Personal Data Retention and Destruction Policy
Version 2026-10-v1 · Updated October 20, 2026
This English translation is provided for convenience. The Turkish text is the governing version.
Purpose and scope
This policy explains how long we keep the personal data we process as data controller and how we destroy that data when the period ends. The data controller is:
Firmanet Yazılım ve Teknoloji A.Ş. (“Firmanet”), Büyükkayacık OSB Mahallesi, 101. Cadde, InnoPark Konya TGB, B Blok, No:4/105, 42160 Selçuklu / Konya. Phone: +90 (312) 439 3940. Email: [email protected]
The purposes of this policy are:
- to keep personal data only for the period laid down in the relevant legislation or for as long as is necessary for the purpose of processing (Article 4(2)(d) of Law No. 6698 on the Protection of Personal Data (KVKK));
- to delete, destroy, or anonymize data, on our own initiative or at your request, once all of the conditions for processing have ceased to exist (KVKK Article 7);
- to set out who carries out these tasks, in which recording media, by which method, and on what schedule.
This policy covers all of the matters listed in Article 6 of the Regulation on the Deletion, Destruction or Anonymization of Personal Data (the Regulation). The periods stated here are the same as the maximum retention periods in our personal data processing inventory. If the inventory changes, this policy is updated as well.
This policy applies to the data of the following persons, for which we are the data controller:
- visitors to iwb.com.tr, people who fill in the demo or quote request form, and people who contact us by phone or email (KVKK Privacy Notice: website and request forms);
- representatives of customers, business partners, and suppliers, the data of IWB users processed for platform security, and people who submit support requests (Privacy Notice: customers, product users, business partners, and suppliers);
- job candidates (Privacy Notice: job candidates);
- people who submit a data subject request (Data subject requests).
This policy covers all of our electronic and paper records relating to the persons above. Data that we hold on behalf of IWB customers in their workspaces is governed not by this policy but by our contract with the customer (see the “Data held on behalf of customers” section). Data relating to Firmanet employees is outside the scope of this policy.
Definitions
| Term | Meaning |
|---|---|
| Personal data | Any information relating to an identified or identifiable natural person. |
| Special categories of personal data | The data listed in KVKK Article 6; for example, health data, criminal convictions, religion, and membership of an association or trade union. |
| Data subject | The natural person whose personal data is processed. |
| Data controller | The person who determines the purposes and means of processing personal data; in this policy, Firmanet. |
| Data processor | The person who processes personal data on behalf of the data controller, based on the authority granted by the data controller. |
| Recording medium | Any electronic or paper medium in which personal data is held. |
| Retention period | The maximum period for which a record is kept under the table in this policy. |
| Destruction (imha) | Deletion, destruction (yok etme), or anonymization. |
| Deletion | Making personal data inaccessible and non-reusable in any way for the relevant users. |
| Destruction (yok etme) | Making personal data inaccessible, irretrievable, and non-reusable in any way by anyone. |
| Anonymization | Making personal data impossible to associate with an identified or identifiable natural person, even when it is matched with other data. |
| Periodic destruction | Destruction, on our own initiative and at recurring intervals on the schedule in this policy, of data for which all of the conditions for processing have ceased to exist. |
| Personal data processing inventory | An internal document that sets out our processing activities with their purpose, legal basis, data category, recipient group, data subject group, and maximum retention period. |
| Destruction report | The record of each destruction operation. |
| Board, Authority | The Personal Data Protection Board (the Board) and the Personal Data Protection Authority (the Authority). |
| TTK, TBK, VUK | Turkish Commercial Code No. 6102 (TTK), Turkish Code of Obligations No. 6098 (TBK), and Tax Procedure Law No. 213 (VUK). |
| ETK | Law No. 6563 on the Regulation of Electronic Commerce (ETK). |
| Commercial Messages Regulation | Regulation on Commercial Communication and Commercial Electronic Messages. |
| Law No. 5651 | Law No. 5651 on the Regulation of Publications on the Internet and Combating Crimes Committed by Means of Such Publications. |
Recording media
| Recording medium | Records kept |
|---|---|
| Firmanet’s IWB workspace | Request records (customer relationship management module); contact cards of representatives of customers, business partners, and suppliers; quote, contract, and order records; marketing consent records |
| Corporate mailboxes | Request, support, candidate, and customer correspondence and attachments; data subject requests received by email |
| Temporary files of the request service | Requests that could not be written to Firmanet’s IWB workspace, until they are transferred |
| Memory | IP address for the form submission limit |
| Server access logs | Access records for iwb.com.tr and the IWB application (app.iwb.com.tr) |
| Application database | IWB user accounts, session records, and records of account emails sent |
| Support ticket system | Support requests, correspondence, attachments, and screenshots |
| Management panel | Subscription, plan, billing, and contract records; records of actions taken in the panel by Firmanet staff; operational information for installations on your own server |
| Accounting records | Invoices, accounting documents, and payment records |
| Human Resources records | Candidate applications, interview notes, and the candidate pool |
| Marketing email sending system | Mailing list and records of commercial messages sent |
| Backups | Backups of the electronic media above |
| Paper archive | Signed contracts, paper invoices, written requests and our responses to them, and destruction reports |
| Old website database and uploads | Records received through the contact, quote, newsletter, and careers forms on the old website |
In the retention periods table, “corporate systems” refers collectively to Firmanet’s IWB workspace, the management panel, and the accounting records.
Reasons for retention and destruction
Reasons requiring retention
- Statutory retention obligations: TTK Article 82 for commercial books, documents, and commercial correspondence; VUK Article 253 for tax records; Article 13(2) of the Commercial Messages Regulation for records of consent to commercial messages and of messages sent; Article 7(3) of the Regulation for records of destruction.
- Contract: Data required for the establishment or performance of a contract, for as long as the contract continues (KVKK Article 5(2)(c)).
- Protection of rights and evidence: Records needed to exercise and prove our rights in a dispute, for the limitation period (TBK Article 146; KVKK Article 5(2)(e)).
- Legitimate interest: Records needed for the security of the site and the application and for detecting misuse (KVKK Article 5(2)(f)).
- Explicit consent: For the candidate pool and marketing emails, for as long as consent remains in effect and without exceeding the period in the table.
- Technical reasons: Records required for the service to operate (such as session and sending records) and backups kept so that data can be restored after data loss, for the periods in the table.
Reasons requiring destruction
Data is destroyed when one of the following occurs and no other condition for processing the data remains:
- expiry of the retention period;
- the purpose of processing ceasing to exist, for example when a request does not lead to a contract, a candidate process is closed, or a contract ends;
- amendment or repeal of the legislative provision on which retention is based;
- withdrawal of explicit consent;
- acceptance of the data subject’s request for deletion or destruction;
- a destruction decision by the Board;
- the data being unsolicited, for example special categories of personal data that a candidate sends in their CV.
Even after the retention period has expired, if a dispute, audit, or review by a competent authority is ongoing, the relevant records are kept until that process is concluded and are then destroyed (KVKK Article 5(2)(e)).
Measures for secure retention
While retaining data, we apply the following measures to prevent unlawful processing of and unlawful access to the data.
Technical measures
- iwb.com.tr does not use cookies, local storage, or similar browser storage, and does not load analytics, advertising, map, video, or chat tools.
- Form data is transferred from the server-side request service to Firmanet’s IWB workspace; the access key is not sent to the browser. The request service’s logs do not contain names, email addresses, or phone numbers.
- The forms include measures that distinguish automated submissions: an invisible field, a signed timestamp that is obtained when the form is first used and is not stored in the browser, and a submission limit per IP address. For this limit, the IP address is held in memory only, for 10 minutes.
- The IWB application is accessed over an encrypted connection. Permissions are set at role level and field level; confidential and masked fields are hidden on screen, in exports, and in reports.
- Passwords are at least 8 characters long and contain uppercase and lowercase letters and a digit. After 5 failed attempts, the account is locked for 5 minutes. Two-step verification is available.
- User passwords are stored hashed, and integration passwords and connection keys are stored encrypted.
- In session records, the last segment of the IP address is masked, and no browser fingerprint is kept.
- The security log records permission changes, access denials, reads of special categories of personal data, downloads of files containing personal data, and changes made from the management panel.
- Each customer’s data is protected separately in the application and in the database.
- Request records in Firmanet’s own workspace are not processed with IWB AI.
- The servers are located with a hosting service provider in Turkey. Backups are not kept for longer than 30 days.
Administrative measures
- Access to personal data is limited to what each person’s duties require. Staff give a confidentiality undertaking. Firmanet staff access customer data only from Turkey.
- Candidate applications are evaluated only by Human Resources; the copy in the general mailbox is deleted.
- Data subject requests are recorded and answered in writing or electronically within 30 days.
- For transfers abroad, standard contracts have been signed and notified to the Authority.
- Data breaches, their effects, and the measures taken are entered in the breach register.
- The personal data processing inventory and this policy are kept up to date together.
Destruction methods
We choose the method according to the recording medium. On request, we explain the method we applied to your data, together with the reasons for it (Article 7 of the Regulation).
| Recording medium | Destruction method |
|---|---|
| Firmanet’s IWB workspace | Deletion of the record, or anonymization of the record by clearing the fields that identify the person, such as name, email, and phone number |
| Corporate mailboxes | Deletion of the message and its attachments, and emptying of the deleted items folder as well |
| Temporary files of the request service | Deletion of the file from the server |
| Memory | Automatic deletion when the period expires |
| Server access logs | Automatic rotation and deletion of log files whose period has expired |
| Application database | Automatic deletion of session and sending records; anonymization of the user account; permanent deletion of a closed workspace |
| Support ticket system | Deletion of attachments, screenshots, and records whose period has expired |
| Management panel | Deletion of the record |
| Accounting records | Deletion of the electronic record; destruction of the paper document |
| Human Resources records | Deletion of application files, messages, and notes |
| Marketing email sending system | Removal of the person from the mailing list; deletion of sending records whose period has expired |
| Backups | Deletion through the backup cycle: an expired backup is deleted |
| Paper archive | Destruction of the document by shredding it so that it cannot be read or put back together |
| Old website database and uploads | Deletion of the records and uploaded files |
A deleted record remains in backups for at most 30 more days and is deleted through the backup cycle. Anonymized data is no longer personal data and is not subject to this policy.
Responsible staff
Responsible staff are designated by title and unit. Each unit is responsible for compliance with retention periods and for destruction in its own recording media.
| Unit | Title | Duties |
|---|---|---|
| Management | Board of Directors | Approves the policy and its updates, puts them into effect, and appoints the responsible staff. Approves periodic destruction reports and ensures that destruction reports are kept for 3 years. Oversees the recording and retention of data subject requests (S21, S22). |
| Sales | Sales unit manager | Monitors the periods for request records, commercial correspondence, and contact cards; deletes or anonymizes records whose period has expired (S05, S06, S08). |
| Marketing | Marketing unit manager | Manages marketing consent records, the mailing list, and sending records; applies opt-outs within 3 business days (S09, S10, S11). |
| Human Resources | Human Resources unit manager | Manages candidate applications and the candidate pool, and deletes those whose period has expired and unsolicited special categories of personal data; destroys career applications left over from the old website (S19, S20, S25). |
| Accounting | Accounting unit manager | Ensures that invoices and accounting documents are kept for the statutory period and destroyed when the period ends (S07). |
| Software Support | Software Support unit manager | Monitors the periods for support records and their attachments; deletes attachments 6 months after the request is closed (S15, S16). |
| System operations | System operations officer | Carries out the technical destruction of access logs, temporary files, automatic deletions within the application, management panel records, backups, and old website data; checks that the automatic deletion routines are working (S01-S04, S12-S14, S17, S18, S23-S25). |
Retention and destruction periods
If a record falls under more than one row, the longer period applies. For example, a request that leads to a contract leaves S05 and becomes subject to S06. For periods that start from “the end of the calendar year”, the period runs from December 31 of the relevant year.
| No. | Record | Period | Starts from | Basis | Medium and destruction |
|---|---|---|---|---|---|
| S01 | iwb.com.tr access log | 6 months | Time of recording | KVKK Article 4(2)(d) | Server; automatic rotation and deletion |
| S02 | Application access logs (app.iwb.com.tr) | 1 year | Time of recording | Lower limit under Article 5(3) of Law No. 5651, applied as a precaution | Server; automatic deletion |
| S03 | IP address for the form rate limit | 10 minutes | Time of request | Proportionality, KVKK Article 4(2)(ç) | Memory only; automatic |
| S04 | Temporary file of the request service (a request that could not be written to the customer relationship management module in Firmanet’s IWB workspace) | Deleted after the transfer; no later than 7 days after it is created | Creation of the file | KVKK Article 4(2)(ç) | Server; deletion |
| S05 | Requests that do not lead to a contract, and related correspondence | 24 months | Last contact | KVKK Article 4(2)(d) | Customer relationship management module and email; anonymization or deletion |
| S06 | Quotes, contracts, orders, and commercial correspondence | 10 years | End of the calendar year in which the relationship ended | TTK Article 82; TBK Article 146 | Corporate systems, email, paper; deletion, destruction |
| S07 | Invoices and accounting documents | 10 years | End of the calendar year to which the document relates | TTK Article 82 (longer than the 5 years under VUK Article 253) | Corporate systems, email, paper; deletion, destruction |
| S08 | Contact card of a representative whose relationship has ended (other than S06) | 2 years | End of the relationship | KVKK Article 4(2)(d) | Corporate systems; deletion |
| S09 | Marketing consent record | 3 years | End of consent (withdrawal) | Commercial Messages Regulation Article 13(2) | Customer relationship management module; deletion |
| S10 | Name, email, and company on the marketing mailing list | While consent remains in effect; opt-out applied within 3 business days | Opt-out | ETK Article 8 | Removal from the list |
| S11 | Records of commercial messages sent | 3 years | Time of recording | Commercial Messages Regulation Article 13(2) | Sending system |
| S12 | Product user account | Until the account is anonymized or the workspace is permanently deleted | – | KVKK Article 5(2)(c) and (f) | Application; anonymization, deletion |
| S13 | Session records | 90 days | End of the session | Product rule | Application; automatic deletion |
| S14 | Records of account emails sent | Delivered: 90 days; failed: 365 days | Time of sending | Product default | Application; automatic deletion |
| S15 | Support record (subject, correspondence) | 10 years | End of the calendar year in which the contract ended | TTK Article 82 | Support ticket system |
| S16 | Support attachments and screenshots | 6 months | Closing of the request | KVKK Article 4(2)(ç) | Support ticket system; deletion |
| S17 | Management panel action records (Firmanet staff) | 2 years | Time of recording | KVKK Article 5(2)(f); evidence | Management panel; deletion |
| S18 | Operational information for installations on your own server | 1 year | Time of recording | KVKK Article 4(2)(d) | Management panel; deletion |
| S19 | Unsuccessful candidate application | 6 months | Notification of the outcome or closing of the process | KVKK Article 4(2)(d); Board Decision No. 2021/670 | Email, Human Resources records; deletion |
| S20 | Candidate pool | 12 months; if consent is withdrawn, deletion within 30 days | Date of consent | Explicit consent | Email, Human Resources records; deletion |
| S21 | Data subject request and the response to it | 3 years | Date of the response | Evidence; consistent with Article 7(3) of the Regulation | Request records |
| S22 | Destruction reports | 3 years | Date of the report | Article 7(3) of the Regulation | Paper or electronic |
| S23 | Backups | 30 days | Creation of the backup | KVKK Article 4(2)(d) | Backup environment; deletion through the cycle |
| S24 | Closed workspace (data held on behalf of the customer) | 30 days during which it can be restored, then permanent deletion; if the retention period for financial documents is still running, a written decision with the customer | Closure | Product rule; VUK, TTK | Application |
| S25 | Form records left over from the old website (contact, quote, newsletter, CV) | CV: S19 rule; contact and quote: S05 rule; newsletter: immediately if there is no proof of consent | Launch of the new website | KVKK Article 4(2)(d) and Article 7 | Old website database and uploads |
Periodic destruction
We carry out periodic destruction every six months, in January and July. The interval does not exceed six months in any case (Article 11 of the Regulation).
- Each unit reviews its own recording media against the retention periods table. It destroys records whose period has expired and for which no other condition for processing remains, using the method in the table.
- Records that are deleted automatically (S01, S02, S03, S13, S14, S23) are deleted in their own cycle. During periodic destruction, the system operations officer checks that these deletions are working.
- Each destruction operation is documented in a destruction report. The report states the date of destruction, the recording medium, the record type and data category, the number of records, the method applied, and the unit that carried out the operation. Reports are kept for 3 years after approval by Management (S22).
Destruction on request
You can request the deletion or destruction of your data through the channels described on the Data subject requests page.
- If all of the conditions for processing have ceased to exist, we destroy your data without waiting for periodic destruction, within 30 days at the latest, and notify you.
- If we have previously transferred your data to a recipient, we also notify that recipient of your request and ask it to destroy the data.
- If one of the conditions for processing still applies (for example, if a statutory retention period has not expired), we reject your request with reasons and notify you of this in writing or electronically within 30 days. This data is destroyed once the condition ceases to exist.
- If you withdraw your consent to marketing emails, you are removed from the mailing list within 3 business days (S10). If you withdraw your consent for the candidate pool, your data is deleted within 30 days (S20).
Data held on behalf of customers
For data in the workspaces of IWB customers, the customer is the data controller; we are the data processor acting on the customer’s behalf. The customer decides the retention period for this data. We retain and delete this data in accordance with the customer’s instructions and the Data Processing Agreement. The retention periods within IWB are also set out in Annex 1 to that agreement.
- A closed workspace can be restored for 30 days and is then permanently deleted. If it contains financial documents whose retention period has not expired, it is not deleted automatically; in that case, a written decision is made with the customer (S24).
- IWB provides customers with the following tools for their own destruction tasks: anonymization of users, contacts who are natural persons, and contact persons; anonymization of HR personnel file data through an HR action once its period has expired; and a flag for marking custom fields as sensitive.
- If we receive a deletion request that concerns data in a customer’s workspace, we forward it to that customer within 5 business days and notify you.
Updates
We review this policy at each periodic destruction and whenever a recording medium, a retention period, or the relevant legislation changes. Each update is entered in the table below.
| Version | Date | Change |
|---|---|---|
| 2026-10-v1 | October 20, 2026 | First publication |
The version and the update date are shown at the top of the page. When we change the text, we publish the new version at this address; the change applies from the date it is published.