The Turkish Personal Data Protection Authority Publishes a Public Announcement on the Use of Personal Data Obtained from Third Parties for Advertising and Marketing Purposes

The Turkish Personal Data Protection Authority ("Authority") has published a public announcement concerning the use of personal data obtained from third parties for advertising and marketing purposes on 21 July 2026.

The announcement states that telephone numbers, email addresses and similar contact information have been obtained from third parties through methods such as referrals, recommendations, brand ambassador programmes or customer referrals and subsequently used for marketing activities without informing the relevant data subjects or, where required, obtaining their explicit consent.

The following points were highlighted in the public announcement dated 21 July 2026:

• The mere fact that personal data have been obtained from third parties does not, in itself, constitute a legal basis for processing such data for advertising and marketing purposes.
• Personal data processing activities carried out within the scope of advertising and marketing must, in each specific case, be based on one of the legal grounds for processing set out under Law No. 6698 on the Protection of Personal Data (“Law”).
• Data subjects must be informed within a reasonable period following the collection of their personal data or, where the data are used for communication purposes, at the time of the first communication.
• Conduct such as continuing to receive information about promotions, not terminating a call, not responding to an SMS with a rejection, requesting information or failing to submit an opt-out request cannot be regarded as valid explicit consent.
• Compliance with the obligation to inform and the obtaining of explicit consent constitute separate processes and must therefore be carried out independently from one another.
• Failure to comply with the obligations set out under the Law may result in administrative sanctions. Failure to comply with the obligations set out under the Law may result in administrative sanctions pursuant to Article 18 of the Law.

You can access the full text of the public announcement here.

Kind regards,

Zumbul Attorneys-at-Law

info@zumbul.av.tr

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