In June 2022, the Turkish Personal Data Protection Authority (the “Authority”) published guidelines on the use of online cookies, opened draft guidelines on loyalty programs for public opinion, and announced five data breach notifications.
On 20 June 2022, the Authority published guidelines (the “Guidelines”) on the use of cookies to collect personal data and the use of personal data in online environments such as websites, mobile applications, smartphones, and tablets.
In summary, the Guidelines evaluate the use of cookies and provide information on:
The Guidelines classify cookies under three fundamental groups: (i) cookies by their duration, (ii) cookies by their usage purposes; and (iii) cookies by parties. The Guidelines also define the types of cookies and the legal requirements to use them. In this respect, data controllers need to determine the types of cookies in use and ensure that the use of such cookies is in compliance with Turkish DP Law. For detailed information, please see our article here.
On 16 June 2022, the Authority published draft guidelines on the processing of personal data via loyalty programs (the “Draft Guidelines”) and announced that the Draft Guidelines will be available for public opinion until 16 July 2022.
The Draft Guidelines state that loyalty program operators are considered as data controllers, and customers who are beneficiaries of such programs are considered as data subjects.
In addition, the Draft Guidelines classify personal data processed through loyalty programs as follows:
The Draft Guidelines also touch on fundamental matters of Turkish data protection law: explicit consent and data controllers’ obligation to inform. Accordingly:
You can access the draft guideline here (available only in Turkish).
| Data Controller | Affected Data Subjects | Affected Personal Data | Number of Data Subjects |
| MBtech Mühendislik ve Danışmanlık Ltd. Şti. | Employees, Users, Customers and Potential Customers | Identity, Communication Information, Location, Information on Consumer Transaction, Personnel Information, Finance, Information on Professional Experience, Audio and Visual Records | 500 |
| Pegasus Hava Taşımacılığı Anonim Şirketi | Employees | Identity, Communication Information and Visual Records | N/A |
| Barçın Spor Malzemeleri Ticaret ve Sanayi Anonim Şirketi | Users, Customers and Potential Customers | Identity, Communication Information, Information on Customer Transaction and Other (Membership Date) | 187,930 |
| Tofisa Tekstil Sanayi ve Ticaret Limited Şirketi | Customers and Potential Customers | Identity and Communication Information | 42,373 |
| ARG Denizcilik İnşaat Otomotiv Sanayi ve Ticaret Ltd. Şti,
İstek Gemi İnşa Bakım İnşaat Hırdavat Sanayi ve Ticaret Ltd. Şti, and Safter Ulubay |
Employees | Identity, Communication Information and Personnel Information | Approx. 2,000 |
For more information please contact Ceren Ceyhan, Associate, at cceyhan@gentemizerozer.com, and Hatice Nur Arslan, Legal Intern, at narslan@gentemizerozer.com.
For detailed information on how we processes your personal data, please see the Clarification Text here.
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