How to Write a Cookie Policy: Examples, Templates, and KVKK-Compliant Steps

The first thing you see when you visit a website these days is usually a cookie notice. But how well are these notices structured? Is simply typing “I Accept” in the box enough? Unfortunately, not. Many businesses prepare cookie policies that are incomplete, inadequate, or simply copy-paste. This brings with it both legal risks and a loss of user trust. Data protection laws, such as KVKK and GDPR, clearly define the personal data collected through cookies and require transparency in this regard. ✋

“How to write a cookie policy?” is no longer just a question for lawyers, but for anyone with a website. This is because this document is not just a legal obligation; It’s also a trust agreement. When your visitor understands what you collect and why, their loyalty to your brand increases. Otherwise, being tracked through their browser history, encountering undisclosed third-party cookies, or being unable to manage their preferences makes your brand untrustworthy. This loss of trust impacts everything from your reputation to your conversions. 😟

In this article, we’ll take a step-by-step look at how to create a simple yet legal cookie policy without getting bogged down in technical jargon. Under each H2 heading, you’ll find the intricacies of creating a cookie policy, its compliance with KVKK and GDPR, its contribution to the user experience, and comparative explanations with sample templates. Finally, you’ll see how to create a simplified template suitable for your own website and say, “Now I can create a proper cookie policy!” 🚀

Let’s start with the first step: What is a cookie policy, and why is it important?

What is a Cookie Policy, and Why Should It Be Created?

A website’s cookie policy is an official and legal document that explains what types of user data are collected, the purposes for which this data is used, and the rights granted to the user. In short, it answers the question, “What traces does our website leave on your device and what it does with them?” However, many businesses either skip this text entirely or use ready-made phrases. The result is both a violation of legal obligations and a loss of user trust. 🚫

Cookies don’t just collect technical data; they also collect highly subjective and sensitive information, such as behavioral analysis, personalized ads, and user preferences. Therefore, a cookie policy isn’t just “information”; it’s the first step in data processing, the foundation of explicit consent and the obligation to inform. Laws like the KVKK and GDPR, however, don’t just require this text, but rather require it to be presented accurately, understandably, and transparently. Especially if third-party software (e.g., Google Analytics, Meta Pixel, Hotjar, etc.) is used, the details of their data processing must be clearly stated. 📊

The existence of a cookie policy also indicates a corporate brand’s level of digital maturity. Being a brand that “cares about users, informs them, and respects their data” provides not only legal but also marketing advantages. Google and other major platforms now consider cookie and data transparency in SEO scores and ad quality. In short: A suitable cookie policy = Digital trust + Search engine advantage + Legal compliance ✅

To summarize what we’ve learned in this section: A cookie policy isn’t just a document; it’s a “bridge of trust” you build between you and the user. If this bridge isn’t built firmly, you’ll face both legal penalties and the loss of customers. Now that we’ve clearly answered the question of why it needs to be prepared. Now, let’s explore how to structure it. Let’s explore the building blocks together! 🧩

What Are the Basic Functions and Types of Cookies?

Cookies are small data files saved in the user’s browser during a website visit. These files can store information such as user session information, preferences, and language settings. Cookies are technically harmless; however, the scope of the data collected and the purpose of processing are important. Basically, cookies are classified as strictly necessary, performance, functionality and targeting/advertising cookies. Transparently explaining this distinction to users is the first step in a cookie policy.

Where Does the Legal Obligation of a Cookie Policy Come From?

Creating a cookie policy is a legal obligation both under the KVKK in force in Turkey and the GDPR in Europe. KVKK, with Law No. 6698, introduced a obligation to inform regarding the collection and processing of personal data. If personal data is collected through cookies on the website, the user must be informed in advance, and, where necessary, their explicit consent must be obtained. Otherwise, administrative fines may be imposed. In other words, a cookie policy is not just an “option,” but clearly a “mandatory.” ⚖️

Why is Informing the User Critical?

When a user first enters a site, they must be informed about what information will be collected from them and how it will be used. Otherwise, this data processing may be considered legally invalid. Therefore, the cookie policy should not be simply a “text” at the bottom of the site; it should be presented with simple, clear, and understandable content that truly informs the user. Providing the user with a structure that allows them to choose which types of cookies to allow and which to reject is the best approach. 🎯

What Risks Are There Without a Cookie Policy?

A website collecting user data without a cookie policy violates the Personal Data Protection Law (KVKK). This not only leads to criminal penalties but also damages the brand’s digital credibility. Users are increasingly sensitive to their personal data; websites without policies become “untrustworthy” platforms in the eyes of users. Furthermore, quality scores on platforms like Google Ads and Facebook Ads may drop, and ads may be rejected. The risk isn’t just legal; it’s also a commercial and reputational risk. 🚨

Performance cookies: Used to measure website performance and improve the user experience.

Targeting/advertising cookies: Monitor user behavior to display personalized ads.

Functionality cookies: Customize the user’s experience by remembering their preferences (e.g., theme selection, location information).

This distinction provides clear and concise information to the user, making it easier for them to understand which cookies they are consenting to and why. According to the Personal Data Protection Law, consent is not required only for essential cookies. Information and consent are mandatory for all other cookies.

The Distinction Between Explicit Consent and Legitimate Interest

When establishing the legal basis of cookie policies, it should be clearly stated which cookies are processed and on which legal basis. According to the Personal Data Protection Law (KVKK), there may be more than one legal reason for processing personal data. The distinction between “explicit consent” and “legitimate interest” is crucial. ⚖️

• • Mandatory cookies are generally considered within the scope of legitimate interest. For example, if a cookie is technically necessary to maintain the user session, it may not require consent.

• • Cookies that track user behavior, such as advertising, targeting, and statistics cookies, are always subject to explicit consent.

Therefore, when preparing a cookie policy, it should be clearly, understandably, and separately stated which cookies are processed and on which legal basis. Running cookies that require explicit consent without the user’s consent violates the Personal Data Protection Law and may result in serious penalties.

How to Write an Explicit Consent Text? You can learn more about the Consent Cookie Privacy Model by reading our article titled “Effective Consent Processes Compliant with KVKK”.

How to Use Third-Party Cookies Should be specified?

A common practice on websites is the use of cookies from third-party providers. For example, tools like Google Analytics, Meta Pixel, and Hotjar set their own cookies to collect data. 📊

According to the Personal Data Protection Law (KVKK), you are obligated to inform the user not only about your own cookies, but also about third-party cookies. It should be explained which provider sets these cookies, what data they collect, and the purpose for which they are used. It should also be clearly stated whether this data is transferred abroad.

A best practice is to list third-party cookies in a separate section of the cookie policy and provide links to the providers of these cookies (e.g., Google’s privacy policy). This way, users can learn in detail which data is being processed and by whom.

Policy Up-to-Date and Accessibility Policy

Preparing a cookie policy is not a one-time action. Legal changes, new site integrations, or changes in the cookies used require this policy to be updated. Therefore, cookie policies should be reviewed regularly and revised if necessary. 🔄

Furthermore, this policy page should be easily accessible by users. The most common method is to place a fixed link in the footer of the page. Additionally, offering a “preference management panel” where users can change their cookie preferences is also an important step in ensuring transparency.

An outdated or inaccessible cookie policy not only undermines user trust but can also lead to administrative sanctions due to non-compliance with the Personal Data Protection Law (KVKK). Therefore, it is crucial for businesses to be proactive in this regard.

Cookie Policy Template: Is It Possible to Start with a Pre-made Text?

As a website owner, it may be tempting to use pre-made templates when creating your cookie policy. But is it really sufficient? The answer to this question may vary depending on your website type, your industry, the integrations you use, and your target user audience. A cookie policy isn’t just a “sample text”; it’s also an important tool for your business’s legal representation in the digital world and for building user trust.

It’s possible to find numerous cookie policy templates on the market: a wide range of templates are available, from WordPress plugins and examples provided by law firms to automated content generators from tools like Cookiebot. However, most of these ready-made texts contain general information and often fail to detail the requirements of the KVKK in the context of local law. For example, a text focused on the GDPR in Europe may be inadequate in Turkey when compared to the KVKK. Similarly, a text that merely provides “information” may subject you to administrative sanctions if it doesn’t correctly define the explicit consent mechanism.

Ready-made templates should only be considered a starting point. The key is to align the template’s content with your business-specific cookie usage, data processing activities, legal bases, third-party tools, data transfer, and user preference management. In short, the template only provides a framework; the sections to be filled in and processed are entirely up to you.

At this point, you should ask the following questions when creating your cookie policy:

• • What cookies do I collect? (Name – Duration – Purpose – Provider)

• • What is the legal basis for each of these cookies?

• • Are user choices offered?

• • How are these preferences stored and updated?

• • Is data transferred abroad?

• • Third-party providers who?

A template that doesn’t answer such questions remains merely a formal document. However, regulations like the KVKK and GDPR require not only having a document but also that it be meaningful and practical. Therefore, it’s possible to start with a template, but customizing the “ready-made” text to your own needs is essential.

✅ What are the advantages of ready-made templates?

Ready-made templates can be quite useful initially for those who want to save time and gain a basic structure when preparing a cookie policy. These texts usually include mandatory sections, are presented in a user-friendly format, and are suitable for quick editing. Additionally, thanks to plugins that provide these templates on platforms like WordPress and Shopify, policies can be created without even requiring technical knowledge.

🎯 Advantages in brief:

• • Time saving

• • General regulatory compliance framework

• • Visually consistent templates

• • Easy for non-technical users

However, these advantages only apply as long as they remain at the “draft” level. Text used without further elaboration can pose serious risks.

✅ Points to Consider When Using Templates

It’s certainly possible to start with a ready-made text. However, the most frequently overlooked point in KVKK compliance is not taking into account a company’s specific circumstances. Elements such as the type, duration, providers, and explicit consent mechanisms for cookies specific to your business model (e.g., advertising, analytics, personalization) are often missing from templates.

⚠️ Therefore, the following should be noted:

• • Manually add the types and purposes of cookies to the template.

• • Define your explicit consent and withdrawal processes.

• • Responsibilities of third-party cookies specify.

• • Update the template based on the year; Revise according to changing tools.

Otherwise, simply placing a “ready-made text” on your website does not mean that you have fulfilled your obligations.

✅ Is it Adequate for KVKK and GDPR?

No, most ready-made templates are not fully compliant with either KVKK or GDPR. They usually only provide “information” but do not reflect the detailed data processing logic, including the “explicit consent” process. User control elements such as saving user preferences and granting the right to change preferences may be missing.

The most common deficiencies in terms of KVKK:

• • There is no purpose-based cookie list.

• • The consent management mechanism is not disclosed.

• • Third parties processing data are not identified.

• • If data is transferred abroad, it is not indicated.

Therefore, the template texts are only a starting point. For an effective cookie policy, each clause should be customized to your activities.

You can learn more about the Consent Cookie Privacy Model by reading our article titled Cookies in Terms of KVKK: Common Mistakes and Solutions During the Compliance Process.

✅ The Right Approach: Template + Customization + Tracking

The most effective method is to enrich a professional template with custom data, add explicit consent flows based on user behavior, and keep it updated. Because the cookie policy is not just a page; It is a living compliance document that should be continuously updated.

🛠 Recommended approach:

1. 1. Get a qualified template (preferably one that complies with local legislation).

1. 1. List and classify cookies.

1. 1. Define your method for obtaining explicit consent.

1. 1. Integrate technical solutions for preference management.

1. 1. Review your policy every 6 months.

This strategy not only serves legislation but also user trust.

Is Your Cookie Policy Page Clear Enough?

The cookie policy pages on websites are often created solely to fulfill a legal obligation. This results in content that is largely complex, full of technical terms, unfriendly, and often unreadable. However, true compliance and effective communication is not simply publishing a text; This is achieved by presenting this text in a way that is understandable, accessible, and transparent to everyone.

Users clearly know what they want to see when they visit the cookie policy page: Why is their data being collected, how is it being used, and can they control it? However, because many websites fail to answer these questions directly and clearly, user trust is damaged, the risk of non-compliance increases, and the likelihood of facing administrative fines, especially under regulatory frameworks such as the KVKK, increases. 📉

Our fundamental question at this point is: Is your cookie policy page truly understandable? If your text is written in a language only understandable to legal experts, if technical terms are left unexplained, or if it doesn’t provide clear information to the user about their rights such as “exit” and “objection,” this page is just a formality. However, the cookie policy is also a user experience element. A visitor can gauge how much your website values them, whether you are transparent, and whether you respect their data through this page. 💡

A clear policy should include simple language, clear headings, a question-and-answer format, bullet points, interactive preferences, and practical explanations such as “Which cookies are being loaded from this device?”. If possible, a cookie preference panel should be integrated that gives the user the right to instantly change their preferences.

Remember: Under the Personal Data Protection Law, the “obligation to inform” means not only providing information, but also presenting this information in a clear and understandable manner.

How to Write an Explicit Consent Text? You can learn more about the Consent Cookie Privacy Model by reading our article titled “Effective Consent Processes Compliant with KVKK.”

What Should Visitors Understand from This Page?

What should a user encounter when they open your cookie policy page? The answer to this question requires much more than a jumble of legalese. Visitors must clearly understand how their data is processed, which cookies are used for what purpose, which cookies are mandatory and which are optional, and what rights they have regarding these preferences. In other words, it’s not just a matter of saying “we use cookies”; You should also clearly provide answers such as why, how, for how long, and what can you do.

Descriptive Headings and Bullet Points Are a Must

Users don’t read long, uninterrupted blocks of text. Therefore, you should use short paragraphs, clear headings, numbered lists, and bullet points on your cookie policy page. For example, presenting categories like “Mandatory Cookies,” “Statistical Cookies,” and “Marketing and Targeting Cookies” with their own subheadings and simple sentences contributes positively to both SEO and user experience. 📄

Interact with the Preference Panel

No matter how well-written a cookie policy is, if the user cannot control these preferences, that page is incomplete. A cookie preference panel should be present that allows users to accept only essential cookies or makes it easy to reject marketing cookies. This panel should include clear buttons like “Accept All” and “Manage Preferences,” and preferences should be changeable at any time. 🧭

Multilingual and Accessible Formats Are Important

Turkish content is already mandatory for websites operating in Turkey. However, offering multilingual versions, especially English, for users with different languages is advantageous for both accessibility and international compliance. Furthermore, details such as ensuring your page is readable on mobile devices, offering screen reader support, and having a sufficiently large font size are important for accessibility standards. 🌐

🌟 Conclusion: A Well-Written Cookie Policy is the Foundation for Building Trust Through Transparency

In the digital world, every visitor leaves a trace. How these traces are collected, how they are used, and the degree of control users have over this process are not only a technical issue but also a matter of trust and reputation. That’s why a cookie policy is not only a legal obligation; it’s also a strategic document that reflects your digital stance.

As we’ve discussed in this guide, preparing a cookie policy isn’t just about filling in a few text boxes. Separating cookie types, associating them with a disclosure text, managing user preferences, regularly updating them, and designing all these processes in compliance with both KVKK and GDPR is every brand’s digital responsibility.

Remember: Transparency is the key to user loyalty. If a visitor trusts your website, they also trust your brand. The first step to this trust is a clear and accessible cookie policy. Today’s visitors want to know which of their data is being processed, why, and how. And every business that clearly answers these questions ensures its future success. 🔐✨

How to Control Cookies with Google Tag Manager? You can learn more about the Consent Cookie Privacy Model by reading our article titled “Technical and Legal Approach.”

📞 Let Us Call You – Take Action for a KVKK-Compliant Cookie Policy!

At Adapte Dijital, we create fully compliant, effective, and understandable cookie policies for your website. If you’d like, we can design a custom form together, set up your preferences panel, and audit your KVKK processes.
👉 Fill out our form, and we’ll call you!

You can visit the Red Makine website, where we implement the Consent Cookie Privacy Management Model, by clicking the link.