Privacy Policy

Last updated: March 2025

In short
You control your data on TOPHEADS. We collect what we need to run the private market (your card, your account, billing). We don't sell your data. We don't publish your identity. We show firms only what you've approved them to see — and we delete what you ask us to delete. Full details below.

1. Data Controller

The data controller for the purposes of applicable data protection legislation is Torchinsky Executive Consulting, Dubai, UAE ("Company," "we," "us"). We are committed to protecting the privacy and security of your personal data in compliance with applicable data protection laws, including the EU General Data Protection Regulation (GDPR) where applicable, and UAE Federal Decree-Law No. 45 of 2021 (Personal Data Protection Law).

2. What We Collect

We collect the following categories of personal data:

  • Identity data: name, email address
  • Professional data: CV/resume content, employment history, skills, qualifications, compensation information, industry, and region preferences
  • LinkedIn data: LinkedIn profile URL (for verification purposes)
  • Payment data: billing information processed through Stripe; cryptocurrency wallet addresses for crypto payments
  • Usage data: page views, feature interactions, login timestamps, device and browser information
  • Communication data: messages sent through TOPHEADS, introduction requests

3. How We Use Your Data

We process your personal data for the following purposes:

  • Creating and maintaining your anonymized member or company profile
  • AI-assisted CV parsing and profile generation
  • Matching members with relevant company opportunities
  • Personal verification and curation by the Founder, Mike Torchinsky
  • Processing payments and managing subscriptions
  • Publishing anonymized profiles to LinkedIn (with consent)
  • TOPHEADS analytics and service improvement
  • Communicating with you about your account and the service

4. AI Processing

We use AI technology (Anthropic Claude API) to parse uploaded CVs and generate structured profile data. When you upload a CV:

  • Your CV content is sent to the AI provider for processing
  • The AI extracts structured information (roles, skills, experience, etc.)
  • The AI provider does not store your data after processing
  • You have the opportunity to review and edit all AI-generated content before publication

5. What Companies See

Companies accessing TOPHEADS see only your anonymized profile. Specifically, companies cannot see:

  • Your real name
  • Your photograph
  • Your contact details (email, phone, address)
  • Your employer names (if you choose to hide them — displayed as industry/role descriptors instead)
  • Your uploaded CV document
  • Your communications with Torchinsky Executive Consulting

Your identifying information is disclosed to a company only when you explicitly accept an introduction request. You review each request individually and decide whether to reveal your contact details. Declining a request does not disclose any information to the requesting company.

6. Personal Review and Verification

Every member profile undergoes personal review by Mike Torchinsky, Founder of Torchinsky Executive Consulting. During this process:

  • What Mike Torchinsky sees: your full name, uploaded CV, complete employment history, and all profile data you have provided — for the sole purpose of quality verification and endorsement
  • What he does NOT do: share your identity with companies, use your data for any purpose other than profile review, or contact your current employer
  • Endorsement process: for Select tier members, Mike Torchinsky writes a personal recommendation based on your verified qualifications. This endorsement appears on your anonymized profile without revealing your identity
  • Communication: any messages exchanged during the review process are stored securely and treated as strictly confidential correspondence between you and Torchinsky Executive Consulting

This personal review process is what distinguishes TOPHEADS from automated job boards. Your trust is the foundation of this service, and we treat it with the highest standard of professional confidentiality.

7. Data Sharing

We do not sell your personal data. We share data only with the following parties:

  • Verified companies: anonymized profile data only, as described above
  • Stripe: payment processing (Stripe's privacy policy applies)
  • Anthropic: CV data for AI parsing (processed, not stored)
  • Supabase: infrastructure and database hosting

We may also disclose your data if required by law, regulation, or court order.

8. Data Retention

  • Active accounts: data is retained for the duration of your account
  • Cancelled accounts: your profile is hidden from companies; data is retained for 12 months, then permanently deleted
  • Upon request: data is deleted within 30 days of a verified deletion request
  • Payment records: retained for 7 years as required by applicable financial regulations

9. Your Rights

Under GDPR and UAE Federal Decree-Law No. 45 of 2021, you have the right to:

  • Know what we hold about you.
  • Correct anything that's wrong.
  • Delete your data and your card.
  • Export your data in a common format.
  • Restrict how we process your data.
  • Object to specific processing.
  • Withdraw consent at any time, for anything you previously consented to.

To exercise any of these, email mike@topheads.pro. We respond within 30 days, usually sooner.

10. Cookies

Our use of cookies is described in detail in our separate Cookie Policy. Essential cookies are used for authentication and session management. Analytics cookies are used only with your consent where required by law.

11. Security

We implement appropriate technical and organizational measures to protect your personal data, including:

  • Encryption of data in transit (TLS) and at rest
  • Supabase infrastructure with enterprise-grade security
  • Role-based access controls
  • Row-level security policies on all database tables
  • Regular security reviews

12. International Transfers

Your data may be processed in the United States (Supabase and Stripe servers) and other jurisdictions. Where data is transferred outside the EEA, we ensure appropriate safeguards are in place, including EU Standard Contractual Clauses where applicable.

13. Children

TOPHEADS is not intended for use by anyone under the age of 18. We do not knowingly collect personal data from individuals under 18. If we become aware that we have collected data from a minor, we will take steps to delete it promptly.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email to registered users. The "last updated" date at the top of this page indicates when the policy was last revised.

15. Contact

For privacy-related inquiries:

Privacy Officer
Torchinsky Executive Consulting
Dubai, UAE
Email: mike@topheads.pro

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