PERSONAL DATA STORAGE AND DESTRUCTION POLICY
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PURPOSE OF THE POLICY
The purpose of this policy is to establish the rules, roles, and responsibilities applicable throughout ONTAD GIDA İNŞAAT SANAYİ VE TİCARET ANONİM ŞİRKETİ (the Company) to fulfill the obligations regarding the storage and destruction of personal data pursuant to Articles 5 and 6 of the Regulation on the Deletion, Destruction or Anonymization of Personal Data (“Regulation”), published in the Official Gazette dated 28.10.2017 and numbered 30224, based on the Personal Data Protection Law No. 6698 (“Law”).
2. SCOPE OF THE POLICY
This policy covers personal data and special categories of personal data, as defined under the Law, held within ONTAD GIDA İNŞAAT SANAYİ VE TİCARET ANONİM ŞİRKETİ; all employees, managers, consultants, subsidiaries, external service providers, and any individuals or legal entities in legal relations with ONTAD GIDA İNŞAAT SANAYİ VE TİCARET ANONİM ŞİRKETİ wherever personal data sharing is in question.
Unless otherwise stated, the term “Personal Data” herein shall collectively refer to both personal data and special categories of personal data.
3. DEFINITIONS
Anonymization: Rendering personal data impossible to link with an identified or identifiable person, even through matching with other data.
Destruction: Deletion or destruction of personal data.
Personal Data: Any information relating to an identified or identifiable natural person.
Personal Data Retention Schedule: A table indicating the periods during which personal data will be retained by ONTAD GIDA İNŞAAT SANAYİ VE TİCARET ANONİM ŞİRKETİ.
Personal Data Processing Inventory: An inventory detailing the processing activities carried out in connection with the Company’s business processes, specifying purposes of processing, data categories, recipient groups, and groups of individuals whose data is processed, retention periods, potential cross-border transfers, and security measures taken.
Deletion of Personal Data: Making personal data inaccessible and unusable for users.
Destruction of Personal Data: Rendering personal data irretrievable and inaccessible by anyone.
Special Categories of Personal Data: Data relating to race, ethnic origin, political opinion, philosophical beliefs, religion, sect, or other beliefs, attire, association, foundation or trade-union membership, health, sexual life, criminal convictions, security measures, biometric and genetic data.
Periodic Destruction: Scheduled deletion, destruction, or anonymization processes to be carried out periodically where the conditions for processing personal data under the Law no longer exist.
Data Recording System: A recording system structured according to specific criteria where personal data is processed.
Direct Identifiers: Identifiers that reveal the related person directly on their own.
Indirect Identifiers: Identifiers that reveal the related person in combination with other data.
Law: Law No. 6698 on the Protection of Personal Data published in the Official Gazette dated 7.04.2016 and numbered 29677.
Regulation: 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 where personal data is processed automatically, wholly or partially, or non-automatically, provided that it is part of a data recording system.
Personal Data Protection and Processing Policy: The Company’s policy on the management of personal data accessible at “https://ontad.com.tr/”.
Data Recording System: A system where personal data is processed according to specific criteria.… (Continue the rest of the translation in the same detailed manner)