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Processing of Personal Data in the Use of Customer Membership Card (Sadakat Card)

Processing of Personal Data in the Use of Customer Membership Card (Sadakat Card)

YOUR EVEN IF I USE THE LOYALTY CARD, THE TEAM SHOULD I BUY THE DRESS AT A DISCOUNT?

As it is known, the loyalty card application is a Times are from the crowd that we all carry in our wallets, but made in our wallets. which we were not very happy with, and then the mobile phone number of the person concerned Defining the number in the company's system or via the mobile application QR code scanning etc. provided. carried out using methods and to benefit from discounts and promotions while shopping. It is an application that offers opportunities.

However, in the application, the loyalty card holder is Even though it is not at the checkout during the shopping process and for this shopping process without any transaction confirmation code being entered into the system by the cashier. There are situations where transactions are carried out. Similar problems It may also occur during internet-based shopping.

For this problem, the Personal Data Protection Board 13 In the Principle Decision No. 2026/266 published in the Official Gazette dated August 2026 He emphasized the following:

In the decision; knowledge and consent of the person concerned Although it is not available, the relevant seller in the company that is the data controller Loyalty by allowing the use of a person's mobile phone number Allowing shopping via card leads to unlawful personal data processing stated.

Also, invoices etc. related to the shopping made. of the document prepared in the name of the relevant personirregularly invoice is issued and in this respect, it is legal It has been stated that an illegal data processing activity has been carried out.

The Board made a further determination and determined that the relevant person It also addresses the situation of making purchases by giving your mobile phone number with your consent. received andWithin the scope of the “Loyalty Card Membership Agreement” to the relevant persons regarding the loyalty card not being used by third parties. Even though responsibility has been assumed, this situation Personal data processing activities carried out by those responsible "will not eliminate the obligation to ensure data security." stated.

In order to avoid these situations, the Board;

·       Loyalty cards for any purpose (creating membership, earning points for shopping, for using points, benefiting from discounts/promotions, etc.) disposable data sent via SMS to people's mobile phone numbers. Notifying the verification code to the cashier,

·       Mobile Thebarcode/QR code provided via the application/website is at the checkout. to be taught;

·       Physical Presenting the loyalty card at the cash register or entering the loyalty card password into the transaction device at the register. entering,

·       Loyalty loyalty through the online membership account created within the scope of card programs When using a card, you can shop only by providing your mobile phone number. which transactions (earning points during shopping/benefiting from discounts or promotions/points) preference is given to the relevant persons regarding the approval of the expenditure, etc.) data controllers by using methods such as providing the opportunity to It was decided that verification mechanisms should be established by gave. Relevant companies provide different services such as earning points/discounts and spending points. Different verification mechanisms can be used according to transaction types.

Ability to create such verification mechanisms. to companies within 6 days from the date of publication of this Policy Decision on 11/2/2026. A monthly adaptation period is envisaged.  companies that they need extra time to create the necessary technical infrastructure As stated above, this period is determined by KVKK as of 28 February, as of 13 August. It has been extended until 2027.

https://www.resmigazete.gov.tr/eskiler/2026/08/20260813-3.pdf