Employment and Labor Law

Author: Merve Demirkaya

Introduction

The Personal Data Protection Authority (“DPA”), on 16.06.2022, published the Draft Guidelines on Examination of Loyalty Programs within the Scope of Personal Data Protection Legislation (“Draft Guidelines”). The public has until 16.07.2022 to submit comments on them, and after these are evaluated, the Draft Guidelines will become binding.

Although it was somewhat different than modern current examples, the first known loyalty program actually began in 1793. This first program used copper tokens. Later, in the 1980s, loyalty programs were implemented by American airline companies with the goal of ensuring commercial stability. These programs served as a role model for today's loyalty programs, which are today implemented almost everywhere and in every sector. Retailers, airline companies, hotels, telecommunication companies, fuel stations and many other businesses can be given as examples. In Turkey, loyalty programs started with the development of organized food retailing and then spread to many areas such as telecommunications, transportation, clothing, automotive, fuel, cosmetics, and, especially, banking.

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