Your data becomes an asset through a contract.
Data processing agreements (DPAs), data sharing agreements and licences: who owns what, the limits on use, and where liability sits when data is commercialised.
The contractual layer of data
Data is an asset that nobody owns in the classical sense and whose value is established by contract. Who may access it, for what purpose it may be used, who owns the derivative products, what happens when the relationship ends — where the answers are not written down, a valuable dataset has no legal protection at all.

Contract typology
Data processing agreements (DPA)
The standard layer in supplier and cloud relationships, carrying the content the KVKK and the GDPR require.
Data sharing agreements
For reciprocal flows with business partners: the balance between purpose, security and liability.
Licensing
For turning a dataset into a product: scope, exclusivity, pricing and audit rights. For connected-product data, the Data Act adds mandatory access and fairness rules on top of that structure.
The personal-data boundary
Licensing begins with classification. Where a dataset contains personal data, the legal basis and the purpose limitation decide what can be done with it; anonymisation properly carried out frees the dataset, but it has to pass a technical test and a legal one. For mixed datasets we design a field-by-field separation — a core practice of our Data focus area.
From flow map to a living template set
Five steps. Data-flow mapping: which data enters and leaves the company, and through which counterparties. Classification: each flow is labelled personal, anonymised or mixed under the KVKK (Law No. 6698) and the GDPR, because the label decides the contract type. Template architecture: DPAs, sharing agreements and licence models are built as a coherent bilingual set, with a fallback matrix for negotiations. Negotiation support: the counterparty's paper is reviewed against your standard and deviations are priced. Renewal and monitoring: usage rights, audit clauses and the return of data on termination are tracked over the life of the contract. Deliverables: the contract inventory, the template set and the fallback matrix.

Typical data businesses and group flows
Typical clients: SaaS and platform companies whose product is inseparable from data, mobility and IoT businesses monetising telemetry, publishers licensing archives, and Turkish-German groups moving datasets between affiliates. In the group scenario, the intra-group agreements and the transfer instruments under Article 9 of the KVKK are designed as one package with our cross-border data transfer practice; where the dataset carries personal data at scale, the architecture is anchored in the KVKK/GDPR compliance programme.
The statutory anchors
The ground under these arrangements has filled up quickly. Since 2025 the Data Act has applied a user right of access to the data generated by connected products and related services, fair terms for sharing it, and rules easing the switch between cloud providers; terms imposed unilaterally are open to unfair-terms review. On the personal data layer, the decisive points are the mandatory content of the KVKK/GDPR processing agreements and the instruments relied on for transfers abroad. In Turkish law the investment in a database is supported by the sui generis protection under the Law on Intellectual and Artistic Works (FSEK, No. 5846); for non-personal sets such as sensor and log data, protection is built essentially through contract and the trade secret regime. Which layer applies is marked field by field, for every data set.
We are by your side for Data Contracts & Licensing
Working from your data-flow map, we build the contract inventory, set up a bilingual template set and align the licensing models with your revenue plan. In AI training-data scenarios we work alongside our AI contracts practice.

Other Applications of This Service
Contract Management — our other specialised solutions in this area.
Matter Connections
The focus areas, practice areas, desks and legislation connected with this sub-service.
Our Matters in This Service
The anonymised examples of our work that relate to this service.
Uninterrupted legal counsel for a multinational supplier
Retainer-based support across day-to-day commercial operations, contract management and compliance processes.
Review the matter →ESG & ComplianceSupply chain due diligence (LkSG) compliance programme
Risk assessment and compliance architecture for a Turkish supplier network under the German LkSG.
Review the matter →Market AccessEstablishing a distribution network in Türkiye
Designing a market entry strategy, distributorship agreements and competition compliance.
Review the matter →The Team Delivering This Service
With our multilingual team of lawyers, well-versed in Turkish and German law, we are by your side.

Mehmet Köksal
Founder and Managing PartnerIstanbul · Berlin · KyreniaProfile →
Kübra Köksal-Yılmaz
PartnerBerlin · İstanbulProfile →
Gül Efem
Of CounselİstanbulProfile →
Herdem Belen
Of CounselİstanbulProfile →
Sven Köksal
Legal EngineerBerlin · İstanbulProfile →Related Publications
Fresh perspectives and guides from the Knowledge Centre.
In legal terms there is no ownership; there are contractual rights and limits. What is critical is that usage rights for raw data, processed data, and derivatives are allocated explicitly.
If it is genuinely anonymous, it falls outside the scope of KVKK/GDPR; however, the re-identification risk must be tested technically. The claim of being “anonymous” is the assumption that fails most often.
Vendors processing high-volume and sensitive data (cloud, CRM, payroll) come first. We build a risk-ranked renewal plan based on the inventory.
Data Contracts & Licensing — get the right legal support.
Let us identify the right solution together, drawing on our experience in Türkiye and the DACH region.
