Privacy Policy

Effective Date: May 28, 2025
Last Updated: July 2, 2026

1. Introduction

This Privacy Policy explains how we collect, use, disclose, and protect personal data when you interact with Top10HRVoices.com, its geographic editions, and any associated subsites (for example, cyprus.top10hrvoices.com, greece.top10hrvoices.com, germany.top10hrvoices.com) — whether by browsing, submitting editorial content, nominating others, participating in awards or events, appearing as a guest on our podcast, or engaging with our commercial offerings.

We handle your data lawfully, fairly, and transparently in accordance with the EU General Data Protection Regulation (GDPR) and applicable Cyprus law.

2. Controller & Contact

For the purposes of data protection law, V.I. Top 10 Voices Ltd, a company incorporated in Cyprus with its place of business in Limassol, is the sole Data Controller for the processing conducted via this Site and, more broadly, the Top10HRVoices vertical within the Top10Voices ecosystem.

We have not appointed a statutory Data Protection Officer. The contacts below are our monitored data protection contact addresses:
📧 [email protected] (General & Legal)
📧 [email protected] (Privacy Queries)
📧 [email protected] (Formal GDPR Requests)
📍 Limassol, Cyprus

3. Categories of Data We Collect

a. Contributor & Nomination Data
Name, contact details, role/title, organization, headshot/photography, quotes, bios, submitted articles, references/sources, nomination details, and related correspondence.

b. Communications
Email content, attachments, and replies sent to our addresses (e.g., editor@ / privacy@ / legal@).

c. Site & Technical Data
Basic server logs, device/browser metadata, and aggregated usage metrics. We currently operate an essential-only setup and do not use analytics, advertising, or cross-site tracking cookies. Strictly necessary storage is described in our Cookies Policy. If we introduce non-essential cookies or trackers in future, they will be loaded only after your explicit opt-in through a compliant consent mechanism.

d. Commercial & Sponsorship Data
Contact and business details from prospective sponsors/partners, briefings, and negotiation records necessary to evaluate and administer potential agreements.

e. Awards & Jury Data
Eligibility and selection notes, conflict-of-interest declarations, jury communications, and operational logistics necessary to run an awards program.

f. Podcast Guest Data
Name, contact details, role/title, organization, headshot/photography, biographical information, and the audio/video recording, transcript, and likeness captured during a NO BRIEF podcast appearance, together with any related correspondence and the Guest Appearance & Release coordinating that appearance.

g. Verification (MeritChecked) Data
The evidence considered, reviewer notes, conflict-of-interest declarations, decision outcome, dates, and related records generated when a submission, engagement, or programme is reviewed under the MeritChecked process — including records relating to submissions that are objected to or declined.

Data received from third parties: Where information about you reaches us through a nomination or referral made by another person rather than directly from you, we process it as described here and provide the information required under Article 14 GDPR where applicable.

4. Purposes of Processing

We process personal data to:

• Evaluate, edit, publish, and archive editorial features.
• Manage nominations, eligibility, jury operations, and awards administration.
• Operate the MeritChecked verification process and maintain its decision record.
• Produce, edit, publish, and archive podcast episodes and related promotional materials.
• Plan and run events (Forum, Gala, and related gatherings), including recording and photography.
• Communicate with contributors, nominators, sponsors/partners, podcast guests, and readers.
• Operate and secure the Site (including consent/preference records and security logs).
• Enforce our Terms & Conditions, including IP protection and takedown actions.
• Comply with legal obligations and respond to data subject requests.

On this Site we do not conduct advertising-based profiling or automated decision-making that produces legal or similarly significant effects. Regulated ecosystem products that may involve such processing — in particular the ProofYourMerit verification platform and the Employer Hire-Verification service — operate under their own separate notices, agreements, and safeguards, and are not governed by this website Policy (see Section 17).

5. Lawful Bases for Processing (GDPR Art. 6)

• Consent
for newsletter opt-ins, non-essential cookies (if introduced), and specific optional uses clearly presented to you (for example, certain uses of your image in unrelated future marketing). Where processing rests on consent, you may withdraw it at any time without affecting prior lawful processing.
• Contract / Pre-contractual Steps
to perform the Guest Appearance & Release for podcast recording, publication, and archival; to evaluate and negotiate commercial collaborations prior to a signed agreement; and to administer any signed terms thereafter.
• Legitimate Interests
to operate a curated editorial platform, maintain a permanent professional archive, publish and archive editorial and podcast content, protect IP, administer awards and jury integrity, respond to inbound sponsorship/partnership enquiries, and to operate and retain the MeritChecked decision record (including records of declined submissions) for the integrity and auditability of our verification standard and the establishment, exercise, or defence of legal claims. We conduct and document legitimate interest assessments (LIA) where appropriate.
• Legal Obligations
to comply with applicable laws, court orders, and regulatory requirements.

6. Editorial Archive & Freedom of Expression

Published contributions, including published podcast episodes, form part of a permanent editorial record. In line with our Terms & Conditions, we may preserve, reformat, update, or enhance published work without altering its core message or intent. Requests for factual corrections will be reviewed; however, full removal of published content is generally not provided in order to protect the integrity and continuity of the archive and our freedom of expression obligations.

7. Data Sharing & Processors

We share data only as necessary with: (i) internal editors/maintainers and named editorial board reviewers; (ii) vetted service providers under GDPR-compliant data processing agreements — currently our website hosting provider (Carrd) and email provider (Zoho Mail); (iii) Google LLC, which delivers the web font used across the Site (see Section 8 and our Cookies Policy); (iv) legal counsel, regulators, or authorities where required by law. As the NO BRIEF podcast launches, podcast hosting and distribution platforms, and embedded media players, may also process related data, and this Policy and our Cookies Policy will reflect those providers. We do not sell or rent personal data.

8. International Transfers & Web Fonts

We endeavor to store and process data within the EEA. Where transfers outside the EEA occur (e.g., certain processors or sub-processors), we rely on appropriate safeguards such as adequacy decisions or the EU Commission’s Standard Contractual Clauses.

For presentation purposes, the Site loads the “Space Grotesk” web font from Google Fonts (Google LLC). Loading this font necessarily transmits your IP address to Google, including to servers in the United States, so that the font can be delivered to your browser. This is used solely to render the Site’s typography and not for analytics, advertising, or tracking, and is relied upon on the basis of our legitimate interest in consistent presentation, with transfers covered by Google’s Standard Contractual Clauses.

9. Retention

Editorial Archive: Published materials and related correspondence, including published podcast episodes, may be retained indefinitely to preserve a reliable professional record.
Verification (MeritChecked) Records: Decision records — including records relating to declined submissions — are retained on the basis of our legitimate interest in the integrity and auditability of the verification standard and in establishing, exercising, or defending legal claims. Where the fact of a decision is referenced publicly, it is presented by category or pattern only and never in a way that identifies a declined individual or organisation.
Operational Records: Routine communications, consent/preference logs, and administrative files are kept only as long as necessary for the purposes stated above and applicable statutory limits.
Commercial Records: Sponsorship/partnership enquiries and agreements are retained for the life of the engagement and for a reasonable period thereafter for accountability.

10. Your Rights

Subject to GDPR and applicable exemptions, you may request: access, rectification, restriction, portability, or objection to certain processing. If processing is based on consent, you may withdraw consent at any time (without affecting prior lawful processing).

Editorial & Archive Limitation: Due to our obligations to preserve a trustworthy editorial archive and freedom of expression, and to maintain the integrity of the verification record, full deletion of published content or of verification decision records is not generally available; we consider such requests, and factual correction requests, fairly and in good faith, and balance them against these interests.

You also have the right to lodge a complaint with the Cyprus Data Protection Commissioner, or, if you are habitually resident in another EEA country, with your local supervisory authority.

11. Security

We employ reasonable technical and organizational controls, including SSL-secured email, role-based access, least-privilege principles, password-protected admin, infrastructure malware scanning, and periodic reviews of processor security. If a data incident poses a risk to your rights and freedoms, we will take appropriate steps consistent with GDPR.

12. Cookies & Consent

We currently operate an essential-only setup: no analytics, advertising, or cross-site tracking cookies. Strictly necessary storage (such as a session flag remembering that you dismissed our banner) operates for core functionality. The Site also loads a web font from Google Fonts, as described in Section 8. Full detail is in our Cookies Policy. If we introduce non-essential cookies in future, they will be disabled by default and require your explicit opt-in, which you can change or withdraw at any time.

13. Awards, Conflicts & Jury Integrity

We process personal data to administer eligibility, protect impartiality, and manage conflicts of interest. Contributors invited to serve on a jury/panel are ineligible for nomination or recognition in that same award cycle.

14. AI-Assisted Submissions & Use of Your Data

Contributors must disclose any material use of AI tools in preparing submissions. Regardless of AI usage, the contributor remains responsible for originality, permissions, accuracy, and compliance with our editorial standards. We do not use your personal data or submissions to train third-party artificial-intelligence systems, and, as set out in our Terms, we prohibit the scraping or harvesting of Site content for that purpose.

15. Podcast Appearances

Participation in the NO BRIEF podcast is governed by a separate Guest Appearance & Release Agreement, which each guest agrees to before recording. The lawful basis for recording, editing, publishing, and archiving a guest’s appearance, likeness, voice, and statements is the performance of that Release (contract) together with our legitimate interest in producing and maintaining the editorial and podcast archive — not consent alone. Consent is sought separately only for peripheral uses that genuinely require it, and withdrawing such consent does not affect the contractual licence or the recordings already made. Guests receive the information required under Article 13 GDPR through the Release and this Policy, and should also read our Cookies Policy and Terms & Conditions.

16. Legal Requests & Enforcement

We may process and share personal data as reasonably necessary to investigate, prevent, or respond to suspected violations of our Terms, alleged infringements, or legal/regulatory requests — including issuing or responding to takedown notices (e.g., DMCA) and GDPR Article 17/21 requests.

17. Commercial & Regulated Services (Separate Agreements)

Some ecosystem services process personal data under their own contracts rather than under this website Policy. In particular, the Employer Hire-Verification service, the ProofYourMerit verification platform, licensed expert courses and webinars, the MeritChecked Membership and Directory, awards and jury-as-a-service engagements, geo-franchise licensing, moderation-training and pressure-test workshops, board and executive referral introductions, vetted speaker placement, benchmark reports, and client consulting or licensing engagements are governed by separate service agreements and, where we process data on behalf of a client, by a separate Data Processing Agreement that establishes the applicable controller and processor roles under the GDPR. This website Policy does not govern the provision of those services.

18. Changes to this Policy

We may update this Privacy Policy at any time. The “Last Updated” date reflects the most recent revision. Material changes that affect consent or contributor rights will be communicated through appropriate channels.
Continued use of the Site constitutes legal binding & acceptance of the updated policy.

19. Contact

For privacy questions or GDPR requests:
📧 [email protected] (Privacy Queries)
📧 [email protected] (Formal GDPR Requests)
📧 [email protected] (Editorial & Legal Contact)
📍 Limassol, Cyprus

This Privacy Policy should be read together with our Cookies Policy and Terms & Conditions;
together they constitute the entire understanding regarding the Site’s operation, your interaction with it, and supersede any prior communications or representations relating to the Site.