In Digital Sales, the Contract and the Records Are Reviewed Together
It must be determined whether the platform is an intermediary or a service provider, who receives the payment, and to whom the accommodation commitment belongs. A change in the terms in the platform dashboard does not erase the terms under which an earlier reservation was made. Keeping dated versions of prices, cancellation policies, campaigns and notices is important in a dispute.
Online reservation platforms and digital sales channels
- Online travel agency and reservation platform contracts, commissions, campaigns and visibility conditions
- Disputes over price, availability, quota, parity, cancellation, refund, chargeback, fake reservations and payment
- Compliance with legislation of the facility name, class, certificate number, photographs, location, price and mandatory information on the platform
- Distance contracts, commercial electronic messages, cookies, data protection and consumer information texts on websites and mobile applications
- Suspension of a platform account, content removal, unjust reviews, trademark infringement and commercial reputation issues
Personal data, guest records and digital compliance
- Assessing the data inventory and processing conditions for guest, employee, agency, supplier and online visitor data
- Reservation, identity notification, loyalty program, camera, Wi-Fi, call center, health or special-category data processes
- Privacy notices, processing that requires explicit consent, data retention and destruction, access authorization and data breach procedures
- Regulating data responsibility by contract among the hotel management company, brand, platform, agency and technology suppliers
- Legal management of data transfers abroad, multinational reservation systems and cyber incidents
Trademarks, promotion, unfair competition and commercial reputation
- Registration, licensing, franchise use and protection of hotel, restaurant, agency and tourism trademarks
- Legal management of facility names, domain names, social media accounts, photographs, videos, menus and other creative content
- Disputes over counterfeit marks, misleading promotion, fake websites, unauthorized use of images and unfair competition
- Applications to protect commercial reputation concerning online reviews, defamation, impersonation of the business and fake ratings
- Reviewing advertising, campaigns, influencer collaborations and personalized offers under consumer, commercial advertising and data protection rules
Identity Notification and an ID Photocopy Are Not the Same Operation
The principle decision No. 2025/2120 of the KVKK Board dated 06.11.2025 provides that recording photocopies of Turkish ID documents at accommodation must end and that earlier copies must be destroyed in accordance with Article 7 of the Law. The obligation to record the necessary identity information and to verify it against the document is separate. The business’s reception procedure, scanner system and archive should be reviewed in light of this distinction.
Listing Verification and Ministry Systems
The Ministry’s Circular 2026/4 dated 14.08.2026 provides that platforms and travel agencies must integrate the data verification system into their software. It is not enough to close to reservations an unsuitable listing that has been reported for removal while continuing to promote it. The certificate information of the facility or housing and the content of the listing should be checked together.
Under Circular 2026/1 dated 16.04.2026, accommodation data is submitted daily in the case of automatic integration and, in the case of manual entry, monthly by the 15th of each month. The data set and the technical method are verified from the current Ministry/TGA documentation. Sharing responsibility with the software provider does not make it unnecessary for the business to follow up on the notification.
Payment Objections and Online Reviews
A chargeback, an in-platform objection and a court claim are different processes. The formation of the contract, the provision of the service, and the cancellation and payment records are preserved together. The assessment must be made without missing the platform’s internal application timeline; these processes are not assumed to suspend the time limit for filing a lawsuit.
A negative customer review is not unlawful in itself. Criticism, fake reviews, threats, infringement of personality rights or of a trademark are distinguished. When responding, guest information must not be disclosed and only proportionate, lawful applications should be made.
Our Approach to Your File
We map the sales channels and data flows. We determine responsibilities from the contract, screen recordings and transaction evidence; we adapt the privacy notice, retention, access and breach management arrangements to how the business actually operates.
Based in Antalya, with a Türkiye-Wide Connection
Güneş & Güneş Law Firm was founded in Kemer in 1999 and has been based in Antalya since 2007. Tourism transactions throughout Türkiye are planned according to the jurisdiction, document and representation requirements of the file. With communication available in Turkish, English, German and Russian, files with a Türkiye connection of persons and companies abroad can also be assessed.
Information Needed for the First Consultation
Briefly state the type of activity or dispute, the location of the facility, your capacity as a party and your request. Prepare the contract, license, decision and notification records. Report any upcoming transaction, travel or application date at the first contact. File-specific documents, secure sharing and the method of representation are clarified during the consultation.