Push Notification

Also known as: App Notification, Instant Notification, Push Bildirimi

In short

Short messages sent instantly by mobile apps or web browsers to a user's device; promotional ones are commercial electronic messages and require prior approval.

A push notification is a short message sent instantly by a mobile app or web browser to a user’s device, appearing on the home screen or in the notification centre. Push notifications can be informational, but they are also widely used for campaigns and product promotion.

Are They Commercial Electronic Messages?

Push notifications sent for promotion and marketing are commercial electronic messages within the meaning of Law No. 6563 and the Regulation on Commercial Communications and Commercial Electronic Messages. The legislation provides no exception for app notifications. As a rule, therefore, prior approval must be obtained, and the message must include the service provider’s MERSİS number, contact details and an opt-out option. In practice, these details are commonly omitted because notifications are short, which creates legal uncertainty.

Board Decision 2021/361

In its decision dated 13.04.2021 and numbered 2021/361, the Personal Data Protection Board found that a bank’s mobile apps having the option to receive promotional messages switched “on” by default breached both the approval rule in Law No. 6563 and the KVKK, and imposed an administrative fine on the bank. The Board ruled that the app’s default settings should be set to not receiving promotional messages.

Uncertainty around IYS

Under the legislation, approvals for commercial electronic messages must be recorded in IYS, but the IYS infrastructure does not support app notifications as a separate channel. Until this uncertainty is resolved, companies should collect approval in the app clearly, separately and in a way that can be recorded, and allow users to change their preference easily.

For a detailed assessment, see Push Notifications in Turkish Law.

Frequently Asked Questions

Is the operating system's notification permission enough?

The notification permission requested by the operating system is a technical permission and does not on its own replace approval for promotional messages. For promotional notifications, a separate, clear in-app approval that is off by default should be obtained.

Is every push notification a commercial message?

No. Informational notifications such as order status, security alerts or account activity are not commercial electronic messages. Notifications containing campaigns, discounts or new product promotions are.

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