Pinterest

An examination of Pinterest’s compliance journey reveals a platform that initially preferred a light-touch, indirect structure but has, as of 2025, pivoted to a model that fully satisfies the stringent structural and financial conditions of Law No. 5651. Recent amendments regarding trade name, capital adequacy, and liability principles demonstrate a clear will to bring its presence in the Türkiye market into total alignment with the legal landscape.

Pinterest’s corporate footprint in Türkiye began on 12 July 2021 with the establishment of “WRP Turkey Web Tasarım Hizmetleri Limited Şirketi” by the Ireland-based Pinterest Europe Holding Unlimited Company. At its inception, the company held a capital of TRY 2.500.000. However, it fulfilled the representation obligation merely “formally”, as its title lacked the platform’s name and its declared activity was the generic field of “web design”.⁹⁰

Following the aggravation of obligations for social media platforms, a radical legal transformation was executed via a General Assembly decision registered on 18 August 2025. First, the company was renamed “Pinterest İstanbul Web Tasarım Hizmetleri Limited Şirketi” to satisfy the “distinctive phrase” requirement. Simultaneously, ownership was consolidated: Pinterest Europe Limited became the sole owner and manager, with James Kim (resident in the USA) authorised to act on behalf of the entity. Furthermore, the company’s capital was aggressively increased by TRY 97.500.000 to reach the legal minimum of TRY 100.000.000.

The linchpin of this transformation is Article 15, titled “Representation and Liability”, which was added to the company’s articles of association. This article explicitly decrees that the local entity is the representative of Pinterest Europe Limited in Türkiye and is “fully authorised and held responsible in technical, administrative, legal, and financial terms” by the parent company.⁹¹ This clause confirms that Pinterest’s local entity has evolved from a mere liaison office into a direct addressee for legal sanctions and administrative decisions.

Legal Obligations	Status	Notes
Representative Obligation	Meets	Authorized representative appointed in Türkiye.
Local Company Establishment	Meets	“Pinterest İstanbul Web Tasarım Hizmetleri Limited Şirketi” was established as an Istanbul-based capital company.
Trade Name Condition	Meets	Trade name includes platform name and province.
Explicit Affiliation & Authorization	Meets	Company is directly affiliated with and authorized by Pinterest.
Turnover & Reporting Obligation	Unknown	No public information regarding report submission to BTK.
Application Form for Users	Partially Meets	Content removal request form specific to Türkiye is available, but only in English.
User Application Processes	Meets	The hierarchy of examining applications is explained in reports.
Transparency Reports	Meets	Reports are published in Turkish with statistical and categorical data.
Personal Data Localization	Does Not Meet	Not specified in transparency reports whether user data is hosted on servers in Türkiye.
Hashtag and Content Liability	Meets	It is stated that hashtags (search terms) violating policies are removed from search results.
Creating a Crisis Plan	Unknown	No public information regarding a crisis plan.
Providing Information to Judicial Authorities	Unknown	No statistics regarding data sharing with judicial authorities.
Ad Library	Partially Meets	Created in 2025.
Bandwidth Throttling Sanctions	Not Applied	Not applied to date under Law No. 5651.
Administrative Fines	Unknown	No information regarding whether applied.
Other Obligations	Partially Meets	Detailed information provided regarding privacy settings and child safety policies.

Table 21: Pinterest Platform Compliance Scorecard

The Language Barrier

While a special application form has been created for users and is explicitly mentioned in reports, a significant barrier remains: the form is available only in English. There is currently no Turkish version, severely limiting its accessibility for local users.⁹²

Screenshot 4: Pinterest Complaint Form

Transparency Reports Assessment

Pinterest has maintained a regular reporting schedule since the second half of 2021, although accessing these reports from a single central hub remains impossible.⁹³

The reports offer specific data (on a Pin, Board, and Account basis) regarding content removed for violations of community guidelines, such as adult content or hate speech. However, the data regarding Article 9 (personal rights) and Article 9/A (privacy),the specific legal regulations for Türkiye, is remarkably sparse.

Period	Turkish Report	Art. 9 Statistics	Art. 9/A Statistics	Categorical Data	Notes
2021-1	No	-	-	-	Not published.
2021-2	Yes	No	No	Yes	Community guidelines violations given in detail.
2022-1	Yes	No	No	Yes	Community guidelines violations given in detail.
2022-2	Yes	No	No	Yes	Community guidelines violations given in detail.
2023-1	Yes	Yes (0 Requests)	Yes (0 Requests)	Yes	Stated that no action taken under Art. 9 and 9/A.
2023-2	Yes	Yes (0 Requests)	Yes (0 Requests)	Yes	Stated that no request received under Art. 9 and 9/A.
2024-1	Yes	Yes (0 Requests)	Yes (0 Requests)	Yes	Stated that no request received under Art. 9 and 9/A.
2024-2	Yes	Yes (0 Requests)	Yes (0 Requests)	Yes	Stated that no request received under Art. 9 and 9/A.
2025-1	Yes	No	Yes (1 Request)	Yes	1 request received under 9/A, no action taken.

Table 22: Summary of Pinterest Platform Transparency Reports

In reports covering 2023 and 2024, Pinterest stated that it received either zero applications under these articles or that the single application received (in 2025-1) was not processed due to insufficient information. This suggests either that users prefer the platform’s native “Report Pin” mechanism over legal channels, or that Pinterest funnels incoming requests primarily through its own community guidelines, effectively bypassing the formal legal procedure.

Advertising Transparency

Pinterest’s declarations regarding advertising have been inconsistent. In 2023 reports, the platform explicitly claimed to offer an “ad-free experience” in Türkiye, stating it did not publish advertisements.⁹⁴ By 2024, this claim vanished. In practice, it is observed that advertisements based in Türkiye appear on the platform.

In the transparency report for the second half of 2024, Pinterest announced the creation of an “Ad Repository”, a searchable library for Turkish users detailing ad content, targeting and reach. However, the report failed to share the web address for this tool.⁹⁵ It was only in the January–June 2025 report that the address was finally shared,⁹⁶ granting access to limited ad information.⁹⁷

Pinterest complies formally with legislation by fulfilling structural obligations, yet it exhibits distinct deficiencies in user rights and transparency. The lack of Turkish language support for the specific application form, combined with near-zero legal application numbers, renders the platform’s rights-seeking mechanisms practically largely theoretical. Furthermore, the shift from claiming an “ad-free experience” to offering a restricted and difficult-to-find “Ad Library” reveals a bureaucratic approach to compliance, one that prioritises meeting minimum administrative conditions over fostering genuine user transparency.

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90. or establishment information, see Turkish Trade Registry Gazette, No. 10369, 13.07.2021, p. 293. ↩

91. For title change, share transfer, capital increase, and amendment to articles of association (Article 15), see Turkish Trade Registry Gazette, No. 11395, 18.08.2025, p. 766. ↩

92. See https://www.pinterest.com/about/turkey/ ↩

93. See https://policy.pinterest.com/tr/transparency-report-turkey ↩

94. In Pinterest’s Transparency Report for the period January 2023 – June 2023, it is stated: “We would like to underline that Pinterest does not advertise in Türkiye and the user experience in Türkiye is ‘ad-free’.” The same statement appears in Pinterest’s Transparency Report for the period July 2023 – December 2023. ↩

95. See https://policy.pinterest.com/tr/turkiye-seffaflik-raporu-h2-2024 ↩

96. See https://ads.pinterest.com/ads-repository/ ↩

97. See https://policy.pinterest.com/en/turkiye-seffaflik-raporu-h1-2025 ↩