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AI Transparency

TopLeader s.r.o.
Effective date: 24 July 2026

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This AI Transparency Notice explains how TopLeader s.r.o. (“TopLeader”, “we”, “us” or “our”) uses artificial-intelligence-assisted functionality within the TopLeader platform.

It should be read together with our Privacy Policy, Terms & Conditions and, where applicable, the Data Processing Agreement agreed with the customer sponsoring a program.

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1. Scope of this Notice

This Notice applies to artificial-intelligence-assisted functionality provided as part of the TopLeader leadership development platform and related programs.

At present, TopLeader uses artificial intelligence for selected recommendation features. These features may suggest relevant:

  • development goals;

  • articles;

  • videos; and

  • other development resources made available within a participant’s program.

Recommendations are intended to help participants navigate relevant development options and maintain continuity between program activities.

TopLeader may update or expand its AI-assisted functionality over time. Where a material change affects the purposes for which personal data is processed or the role AI plays in a program, we will update this Notice and other relevant documentation.

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2. AI technology provider

TopLeader currently uses the OpenAI API to support selected AI-assisted recommendation features.

The specific models and technical configurations used may change over time as models are updated, replaced or selected for different tasks. TopLeader remains responsible for determining:

  • the purpose of the feature;

  • the information provided as context;

  • how the resulting recommendation is presented;

  • the access permissions applied within TopLeader; and

  • the safeguards surrounding its use.

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OpenAI processes API data as a service provider under its applicable contractual and data-protection terms.

Data submitted through the OpenAI API is not used to train or improve OpenAI models by default unless the API customer expressly opts in to data sharing.

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3. Information used to generate recommendations

Depending on the feature and the configuration of the relevant customer program, the information processed may include:

  • a prompt describing the requested recommendation;

  • the participant’s selected development goal or development area;

  • relevant program context;

  • the language of the participant or program;

  • the stage or focus of the applicable development journey;

  • metadata relating to available articles, videos or other resources; and

  • limited account or profile information where reasonably necessary to provide the feature.

TopLeader applies data-minimisation principles and aims to provide the AI service only with the information reasonably necessary for the requested recommendation.

We do not intentionally transmit the substantive content of private coaching or mentoring sessions, private expert notes or unrelated private communications unless:

  • a specific feature expressly requires that processing;

  • the customer has instructed TopLeader to provide that feature;

  • the processing has an appropriate legal basis; and

  • the affected users have been appropriately informed.

Google Calendar content unrelated to TopLeader sessions is not used for AI-assisted recommendations.

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4. What AI-assisted features do

AI-assisted features may analyse the available program context and generate suggestions that could be relevant to the participant’s stated development focus.

For example, an AI-assisted feature may:

  • propose wording for a development goal;

  • suggest an article or video related to a development priority;

  • offer possible areas for further reflection; or

  • help connect a current program focus with an available development resource.

Recommendations are generated based on the information made available to the feature. They do not represent a complete assessment of the participant, their performance, their organisation or their professional situation.

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5. What AI-assisted features do not do

TopLeader’s AI-assisted features are not designed to:

  • make recruitment or candidate-selection decisions;

  • decide whether a person should be promoted, dismissed or reassigned;

  • determine compensation or employment conditions;

  • produce an autonomous employee-performance rating;

  • make disciplinary decisions;

  • diagnose a medical or psychological condition;

  • replace a qualified coach, mentor, trainer, facilitator or other professional;

  • guarantee a particular development, behavioural or business result; or

  • make decisions that produce legal or similarly significant effects for an individual.

TopLeader does not use AI to autonomously determine whether an individual is suitable for employment, promotion, dismissal, compensation or access to a professional opportunity.

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6. Human oversight

AI-generated recommendations are intended to support human reflection and decision-making, not replace them.

A participant, expert, customer administrator or other authorised user should:

  • review the recommendation in context;

  • consider whether it is relevant and appropriate;

  • disregard it where it does not fit the situation;

  • verify any factual or professional information before relying on it; and

  • apply appropriate human judgement.

Customers and users must not use an AI-generated recommendation, engagement indicator, assessment result or other TopLeader output as the sole basis for a significant employment decision.

Decisions concerning recruitment, promotion, dismissal, compensation, performance evaluation or access to employment must involve appropriate human review and comply with applicable employment and data-protection requirements.

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7. Accuracy and limitations

AI models generate outputs probabilistically. A recommendation may therefore be:

  • incomplete;

  • inaccurate;

  • outdated;

  • overly general;

  • unsuitable for a particular organisational or cultural context;

  • based on an incorrect interpretation of the available information; or

  • affected by limitations or biases present in the underlying model or context.

TopLeader does not represent that an AI-generated recommendation is always correct, complete or suitable for a particular purpose.

Users remain responsible for evaluating recommendations before acting on them.

AI-generated content does not constitute medical, psychological, legal, tax, financial or other regulated professional advice.

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8. Personal data and confidentiality

The processing of personal data in connection with AI-assisted functionality is governed by the TopLeader Privacy Policy and, for Customer Program Data, the applicable Data Processing Agreement.

Where TopLeader processes program data on behalf of a customer:

  • the customer generally acts as data controller;

  • TopLeader generally acts as data processor;

  • AI processing is carried out only as necessary to provide the agreed functionality and in accordance with the customer’s documented instructions.

The use of an AI-assisted feature does not by itself make private participant content visible to customer administrators or program sponsors.

Visibility continues to depend on:

  • the customer’s program configuration;

  • the user’s role and permissions;

  • whether the participant deliberately shares particular information; and

  • the confidentiality boundaries described in the Privacy Policy and applicable program documentation.

Private reflections, coaching or mentoring notes, session content and private communications are not included in sponsor reporting merely because an AI-assisted feature is used.

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9. Data retention by the AI provider

By default, OpenAI may retain API prompts, outputs and associated abuse-monitoring information for up to 30 days, unless:

  • a different approved retention control applies;

  • a particular API feature requires application-state storage;

  • longer retention is required by law; or

  • retention is reasonably necessary to protect the service or third parties from serious harm.

Eligible API customers may apply for modified abuse monitoring or zero-data-retention controls for supported functionality.

TopLeader retains recommendations and related program records according to the retention periods described in its Privacy Policy and applicable customer agreement.

TopLeader does not use Customer Program Data to create a publicly available AI model or a model made available to unrelated customers.

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10. International data transfers

The use of an external AI provider may involve the processing of personal data outside the European Economic Area.

Where required, TopLeader uses an appropriate transfer mechanism and contractual safeguards, such as:

  • an adequacy decision;

  • the European Commission’s Standard Contractual Clauses;

  • the UK International Data Transfer Addendum, where applicable; or

  • another mechanism permitted by applicable data-protection law.

Further information is available in the Privacy Policy and Data Processing Agreement.

OpenAI’s applicable Data Processing Addendum incorporates transfer safeguards including the European Commission’s Standard Contractual Clauses.

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11. Security safeguards

TopLeader applies technical and organisational measures designed to protect information processed through AI-assisted functionality.

Depending on the relevant feature and risk, these measures may include:

  • restricting the information included in prompts;

  • role-based access controls;

  • least-privilege access;

  • encryption in transit and at rest;

  • logging and monitoring;

  • controlled access to production systems;

  • confidentiality commitments;

  • incident-response procedures; and

  • review of providers and contractual safeguards.

No AI system or online service can be guaranteed to be completely secure or error-free.

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12. Responsible use

Users should not enter the following into AI-enabled fields unless the processing has been expressly authorised and appropriate safeguards are in place:

  • unnecessary confidential business information;

  • health information;

  • biometric data;

  • political or religious beliefs;

  • trade-union membership;

  • information about a person’s sex life or sexual orientation;

  • other special-category personal data;

  • information about third parties that the user is not authorised to provide;

  • passwords, access credentials or security secrets; or

  • information whose disclosure would breach a contractual or professional duty.

Users should provide only the information reasonably necessary for the requested recommendation.

Suspected inappropriate, harmful or inaccurate AI behaviour may be reported to info@topleader.io.

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13. Customer responsibilities

Customers using TopLeader within a leadership or talent development program are responsible for:

  • determining an appropriate purpose and legal basis for the program;

  • informing participants about relevant AI-assisted functionality;

  • configuring access permissions appropriately;

  • deciding which categories of information may be processed;

  • ensuring that users do not submit data they are not authorised to provide;

  • maintaining appropriate human oversight;

  • avoiding the use of TopLeader outputs as the sole basis for significant employment decisions; and

  • complying with applicable employment, data-protection and artificial-intelligence requirements.

Where a customer requests a materially different AI use case, additional review, documentation and contractual safeguards may be required before the feature is enabled.

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14. Changes to this Notice

We may update this Notice to reflect changes in:

  • AI-assisted functionality;

  • model or technology providers;

  • data flows or retention settings;

  • security safeguards;

  • applicable law; or

  • the purposes for which AI is used.

The current version will be published on our website with a revised effective date.

Where a change materially affects the processing of personal data or the role of AI in a customer program, we will provide additional notice where required.

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15. Contact

Questions about TopLeader’s use of artificial intelligence, data processing or safeguards may be sent to:

TopLeader s.r.o.
Kolodějská 82
250 84 Sibřina
Czech Republic

Company ID: 19930003
VAT ID: CZ19930003
Email: info@topleader.io

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