KVKK Compliance in Turkey for Tech and SaaS Companies (2025 Guide)

Introduction

Launching or scaling a tech business in Turkey? Processing user data, collecting emails, using cookies, or storing customer info?

Then you’re subject to KVKK — Turkey’s Law on the Protection of Personal Data.

At RT-Union – Turkish International Law & Consulting Firm we help foreign startups, SaaS platforms, and digital companies achieve full KVKK compliance — without disrupting growth.

This guide explains how to comply with KVKK in 2025, what penalties you face for ignoring it, and how we make compliance clear, fast, and legally bulletproof.

What is KVKK and Who Needs to Comply?

KVKK is Law No. 6698 on the Protection of Personal Data, Turkey’s version of the GDPR.

It applies to:

Companies based in Turkey (including subsidiaries of foreign groups);
Foreign companies that process personal data of Turkish residents (even without local presence);
Any platform collecting names, emails, phone numbers, device info, cookies, payment data, etc.

If you have Turkish users, clients, leads, or employees — you need KVKK compliance.

Key Legal Requirements Under KVKK

Obligation:

Clarification Text
Explicit Consent
Data Controller Registration (VERBIS)
Data Security Measures
Data Subject Rights
Cross-Border Transfers

Description:

Users must be clearly informed about how their data is used (Privacy Notice)
Required for sensitive data, profiling, and data transfer
Mandatory registration with Turkish Data Protection Authority
Adequate technical and organizational protections
Users must be able to access, correct, delete, and object to processing
Strictly regulated — allowed only with safeguards or consent

Failure to comply may result in fines, lawsuits, and even access restrictions.

Penalties for Non-Compliance (2025)

Fines up to TRY 2,000,000 per violation (approx. €60,000)
Blacklisting of domains or apps for major breaches
Civil claims from affected data subjects
Criminal liability in some data leak scenarios

RT-Union ensures your privacy documents, processes, and risk profiles are legally valid and fully documented.

How Does KVKK Differ from GDPR?

Feature:

Extraterritorial application
Broad legal bases (e.g., contract, legitimate interest)
Data transfer via SCCs/BCRs
Right to data portability
Penalties
DPO required

GDPR:

Extraterritorial application - ✅
Broad legal bases (e.g., contract, legitimate interest) - ✅
Data transfer via SCCs/BCRs - ✅
Right to data portability - ✅
Penalties - €20M or 4% global turnover
DPO required - In some cases

KVKK?

Extraterritorial application - ✅
Broad legal bases (e.g., contract, legitimate interest) - ❌ (Consent-focused)
Data transfer via SCCs/BCRs - ❌ (Requires approval or consent)
Right to data portability - ❌
Penalties - TRY 2M+
DPO required - ❌

📌 Compliance with GDPR ≠ Compliance with KVKK. Many foreign companies assume one covers the other — that’s a costly mistake.

Who Must Register with VERBIS?

VERBIS is the Turkish Data Controller Registry. You must register if:

You are a company (Turkish or foreign) processing data in Turkey;
You meet thresholds based on annual turnover or employee count;
You are not exempt under KVKK Communiqués.

RT-Union:

Determines whether your company is subject to VERBIS;
Handles full registration, documentation, and filings in Turkish.

Our KVKK Legal Services Include

✔️ Legal Gap Assessment (GDPR vs KVKK)
✔️ Custom Privacy Policies and Clarification Texts
✔️ Consent Framework Review (e.g., cookie banners, opt-ins)
✔️ VERBIS Registration & Ongoing Maintenance
✔️ Data Processing Contracts and Cross-border Flow Protocols
✔️ Crisis Response (breach notification, regulator inquiries)

We serve:

SaaS platforms with Turkish users,
Fintech and payment services,
Marketplaces and e-commerce,
Healthtech and Edtech startups,
International cloud providers with Turkish operations.

Case Example: SaaS Launch with Full Compliance

An EU-based subscription platform expanded to Turkey and collected data via landing pages and trial sign-ups.

RT-Union:

Reviewed GDPR stack and adapted it for KVKK;
Created bilingual clarification text and opt-in architecture;
Registered the company with VERBIS;
Provided legal representation for cross-border data flow review.

Result: ✅ KVKK-compliant launch, no user complaints, scalable framework.

Frequently Asked Questions (FAQ)

Do I need to register with VERBIS if I have no Turkish office?
Yes — if you collect personal data from Turkish individuals or users. Presence in Turkey is not required for applicability.

Do we need a separate Privacy Policy for Turkey?
Yes. RT-Union provides fully KVKK-compliant privacy documentation — standalone or hybrid with GDPR.

Can I transfer data to servers in the EU or US?
Only if:

You have Turkish Data Protection Authority approval;
Or you obtain explicit user consent with proper documentation.

Is there a deadline for compliance?
There’s no fixed grace period. Non-compliance can result in penalties upon inspection or complaint — proactive compliance is essential.

Why Work with RT-Union – Turkish International Law & Consulting Firm

🌍 Specialists in cross-border privacy law
⚖️ Licensed representation before Turkish Data Protection Authority (KVKK Kurumu)
💼 Bilingual legal documents and audit-ready compliance packages
🧩 Scalable solutions for startups and multinational tech businesses

We don’t just write policies — we protect your business against regulatory risk.

Request a KVKK Compliance Audit

🕊️ Launching or scaling a tech business in Turkey?

Let RT-Union handle your KVKK compliance — with confidence, clarity, and cross-border expertise.

📞 Get a free preliminary consultation and document review.

👉 Start Your Compliance Journey with RT-Union