Ekşi Sözlük¶
As a domestic platform, Ekşi Sözlük operates under a different framework from its foreign counterparts. It is exempt from the requirement to appoint a representative or establish a local branch. Instead, it operates as an Istanbul-based entity (Ekşi Teknoloji ve Bilişim A.Ş.), fulfilling its reporting duties under Law No. 5651 directly. Notably, the platform explicitly confirms that it hosts user data within Türkiye and maintains an active ad library.
The platform’s compliance status regarding legal obligations is evaluated in the table below.
| Legal Obligations | Status | Notes |
|---|---|---|
| Representative Obligation | Not Applicable | No obligation to appoint a representative as it is domestic-sourced. |
| Local Company Establishment |
Meets | It is a company established in Türkiye (Ekşi Teknoloji ve Bilişim A.Ş.). |
| Turnover & Reporting Obligation |
Unknown | No public information regarding report submission to BTK. |
| Application Form for Users | Meets | Communication channels and application methods exist. |
| User Application Processes |
Meets | The manner in which applications are examined is explained in transparency reports. |
| Transparency Reports | Partially Meets | Reports are published regularly, and statistical data is presented in graphs. However, Article 9 and 9/A data are not numerically disaggregated. |
| Personal Data Localization | Meets | It is stated in transparency reports that user data is hosted on servers in Türkiye. |
| Hashtag and Content Liability |
Unknown | No mention of a procedure specific to hashtags in reports. |
| 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 | Meets | It is declared in transparency reports that the ad library has been created and is accessible.[1] |
| Bandwidth Throttling Sanctions |
Not Applied | Not applied to date under Law No. 5651. |
| Administrative Fines | Unknown | No information regarding whether applied. |
| Other Obligations | Unknown | No publicly available information. |
Transparency Reports Assessment¶
Ekşi Sözlük has maintained a consistent reporting schedule since 2021. However, the granularity of the data leaves room for improvement. While the reports provide a “total” figure for applications under Article 9 and Article 9/A of Law No. 5651, they fail to provide specific numerical disaggregation for these distinct legal grounds.
The reports do categorise decisions, listing “violation of personal rights”, “right to be forgotten”, and “lifting of access blocking”, but fail to tie these back to the specific articles of the Law. While they track personal application categories (e.g., “insult”, “damage to commercial reputation”, “unauthorised sharing of personal data”), and provide outcome data (positive/negative/partial), it remains impossible to discern which specific legal lever (Article 9 or Article 9/A) was pulled for each application.
| Period | Turkish Report |
Art. 9 Statistics |
Art. 9/A Statistics |
Categorical Data | Notes |
|---|---|---|---|---|---|
| 2021-1 | Yes | No | No | Partially Exists | 2.268 applications. |
| 2021-2 | Yes | No | No | Partially Exists | 3.965 applications. |
| 2022-1 | Yes | No | No | Partially Exists | 4.088 applications. |
| 2022-2 | Yes | No | No | Partially Exists | 2.497 applications. |
| 2023-1 | Yes | No | No | Partially Exists | 1.777 applications. |
| 2023-2 | Yes | No | No | Partially Exists | 3.545 applications. |
| 2024-1 | Yes | No | No | Partially Exists | 2.384 applications. |
| 2024-2 | Yes | No | No | Partially Exists | 2.374 applications. |
| 2025-1 | Yes | No | No | Partially Exists | 2.320 applications. |
Data Localisation and Format Issues¶
On a positive note, the platform is unequivocal regarding data sovereignty. Ekşi Sö- zlük explicitly states that it hosts user data on servers in Türkiye and has established an accessible ad library, thereby complying with the obligations introduced by Law No. 5651.
However, the presentation of data poses a challenge for researchers. Instead of standard numerical lists, Ekşi Sözlük opts to present statistical data via visual graphs. While aesthetically pleasing, this format preference hinders the automatic processing and independent analysis of the data.
The Legal Lag¶
Furthermore, the reports fail to align with recent legal developments. Despite the Constitutional Court’s annulment of Article 9, recent reports contain no update regarding this shift. Applications continue to be lumped under the obsolete general category of “relevant persons under Articles 9 and 9/A”.
Consequently, while Ekşi Sözlük meets the structural requirements of a domestic entity, its transparency reports are only partially compliant with the specific demands of Law No. 5651.