of real persons, including employees, employee candidates, suppliers, supplier officials, supplier employees, product or service buyers, shareholders/partners, visitors and other third parties are stored and destroyed in accordance with KVKK.

In this context, detailed explanations regarding storage and disposal are given below.

4.1 Information on Storage

In Article 3 of the Law, the concept of processing personal data is defined, in Article 4, it is stated that the personal data processed should be related to the purpose for which they are processed, limited and proportionate and should be kept for the period foreseen in the relevant legislation or for the period required for the purpose for which they are processed, and in Articles 5 and 6, it is stated that the processing conditions of personal data has been counted.

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

.1.1 Legal Reasons Requiring Storage

The company retains personal data processed within the scope of its activities for the period stipulated in the relevant legislation. In this context, personal data;

Tax Procedure Law No. 213

Labor Law No. 4857

Social Insurance and General Health Insurance Law No. 5510

Law No. 5651 on Regulation of Publications Made on the Internet and Combating Crimes Committed Through These Publications

Turkish Code of Obligations No. 6098

Turkish Commercial Code No. 6102

Occupational Health and Safety Law No. 6361

Personal Data Protection Law No. 6698

It is stored for the duration of the retention periods specified in other secondary legislation in force.

4.1.2. Processing Purposes Requiring Storage

The company stores the personal data it processes within the scope of its activities for the following purposes:

Execution of emergency management processes

Execution of information security processes

Carrying out the application processes of working candidates

Fulfillment of obligations arising from employment contracts and legislation for employees

Audit / Conducting ethical activities

Carrying out Training Activities

Carrying out financial and accounting affairs

Providing physical space security

Carrying out assignment processes

Follow-up and execution of legal affairs

Carrying out communication activities

Carrying out human resources processes

Conduct/supervision of Business Activities

Carrying out occupational health/safety activities

Carrying out activities to ensure business continuity

Conducting Logistics Activities

Execution of goods/service production and operation processes

Carrying out goods/service purchasing processes

Execution of goods/service sales processes

Execution of contract processes

Ensuring the security of movable goods and resources

Providing information to authorized persons, institutions and organizations