Compliance Period Extended under the Principle Decision of the Turkish Personal Data Protection Board on the Protection of Personal Data of Loyalty Cardholders

The Decision of the Turkish Personal Data Protection Board (“Board”) dated 22 July 2026 and numbered 2026/1491 (“Decision”) was published by the Turkish Personal Data Protection Authority in the Official Gazette dated 13 August 2026 and numbered 33339.

With the Decision, the compliance period prescribed for data controllers under the Board’s Principle Decision dated 11 February 2026 and numbered 2026/266 has been extended.

In summary, the following matters have been decided under the Decision:

• Pursuant to the Principle Decision dated 11 February 2026 and numbered 2026/266, where a loyalty card holder’s mobile phone number or loyalty card number is used by a third party during a purchase, verification mechanisms are required to be implemented to confirm that the transaction is carried out with the knowledge and consent of the data subject.
• The six-month compliance period granted to data controllers to comply with the obligations set forth under the Principle Decision, which was due to expire on 28 August 2026, has been reassessed in light of requests submitted by data controllers and sector representatives.
• Accordingly, in order to enable data controllers to establish the necessary technical and administrative infrastructure, the compliance period has been extended until 28 February 2027.

You can access the full text of the Decision here.

Kind regards,

Zumbul Attorneys-at-Law

info@zumbul.av.tr 

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