Multi Mulk

Privacy & Data Protection

Company policies concerning leads, CRM systems, data protection, information security, confidentiality, intellectual property, digital systems and professional responsibilities.

SECTION 10

Company Leads, CRM & Data Protection

The Employee acknowledges that all Company leads, client data, CRM records, internal systems, databases, communications, pricing information, business strategies, developer information, partnership information, project details, marketing data, and operational processes are confidential, proprietary, and remain the exclusive property of the Company.

This includes, but is not limited to:

  • Client names and contact details;
  • Leads assigned through CRM, marketing campaigns, referrals, developers, partners, websites, social media, call campaigns, walk-ins, exhibitions, or internal sources;
  • CRM records and lead history;
  • WhatsApp messages and business communications;
  • Email communications;
  • Client files and documents;
  • Developer offers, inventories, price lists, payment plans, and commission arrangements;
  • Business strategies and sales methods;
  • Internal reports and performance data;
  • Marketing materials and campaign results;
  • Partner, broker, developer, and supplier contacts;
  • Company templates, forms, agreements, and presentations.

The Employee shall ensure that all assigned leads, client interactions, calls, meetings, follow-ups, qualification notes, documents, and transaction progress are accurately and promptly recorded in the Company's CRM or other approved systems.

Failure to properly or promptly update the CRM may result in disciplinary action in accordance with Company policies and applicable law. Where relevant, commission eligibility may also be affected in accordance with the applicable commission plan, Company policy, and applicable law until compliance has been verified by Management.

SECTION 11

Direct Prohibition on Lead Bypassing

The Employee is strictly prohibited from bypassing corporate communication channels or Company systems in order to handle Company leads or clients independently or for unauthorized purposes.

The Employee shall not:

  • Divert Company leads to external entities;
  • Refer Company leads to third-party brokers, agents, developers, consultants, competitors, or other persons without prior written approval from Management;
  • Handle Company clients outside approved Company systems for personal benefit or the benefit of any third party;
  • Use personal devices, personal email accounts, personal cloud accounts, personal CRM tools, or personal messaging channels to store, manage, transfer, or transmit Company data without explicit written authorization from HR or Management;
  • Introduce Company clients to external parties outside the Company's involvement without authorization;
  • Hide, delay, manipulate, delete, falsify, or misrepresent lead status, client information, or CRM activity;
  • Save Company clients under personal names or private contact lists for future personal or external use;
  • Reassign, redirect, or transfer Company clients, leads, or opportunities to personal accounts or third parties without authorization;
  • Receive or attempt to receive any personal commission, referral fee, benefit, or compensation arising from a Company lead without written authorization.

Any confirmed breach of this clause may constitute serious misconduct and may result in disciplinary action and/or termination for cause where the requirements for such action are satisfied under applicable Turkish labor law.

The Company reserves all rights and remedies available under applicable law in relation to lead diversion, unauthorized transactions, misuse of Company information, or related misconduct.

SECTION 12

Data Extraction & Information Security

The Employee is strictly prohibited from downloading, exporting, screenshotting, photographing, copying, recording, reproducing, transmitting, forwarding, syncing, or otherwise extracting lead lists, client databases, CRM records, Company documents, WhatsApp conversations, email records, contact lists, project information, pricing data, or other Company information except where reasonably required within the direct scope of the Employee's authorized duties.

The following actions are strictly prohibited without prior written authorization from HR or Management:

  • Downloading or exporting CRM data;
  • Copying lead lists or client databases;
  • Taking unauthorized screenshots or photographs of CRM records, client records, or internal documents;
  • Forwarding Company emails or client communications to personal accounts;
  • Exporting contacts from Company systems;
  • Syncing Company data with unauthorized personal phones, laptops, tablets, cloud storage, applications, or external devices;
  • Copying WhatsApp conversations or forwarding Company WhatsApp messages outside approved channels;
  • Saving Company files on unauthorized personal or third-party cloud storage;
  • Uploading Company information to unauthorized AI tools, databases, applications, websites, or external platforms;
  • Using Company data for personal purposes or for the benefit of any third party.

Downloading, exporting, screenshotting, photographing, copying, transmitting, or extracting Company information for personal use or for use outside the authorized scope of the Employee's duties may constitute misuse of Company property, breach of confidentiality, unfair competition, data misuse, serious misconduct, and, where the applicable legal requirements are satisfied, infringement or misappropriation of Company intellectual property.

Any confirmed instance of data leakage, unauthorized lead sharing, unauthorized data extraction, CRM misuse, client diversion, lead diversion, or deliberate bypassing of Company information systems may result in disciplinary action and/or termination for cause where legally permissible and where the requirements of applicable Turkish labor law are satisfied.

Nothing in this clause shall limit any mandatory statutory rights of the Employee.

The Company reserves all legal rights and remedies in relation to unauthorized data use, data leakage, intellectual property misuse, client diversion, confidentiality breaches, or other unauthorized use of Company information.

SECTION 13

Personal Devices & Personal Accounts

The Employee shall not use personal devices, personal cloud storage, personal email accounts, personal CRM systems, personal social media accounts, or personal communication platforms for Company business unless expressly authorized in writing by HR or Management.

If the Company authorizes the Employee to use a personal device or personal account for Company-related work, all Company information stored, accessed, processed, transmitted, or received through such device or account shall remain the property of the Company.

The Employee must take reasonable security measures to prevent unauthorized access, disclosure, loss, copying, or misuse of Company information.

Upon request by the Company, resignation, termination, reassignment, or withdrawal of authorization, the Employee shall promptly:

  • Return all Company information and Company property;
  • Transfer all Company-related files, records, and communications to approved Company systems;
  • Delete Company information from personal devices, accounts, and storage locations where legally and technically possible;
  • Stop accessing Company platforms, systems, accounts, and communication channels for which access is no longer authorized;
  • Return or permanently delete credentials, access tokens, files, backups, and copies relating to Company systems where applicable;
  • Cooperate with reasonable verification that Company information has been properly transferred or deleted.

Any verification involving a personal device or personal account shall be limited to what is reasonably necessary to confirm the transfer, return, or deletion of Company information and shall be conducted in accordance with applicable privacy and personal-data-protection requirements. The Company shall not require access to unrelated private information unless permitted by applicable law.

The Employee shall not intentionally retain Company information after termination of employment except where retention is required by applicable law or expressly authorized in writing by the Company.

SECTION 14

AI Tools, Company Systems & Digital Security

The Employee shall use only Company-approved systems, applications, CRM tools, AI tools, cloud-storage services, communication channels, and digital platforms for Company work where such approval is required by Company policy.

The Employee shall not upload, copy, paste, submit, disclose, share, or process Company data, client information, lead records, documents, contracts, developer information, pricing information, internal strategies, credentials, or other confidential material through unauthorized AI tools, software, public databases, cloud platforms, or external applications without prior written approval from Management.

This restriction includes, but is not limited to:

  • AI chatbots;
  • AI writing and content-generation tools;
  • AI coding or analysis tools;
  • CRM alternatives;
  • Personal automation tools;
  • Personal cloud drives;
  • External databases;
  • Third-party file-sharing systems;
  • Unapproved messaging applications;
  • Unapproved browser extensions or integrations capable of accessing Company information.

Where the Company authorizes the use of an AI tool or other external platform, the Employee shall use such tool only within the authorized scope and shall comply with all applicable Company security, confidentiality, privacy, and data-protection policies.

The Employee shall immediately report any known or reasonably suspected:

  • Data breach;
  • Unauthorized access;
  • Account compromise;
  • Phishing attempt;
  • Malware or cybersecurity incident;
  • Loss or theft of a device containing Company information;
  • Accidental disclosure of Company information;
  • Unauthorized sharing of login credentials;
  • Unauthorized extraction or transfer of Company data.

The Employee shall reasonably cooperate with Company security procedures following any such incident.

SECTION 15

Confidentiality

The Employee acknowledges that during employment they may have access to confidential, proprietary, commercially sensitive, or legally protected information belonging to the Company, its clients, developers, partners, suppliers, employees, or other third parties.

Confidential information includes, but is not limited to:

  • Client data;
  • Leads;
  • CRM records;
  • Internal systems;
  • Databases;
  • Business strategies;
  • Pricing information;
  • Developer relationships;
  • Partnership agreements;
  • Commission structures;
  • Company documents;
  • Marketing materials;
  • Operational processes;
  • Sales scripts;
  • Training materials;
  • Employee records;
  • Financial information;
  • Legal documents;
  • Business plans;
  • Technical information;
  • Login credentials and access information;
  • Internal reports and analytics;
  • Non-public commercial information.

The Employee shall not disclose, share, copy, misuse, publish, transfer, retain, sell, reproduce, or otherwise use confidential information except as reasonably necessary for authorized Company duties or as expressly authorized in writing.

The obligations in this clause shall not apply to information that the Employee can demonstrate:

  • Was lawfully known to the Employee before disclosure by the Company;
  • Becomes publicly available through no breach of this Agreement;
  • Was lawfully obtained from a third party without a confidentiality obligation;
  • Was independently developed without unauthorized use of Company confidential information;
  • Has been expressly approved for disclosure by the Company; or
  • Must be disclosed pursuant to applicable law, a court order, or a binding request from a competent authority.

Where legally permitted, the Employee shall promptly notify the Company before making a legally required disclosure and shall disclose only the information legally required.

Confidentiality obligations relating to trade secrets, client data, personal data, and other information protected by law shall continue for as long as such information remains legally protected or confidential. Other confidentiality obligations shall continue after termination to the extent permitted by applicable law.

SECTION 16

Intellectual Property & Work Product

The Employee acknowledges that work product created, developed, prepared, produced, adapted, organized, or materially contributed to by the Employee within the scope of their employment duties, specifically for Company business, or using Company resources shall belong to the Company to the extent provided by applicable law.

Such work product includes, but is not limited to:

  • Videos;
  • Photos;
  • Reels;
  • Interviews;
  • Social media content;
  • Marketing content;
  • Audio recordings;
  • Promotional materials;
  • Educational or sales-related content;
  • Scripts;
  • Captions;
  • Presentations;
  • Brochures;
  • Proposals;
  • Reports;
  • Templates;
  • Client databases;
  • CRM records;
  • Lead lists;
  • Sales scripts;
  • Training documents;
  • Standard Operating Procedures (SOPs);
  • Workflows;
  • Automations;
  • AI-generated content;
  • AI prompts and prompt systems;
  • Designs;
  • Images;
  • Documents;
  • Checklists;
  • Market research;
  • Business processes;
  • Operational materials;
  • Software, code, configurations, or digital assets created within the Employee's duties, where applicable;
  • Other materials created specifically in connection with Company business.

To the extent permitted by applicable law, and subject to any formal requirements imposed by applicable copyright legislation, the Company shall be entitled to exercise or acquire the economic exploitation rights associated with eligible work product created within the scope of employment, including, where legally applicable, the rights of adaptation, reproduction, distribution, performance, and communication to the public.

The Company may, subject to applicable law, edit, publish, distribute, advertise, promote, reproduce, adapt, modify, translate, localize, commercialize, and otherwise use Company-owned work product for legitimate Company purposes.

Where applicable law requires a separate written assignment, authorization, specification of rights, or other document in order to validly transfer or exercise particular economic rights, the Employee agrees to reasonably cooperate in executing the necessary documentation.

Nothing in this Agreement shall be interpreted as requiring the Employee to waive any moral right, authorship right, or other right that cannot legally be waived or transferred under applicable law.

Materials demonstrably created by the Employee before employment and not created for the Company shall remain the Employee's property unless such materials are separately assigned or licensed to the Company in writing.

If the Employee incorporates pre-existing Employee-owned material into Company work with the Company's knowledge and authorization, the Employee grants the Company, to the extent necessary for the intended Company use, a license to use that incorporated material, subject to any separate written agreement between the parties.

SECTION 17

Content Creation & Media Rights

The Employee acknowledges that their role may involve participation in videos, photographs, interviews, social media content, marketing materials, audio recordings, promotional materials, presentations, educational content, sales-related content, or other Company media.

Company-produced content and recordings created within the scope of the Employee's authorized duties shall be treated as Company work product subject to Clause 16 and applicable law.

Subject to applicable law and the applicable legal basis for processing personal data, the Company may use authorized recordings and materials containing the Employee's professional image, voice, likeness, appearance, statements, presentations, interviews, or other participation for legitimate Company purposes, including:

  • Social media platforms;
  • Company websites;
  • Advertisements;
  • Marketing campaigns;
  • Corporate materials;
  • Presentations;
  • Recruitment or employer-branding materials where appropriate;
  • Training materials;
  • Internal and external Company communications.

The Company shall process the Employee's personal data contained in such materials in accordance with applicable personal-data-protection requirements.

Where applicable law requires explicit consent for a particular use of the Employee's image, voice, likeness, or other personal data, such consent shall be obtained separately and shall not be deemed automatically granted solely by execution of this Agreement.

The Employee shall receive any legally required privacy notice regarding the processing of their personal data, including the purposes of processing, applicable legal basis, recipients or categories of recipients, and relevant rights under applicable data-protection law.

Following termination of employment, the Company may continue using lawfully created and published Company materials containing the Employee's participation where a valid legal basis continues to exist and such continued use is permitted by applicable law.

Nothing in this clause shall authorize misleading use of the Employee's image, voice, or statements in a manner that falsely suggests that the Employee continues to hold a position with the Company after termination.

SECTION 18

Social Media & Brand Representation

The Employee agrees to represent the Company professionally when acting on behalf of the Company or when reasonably identifiable as speaking in an official Company capacity.

The Employee shall:

  • Follow applicable Company branding and communication policies;
  • Avoid making unauthorized public statements on behalf of the Company;
  • Avoid disclosing confidential or proprietary Company information;
  • Avoid publishing client, developer, partner, employee, financial, legal, or operational information without authorization;
  • Avoid intentionally making false statements while representing the Company;
  • Avoid using the Company's branding, logo, name, materials, accounts, or intellectual property for unauthorized personal or commercial purposes;
  • Protect account credentials and comply with Company cybersecurity requirements;
  • Obtain required approval before publishing official Company communications where Company approval procedures apply.

Nothing in this clause is intended to restrict lawful employee rights or legally protected communications under applicable law.

The Employee shall not create the impression that personal opinions or statements are official Company positions unless authorized to speak on behalf of the Company.

Company social media accounts, login credentials, audiences, business contacts, content libraries, analytics, advertising accounts, and related digital assets created or maintained for Company business shall remain under the Company's control.

Upon resignation, termination, or reassignment, the Employee shall promptly transfer control of Company social media accounts and related digital assets to the Company and shall cease unauthorized access.

SECTION 19

Conflict of Interest

The Employee shall act in the legitimate interests of the Company while performing their employment duties and shall promptly disclose any actual or material potential conflict of interest relating to their responsibilities.

Without prior written authorization from Management, the Employee shall not:

  • Divert Company clients, leads, opportunities, developers, partners, or suppliers for personal benefit or the benefit of another person or business;
  • Receive undisclosed commissions, referral fees, kickbacks, payments, gifts of material value, or other benefits arising from Company transactions;
  • Conduct personal transactions with Company clients or leads outside approved Company channels;
  • Use Company information, relationships, systems, resources, or opportunities for unauthorized personal benefit;
  • Represent a competitor or conflicting business in connection with matters that materially conflict with the Employee's Company duties;
  • Direct Company opportunities to relatives, associates, external brokers, agents, developers, consultants, or businesses without authorization where doing so creates a conflict of interest;
  • Participate in decision-making on behalf of the Company where the Employee has an undisclosed personal financial interest;
  • Use confidential information obtained through employment to compete unfairly with the Company.

The Employee shall not speak on behalf of the Company, publish Company-related statements, share internal matters, or disclose client, developer, financial, legal, commercial, or operational information publicly without written authorization, except where disclosure is legally protected or required by applicable law.

If the Employee becomes aware of an actual or potential conflict of interest, the Employee shall disclose it promptly to Management or HR.

A disclosed outside activity shall not automatically constitute a prohibited conflict where it does not materially interfere with the Employee's duties, misuse Company information or resources, compete unlawfully with the Company, or otherwise violate this Agreement or applicable law.

Any breach of this clause may result in appropriate disciplinary action and, where the applicable legal requirements are satisfied, termination of employment and/or other legal remedies available to the Company.

The obligations contained in this clause shall be interpreted and enforced in accordance with applicable Turkish law.

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