This page summarises the personal data retention and destruction policy of Milore Tekstil Gıda ve Toptan Ticaret Limited Şirketi ("Roicool"). The policy rests on Article 7 of Law No. 6698 on the Protection of Personal Data ("KVKK") and the Regulation on the Deletion, Destruction or Anonymisation of Personal Data. The Turkish text prevails.
1. Principle
We keep personal data only as long as the purpose requires and the law prescribes. When the period ends, or the conditions for processing no longer apply, the data is deleted, destroyed or anonymised at the next periodic destruction or at your request. The retention period is the longer of the legal period and the period the purpose needs; where the law sets none, the purpose decides.
2. Retention periods
| Data | Where | Period | When it ends |
|---|---|---|---|
| Contact, proposal, meeting, e-book, tool-report and partner-application forms | The Site's records | 24 months after receipt | Anonymised automatically |
| The CRM send-queue copy of the same requests | The Site's records | 24 months; undelivered ones 30 days after the last attempt | Deleted automatically |
| Prospect and client records | CRM | 2 years from the last contact | Deleted or anonymised |
| Contracts, invoices and business correspondence | Accounting and contract records | 10 years (Turkish Commercial Code No. 6102, Art. 82) | Deleted or destroyed |
| Partner agreement and commission records | Accounting and contract records | For the term of the agreement and 10 years after it ends | Deleted or destroyed |
| Commercial-message approval and refusal records | İYS and CRM | 3 years from the end of the approval | Deleted |
| Report confirmation links | The Site's records | 24 hours; single use | Expire |
| Security and abuse logs (IP addresses only hashed) | Server logs | 2 years | Deleted |
| Site analytics (Google Analytics 4) | 14 months | Deleted by Google | |
Cookie choice (rc_consent) | Your browser | 180 days | We ask again |
Campaign source (roicool_attr) | Your browser | 90 days | Renewed or cleared in your browser |
| Job applications | E-mail and application records | 1 year | Deleted |
| Data-subject requests and answers | Request records | 2 years from our answer | Deleted |
3. Deletion, destruction and anonymisation
- Deletion: making the data inaccessible and unusable for the relevant users in any way (removing records from the database, permanently deleting e-mails).
- Destruction: making the data inaccessible and unrecoverable by anyone (shredding paper, physically destroying media).
- Anonymisation: making the data impossible to link to a person, even when matched with other data. In form requests the name, e-mail, phone, company and message fields are emptied; only the request type, language and date remain for statistics.
Periods in the Site's records are applied by an automated job that runs every day, and each run is logged with counts that hold no personal data. For other records, periodic destruction is carried out at least every 6 months.
4. Backups
Server backups are kept for at most 3 months (daily, weekly and monthly copies: 7, 4 and 3); deleted data leaves the backups at the latest when the backup expires.
5. Deletion on request
You can ask for your data to be deleted with our data-subject request form. If every condition for processing has ended, we conclude your request within 30 days at the latest and let you know; if the law requires us to keep the data, we tell you why.
More detail: KVKK Privacy Notice. All our legal texts are on Legal.