1. Nature and Purpose of the Policy
1.1 Introduction
This Personal Data Retention and Destruction Policy has been prepared by FELTOUCH YAPI TASARIM YAZILIM ARAŞTIRMA VE GELİŞTİRME DANIŞMANLIK MÜHENDİSLİK SANAYİ DIŞ TİC. LTD. ŞTİ. (“FELTOUCH YAPI TASARIM”), acting as the data controller, in order to determine the procedures and principles regarding the deletion, destruction, or anonymization of personal data in accordance with the Law No. 6698 on the Protection of Personal Data (“KVKK”) and other applicable legislation.
Within this scope, the personal data of employees, job applicants, customers, and all real persons whose personal data are processed by FELTOUCH YAPI TASARIM are managed in compliance with the law under the Personal Data Processing and Protection Policy and this Retention and Destruction Policy.
1.2 Definitions
- Data Subject: The real person whose personal data is processed.
- Destruction: Deletion, destruction, or anonymization of personal data.
- Law: Law No. 6698 on the Protection of Personal Data.
- Regulation: Regulation on Deletion, Destruction or Anonymization of Personal Data.
- Board: Personal Data Protection Board.
- Recording Medium: Any environment where personal data is processed.
- Personal Data Processing and Protection Policy: The policy accessible at https://feltouch.tr.
- Data Recording System: Systems where personal data is structured and processed.
2. Storage Environments and Security Measures
2.1 Storage Environments
Personal data processed by FELTOUCH YAPI TASARIM are stored in environments suitable for the nature of the data and legal obligations.
- Printed Media: Paper documents and microfilms
- Local Digital Media: Servers, hard drives, portable storage devices
- Cloud Media: Encrypted internet-based systems used by the Company
2.2 Ensuring Data Security
2.2.1 Technical Measures
- Use of up-to-date and secure technological systems
- Access restriction and authorization controls
- Regular security testing and vulnerability assessments
- Logging and monitoring of data access activities
- Employment of qualified technical personnel
2.2.2 Administrative Measures
- Raising employee awareness on data protection and privacy
- Receiving legal and technical consultancy
- Signing data protection protocols with third parties
2.2.3 Internal Audits
FELTOUCH YAPI TASARIM conducts internal audits in accordance with Article 12 of KVKK.
Any deficiencies identified are promptly remedied.
3. Destruction of Personal Data
3.1 Reasons for Retention and Destruction
3.1.1 Retention Reasons
Personal data are retained for legal, contractual, and operational purposes as specified under KVKK and the Personal Data Processing and Protection Policy.
3.1.2 Destruction Reasons
Personal data are destroyed upon request of the data subject or automatically when the legal grounds for processing cease to exist.
3.2 Destruction Methods
Deletion Methods
- Blackening: Irreversible masking of data on printed documents
- Secure Software Deletion: Permanent deletion from digital systems
Destruction Methods
- Physical Destruction: Shredding, melting, or pulverizing storage media
- Degaussing: Disrupting magnetic fields to render data unreadable
- Overwriting: Writing random data multiple times over storage media
3.3 Retention Periods
Personal data are retained in accordance with legal limitation periods and contractual obligations. If legislation prescribes longer periods, those periods shall prevail.
3.4 Periodic Destruction
Periodic destruction processes commence on 01 January 2026 and are carried out every 6 months.
3.5 Audit of Legal Compliance
FELTOUCH YAPI TASARIM ensures that all destruction activities are carried out in compliance with applicable legislation and records all destruction operations for a minimum period of three years.
4. Personal Data Committee
A Personal Data Committee has been established within FELTOUCH YAPI TASARIM to oversee compliance, manage requests, and supervise retention and destruction processes.
5. Effectiveness and Updates
This Personal Data Retention and Destruction Policy entered into force on 01 January 2026. FELTOUCH YAPI TASARIM reserves the right to amend this Policy in line with legislative, regulatory, or technological developments.