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A gateway can help route AI requests to infrastructure in Türkiye, but its presence alone does not prove that personal data stays there or that a system complies with Türkiye’s Personal Data Protection Law (KVKK). To make that claim responsibly, define every destination and processing step: inference, logs, backups, support access, and any downstream provider.
What “keeping data in Türkiye” means
For an AI request, the phrase should describe a specific data path—not a general promise. Identify where the gateway runs, where each model performs inference, and where request content, responses, logs, backups, and operational metadata may be stored or accessed. A location label by itself cannot establish where every copy or processing activity occurs.
A gateway can enforce parts of that path by inspecting requests, filtering or transforming content, selecting a provider, and controlling logging, storage, and response handling. Those controls are only as complete as the architecture and provider arrangements they cover.
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What KVKK requires you to consider
Law No. 6698 defines personal data broadly as information relating to an identified or identifiable natural person. Its principles include processing for specified, explicit, and legitimate purposes; keeping data relevant and limited to those purposes; and retaining it only for the period required by law or the purpose of processing. See the KVKK Authority’s English translation of Law No. 6698. The Authority says the law was ratified on 24 March 2016 and published on 7 April 2016; where the English translation differs in meaning, the Turkish text applies.
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Foreign transfers are not an absolute ban
KVKK Article 9 was amended in 2024. It provides conditional mechanisms for transferring personal data abroad, including an adequacy decision for the destination and appropriate safeguards, subject to the applicable processing condition. The Authority’s transfer guidance discusses adequacy, explicit consent, written commitments, and Board authorization; its 2024 announcement identifies standard contract texts and binding corporate rules as appropriate-safeguard methods. The route depends on the actual circumstances, so neither “KVKK bans cloud” nor “a gateway makes transfers compliant” is an accurate blanket rule.
Before a request reaches a global provider, determine whether the route involves a transfer abroad and which legal mechanism applies. The Authority’s guidance on transfers abroad and its 2024 announcement on standard contracts are useful starting points; they do not decide whether a particular deployment meets the requirements.
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Masking is not automatically anonymization
KVKK defines anonymization as rendering personal data impossible to link to an identified or identifiable person, even by matching it with other data. Replacing a name with a placeholder, redacting a field, or keeping a re-identification map may be masking or pseudonymization rather than anonymization. Describe the transformation precisely unless you can establish that it meets the statutory definition.
Choose the route by tracing the whole request
A meaningful comparison is between a model hosted in Türkiye and a global-provider route. Assess each route across the same dimensions rather than relying on a provider’s location label alone.
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| Question | What to establish |
|---|---|
| Where is inference performed? | Identify the model and its actual inference location, as well as any other locations involved in processing. |
| Who receives or handles data? | Name the provider and relevant subprocessors, including any downstream services in the request path. |
| What is retained? | Determine whether request content, responses, logs, backups, or operational metadata are stored, for how long, and who can access them. |
| Does the route transfer data abroad? | Assess the actual processing path and identify the applicable KVKK transfer mechanism, if any. |
| What are the operational trade-offs? | Compare capability, latency, cost, and operational requirements using evidence for the models and deployment being considered. The cited sources provide no comparable performance or security test results. |
For example, LLMTR says its API is OpenAI-compatible and offers both Turkey-hosted and global model access. It states that only models clearly marked Turkey-hosted run on its infrastructure in Türkiye, while global-provider models may follow the selected provider’s processing rules. It also identifies its operator as Knowhy İleri Teknoloji Ticaret Limited Şirketi. These are the vendor’s descriptions, not independent verification of a deployment or its data path; check the relevant model and provider terms before relying on them. See LLMTR’s service information.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Design logging, retention, and deletion deliberately
Logging choices affect both data exposure and the ability to operate a service. Decide what the gateway needs to record for troubleshooting, security, and accountability, then limit content and retention to what those purposes require. Include backups and operational access in the retention plan rather than considering only the primary database.
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The KVKK Authority says controllers must take technical and organizational measures, document methods in relevant policies and procedures, and record erasure, destruction, and anonymization operations. Those records must be retained for a minimum of three years, excluding other legal obligations. The period applies to the records of those operations, not as a general retention period for all personal data. See the Authority’s guidance on personal-data storage and destruction.
What evidence supports a data-location claim?
To substantiate a claim that a particular AI route keeps personal data in Türkiye, document and verify the real deployment rather than infer it from the gateway’s location. A useful record should cover:
- Where the gateway and model inference run, including the selected model for each route.
- Every provider and subprocessor that may receive or process request data.
- How request content and responses are filtered or transformed, and whether any re-identification information remains accessible.
- Where logs, backups, and operational metadata are stored, their retention periods, and who can access them.
- Whether any route transfers data abroad and the legal mechanism relied on for that transfer.
- Tests or other evidence that confirm the implemented routing and storage behavior.
Without those facts, it is not possible to establish where all processing occurs or determine whether a particular deployment complies with KVKK. The statutory framework and a vendor’s hosting description can inform the assessment, but neither substitutes for evidence about the system’s own configuration and data flows.
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