KVKK, GDPR & CCPA: What Each Regulation Demands from Cookies

Learn how to meet all three regulations simultaneously.

Three regimes, one banner

GDPR, KVKK and CCPA/CPRA start from different legal traditions but hit the same page. GDPR and KVKK are opt-in: nothing non-essential loads until the visitor agrees. CCPA is opt-out: processing may start, but the visitor must be able to say "Do Not Sell or Share My Personal Information" and the site must honour the Global Privacy Control browser signal.

Consent definitions compared

GDPR requires freely given, specific, informed and unambiguous consent through a clear affirmative action. KVKK requires açık rıza with the same qualities, plus explicit rules for transfers abroad. CCPA does not require consent for most adult data but adds strict rules for minors and for the sale or sharing of personal information.

• GDPR: opt-in, fines up to 4% of global turnover
• KVKK: opt-in, administrative fines set by the Turkish authority
• CCPA/CPRA: opt-out plus mandatory GPC signal support

Cross-border transfers

GDPR relies on adequacy decisions and Standard Contractual Clauses. KVKK requires either an adequacy decision, a written undertaking, or explicit consent for the specific transfer. CCPA regulates service-provider contracts rather than geography. A single consent record therefore has to store the jurisdiction it was collected in, not only the answer.

Serving all three from one platform

Geo-targeting solves the conflict: show an opt-in banner to EU and Turkish visitors, an opt-out notice with a Do Not Sell link to Californian visitors, and keep one consent log with jurisdiction, timestamp and banner version. CookieTrace ships this behaviour by default, including Consent Mode v2 signalling so Google tags respect each regional rule.