Merchants don't have to opt in, but they can opt out
Turkey's Regulation on Commercial Communication and Commercial Electronic Messages doesn't require prior consent for commercial electronic messages sent to merchants or tradespeople. If the recipient has used their right to opt out, though, you can't send them anything.
İYS comes before sending
Since a 2020 amendment, anyone sending messages to merchants and tradespeople must first register the addresses in İYS (Turkey's Message Management System) and check through İYS whether they've opted out. Any opt-out you receive directly must also be recorded in İYS within three working days.
Personal data
A generic company address such as info@ isn't treated the same way as one with a person's name in it. For sole proprietors, even business details can count as personal data. Decide why you're processing the data and for how long, and meet your duty to inform the people concerned.
Practical checklist
- A reasonable basis for believing the recipient is a merchant or tradesperson
- A generic company address wherever possible
- İYS registration and an opt-out check before sending
- Sender details and an easy opt-out in every email
- Anyone who opts out removed for good
- Opt-outs recorded in İYS within three working days
This article is general information, not legal advice. Speak to a lawyer about your own situation.