Personal Data Storage and Destruction Policy
1. Aim
The purpose of this destruction policy ("Destruction Policy") is to determine the maximum period required for the processing purposes of personal data by Murat ÖRNEK ("LOVELAMP") and the methods and responsibilities regarding the deletion, destruction and anonymization of personal data, primarily in accordance with the Personal Data Protection Law No. 6698 (" KVKK"), the Regulation on Deletion, Destruction or Anonymization of Personal Data ("Regulation") and LOVELAMP Personal Data Protection Policy.
2. Scope of Destruction Policy
The principles and methods to be followed in the storage and destruction of Personal Data are covered within the scope of this policy.
3. Definition and Concepts
Anonymization: Making Personal Data impossible to associate with an identified or identifiable natural person in any way, even if it is matched with other data.
Relevant User: Persons who process Personal Data within the LOVELAMP organization or in line with the authority and instructions received from LOVELAMP, excluding the person or unit responsible for the technical storage, protection and backup of Personal Data.
Destruction: The deletion, destruction or anonymization of Personal Data.
Personal Data: Any information regarding an identified or identifiable natural person.
Deletion: Deletion of Personal Data is the process of making Personal Data inaccessible and unusable in any way for the relevant users.
Destruction: It is the process of making Personal Data inaccessible, irretrievable and unusable by anyone.
4. Ensuring the Security of the Environment and Precautions Taken
LOVELAMP takes all necessary technical and administrative measures in accordance with the characteristics of the relevant personal data and the environment in which it is kept, in order to store personal data securely and prevent it from being processed and accessed unlawfully. These measures include, but are not limited to, the following administrative and technical measures to the extent appropriate to the nature of the relevant personal data and the environment in which it is kept.
4.1. Technical Measures
LOVELAMP takes the following technical measures in accordance with the characteristics of all environments where personal data is stored, the relevant data and the environment where the data is kept:
Only up-to-date and secure systems that comply with 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 current or potential risks identified as a result of the tests and research are eliminated.
By restricting access to the environments where personal data is kept, only authorized persons are allowed to access these data, limited to the purpose of storing personal data, and all access is recorded.
LOVELAMP works with well-equipped and competent partners to ensure the security of the environments where personal data is kept.
4.2. Administrative Measures
LOVELAMP takes the following administrative measures in accordance with the characteristics of all environments where personal data is stored, the relevant data and the environment where the data is kept:
Efforts are being made to raise awareness of all LOVELAMP employees who have access to personal data on information security, personal data and privacy. Legal and technical consultancy services are received to follow the developments in the field of information security, privacy of private life and protection of personal data and to take the necessary actions.
If personal data is transferred to third parties due to technical or legal requirements, protocols are signed with the relevant third parties to protect personal data, and all necessary care is taken to ensure that the relevant third parties comply with their obligations in these protocols.
4.3. Internal Audit
In accordance with Article 12 of the Law, LOVELAMP carries out internal audits regarding the implementation of the provisions of the Law and this Personal Data Storage and Destruction Policy and the Personal Data Processing and Protection Policy.
If deficiencies or defects regarding the implementation of these provisions are detected as a result of internal audits, these deficiencies or defects will be corrected immediately.
If it becomes clear during the audit or otherwise that the personal data under LOVELAMP's responsibility has been obtained by others through illegal means, LOVELAMP will notify the relevant party and the Board of this situation as soon as possible.
5. Reasons for Personal Data Storage and Destruction
Personal Data held by LOVELAMP is stored securely in physical environments such as unit cabinets, archives or digital environments in accordance with KVKK and relevant legislation.
LOVELAMP, Personal Data below