Privacy Policy

The Vocal Excellence School, the Summer Programme, the Vocal Excellence Choir and the Masterclass Series · Effective 7 October 2026 · Version 3.7

1. Introduction

This Privacy Policy explains how Vocal Excellence collects, uses, stores, shares, protects, and retains personal data when you visit our website, apply to the Vocal Excellence Summer Programme, participate in the Programme, contact us, purchase services, attend events, appear in recordings, or otherwise interact with us.

In this Policy, Vocal Excellence, we, us, and our refer to the organiser and data controller of the Vocal Excellence Summer Programme.

This Policy applies to:

  • Website visitors
  • Applicants
  • Participants
  • Parents and legal guardians
  • Nominated responsible adults
  • Emergency contacts
  • Faculty
  • Staff
  • Contractors
  • Volunteers
  • Chaperones
  • Photographers and videographers
  • Event guests and visitors
  • Any person whose personal data is processed in connection with Vocal Excellence

We process personal data in accordance with applicable data protection law, including the General Data Protection Regulation (EU) 2016/679, known as the GDPR, and the applicable data protection laws of the Republic of Cyprus, including Law 125(I)/2018.

Nothing in this Policy is intended to reduce any mandatory privacy rights that apply by law. At the same time, Vocal Excellence reserves all lawful rights, defences, exemptions, limitations, and protections available to it, its Owner/Founder, staff, faculty, contractors, insurers, and legal representatives.

2. Data Controller Information

The data controller is:

Vocal Excellence

Legal name: Vocal Excellence

Business or registered address: Ναυπλίου 12, Χριστοδουλίδης Κόρτ, Κατάστημα 1, Limassol, 3025

Email: info@vocalexcellence.cy

General contact: info@vocalexcellence.cy

Telephone: +357 25 775 885

Privacy Contact

The privacy contact for Vocal Excellence is:

Andreas Aroditis

Owner/Founder and Programme Director

Email: info@vocalexcellence.cy

Telephone: +357 25 775 885

Unless Vocal Excellence separately states otherwise in writing, this privacy contact is not appointed as a statutory Data Protection Officer under GDPR Article 37. Vocal Excellence may appoint a Data Protection Officer if legally required or if it chooses to do so.

Where Vocal Excellence operates through a separate legal entity, that entity is the data controller. The Owner/Founder acts on behalf of the controller and is not personally the data controller unless required by law or unless no separate legal entity exists.

3. Key Definitions

For the purposes of this Policy:

Personal data
means information relating to an identified or identifiable living person.
Processing
means any use of personal data, including collection, storage, review, organisation, sharing, deletion, restriction, or retention.
Controller
means the person or organisation that decides why and how personal data is processed.
Processor
means a service provider that processes personal data on behalf of the controller.
Special category data
means more sensitive personal data, including health data, biometric data used for identification, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, sex life, and sexual orientation.
Consent
means a freely given, specific, informed, and unambiguous indication of agreement.
Explicit consent
means a clear and express form of consent used for certain higher-risk processing, including some processing of special category data.
Participant
means a person applying to or attending the Programme.
Guardian
means the parent or legal guardian of a Participant under 18.
Protected Parties
means Vocal Excellence, its Owner, Founder, Programme Director, directors, officers, staff, faculty, contractors, volunteers, agents, representatives, venue partners, insurers, and professional advisers, to the fullest extent permitted by law.

4. Personal Data We Collect

Vocal Excellence follows data minimisation principles and aims to collect only personal data that is relevant, proportionate, and reasonably necessary for the Programme, website, legal obligations, safety, safeguarding, administration, communication, and protection of our lawful interests.

Depending on your relationship with us, we may collect the following categories of personal data.

4.1 Identity and Contact Data

This may include:

  • Full name
  • Email address
  • Telephone number
  • Postal or billing address
  • Date of birth
  • Age
  • Nationality
  • Country of residence
  • Parent or guardian details
  • Emergency contact details
  • Nominated responsible adult details
  • Identification information where reasonably required for verification, safeguarding, payment, legal, visa-support, or administrative purposes

We do not normally require passport or national ID details unless they are reasonably necessary for a specific purpose.

4.2 Application and Audition Data

This may include:

  • Vocal type or range
  • Musical background
  • Educational background
  • Performance experience
  • CV, résumé, biography, or personal statement
  • Audio recordings
  • Video recordings
  • Audition materials
  • Repertoire lists
  • References or recommendations
  • Faculty assessment notes
  • Application outcome
  • Scholarship or discount information where applicable

4.3 Programme Administration Data

This may include:

  • Attendance records
  • Class groupings
  • Coaching allocations
  • Timetables
  • Session notes
  • Participant communications
  • Certificates or confirmations
  • Internal staff notes
  • Feedback
  • Programme-related correspondence
  • Incident reports where necessary

4.4 Parent, Guardian, and Emergency Contact Data

For Participants under 18, we may collect:

  • Parent or guardian name
  • Relationship to Participant
  • Contact details
  • Consent forms
  • Emergency contact details
  • Nominated responsible adult details
  • Written permissions
  • Safeguarding-related correspondence where necessary

By providing another person's contact details, you confirm that you have authority to provide those details and that the person can reasonably expect to be contacted in connection with the Programme.

Masterclass Series: if a singer aged 14 to 17 joins the waitlist themselves, we ask for a parent or guardian’s email address. We send the singer’s personal enrolment link to that parent or guardian, because a parent or guardian books for anyone under 18. We do not send the enrolment link to the singer’s own address.

4.5 Health, Medical, Dietary, Access, and Welfare Data

Where necessary for safety, safeguarding, catering, accessibility, emergency response, or reasonable support, we may collect:

  • Allergy information
  • Dietary requirements
  • Medication information
  • Relevant medical conditions
  • Vocal health information
  • Access requirements
  • Disability-related information
  • Learning support information
  • Welfare concerns
  • Emergency medical information
  • Information needed to protect a Participant's health, safety, or wellbeing

Some of this information may be special category data under GDPR. We process it only where we have an appropriate lawful basis and, where required, an additional special-category condition.

4.6 Payment and Financial Data

This may include:

  • Billing name
  • Billing address
  • Invoice details
  • Payment status
  • Transaction references
  • Deposit and tuition payment records
  • Refund records
  • Scholarship, discount, or instalment information

We do not intentionally store full payment card numbers. Card and payment processing is normally handled by third-party payment providers.

4.7 Website and Technical Data

When you use our website, we may collect:

  • IP address
  • Browser type and version
  • Device type
  • Operating system
  • Time zone or approximate location
  • Website pages visited
  • Date and time of visit
  • Referring website
  • Cookie identifiers
  • Form-submission metadata
  • Security logs
  • Error logs

Masterclass sign-ups. When you sign up for the masterclass waitlist, we check that the sign-up is real. We may email you a link to confirm your email address; for a singer aged 14 to 17 who signs up themselves, that email goes to the parent or guardian's address instead. Our system looks for signs that a name, age, email address or phone number was made up, and asks the internet's address book (DNS) whether the part of your email address after the “@” can receive mail; nothing else about you is sent for this. We also save the type of device and browser you used (for example, “iPhone · Safari”) and a coded form of your internet address (IP address). We do not store the address itself: the code only lets us see that two sign-ups came from the same connection. It is still information about you, so we protect it like the rest of your sign-up and never use it to work out the address. We use these details to spot fake sign-ups and our own test entries, and we delete the device type and the coded address automatically after 30 days. If the security check in section 14.1 cannot confirm that a person is using the form, we may ask you to try again, or hold the sign-up back for us to look at instead of adding it to the list straight away; we look at every sign-up we hold back, and if it seems to come from a real person we write to them. Our other checks only mark a sign-up for us to look at; they never decide on their own whether you get a place. When we send booking links, we may hold back, for that round, a sign-up whose details look made up or whose email address has not been confirmed. We look at each one before deciding. This is separate from our own step counter (section 12.5), which keeps nothing about you.

If you sign up through an invitation link that a music school or teacher gave you, we also record which school’s link you came through, so that we can honour our arrangement with them; this is kept with your sign-up and deleted with it.

4.8 Marketing and Communication Data

This may include:

  • Newsletter subscription status
  • Marketing preferences
  • Email open and click information, where enabled
  • Enquiry history
  • Responses to campaigns
  • Social media interactions
  • Consent records
  • Opt-out or unsubscribe records

4.9 Photography, Video, Audio, and Media Data

We may collect:

  • Photographs
  • Video recordings
  • Audio recordings
  • Mock audition recordings
  • Showcase recordings
  • Rehearsal footage
  • Interviews
  • Testimonials
  • Behind-the-scenes media
  • Group photos
  • Crowd or background footage

Photos, video, and audio recordings are personal data where an individual can be identified. They are not automatically special category data unless they reveal special category information or are processed for biometric identification. Vocal Excellence does not use participant images for biometric identification unless expressly stated and separately agreed.

4.10 Safeguarding and Incident Data

Where necessary, we may collect:

  • Safeguarding concerns
  • Welfare reports
  • Incident reports
  • Accident reports
  • Behavioural concerns
  • Missing-participant records
  • Allegations or complaints
  • Communications with parents, guardians, authorities, medical professionals, legal advisers, insurers, or safeguarding bodies

Safeguarding information is handled with particular care and shared only where necessary and lawful.

5. How We Collect Personal Data

We may collect personal data directly from you when you:

  • Visit the website
  • Complete an application form
  • Submit audition materials
  • Pay a fee
  • Sign a consent form
  • Contact us by email, phone, form, social media, or message
  • Attend the Programme
  • Participate in recordings, coaching, classes, or events
  • Request support, refunds, information, or access arrangements
  • Make a complaint or raise a concern

We may also receive personal data from:

  • Parents or guardians
  • Emergency contacts
  • Nominated responsible adults
  • Faculty or staff
  • Contractors
  • Venues
  • Payment providers
  • Referees or recommenders
  • Medical professionals, where relevant and lawful
  • Safeguarding authorities, emergency services, or public authorities, where relevant and lawful
  • Publicly available sources, such as professional profiles, websites, or social media, where relevant to application review, due diligence, safeguarding, legal protection, or legitimate business purposes

7. Special Category Data

We may process special category data where necessary for the Programme, safeguarding, accessibility, emergency response, legal protection, or participant welfare.

This may include health data, allergy information, medical information, disability-related information, access needs, or welfare information.

We process special category data only where an Article 9 GDPR condition applies, such as:

  • Explicit consent
  • Vital interests, where a person cannot give consent and urgent action is needed
  • Establishment, exercise, or defence of legal claims
  • Substantial public interest where applicable
  • Health or safety-related necessity where applicable under law

Vocal Excellence does not seek unnecessary special category data and asks Participants and Guardians to provide only information that is accurate, relevant, and necessary.

8. How We Use Personal Data

We may use personal data for the following purposes:

  • To operate the Vocal Excellence website
  • To respond to enquiries
  • To review applications
  • To assess suitability for the Programme
  • To issue Letters of Acceptance
  • To manage invoices, payments, instalments, and refunds
  • To communicate Programme information
  • To prepare schedules and classes
  • To allocate faculty and coaching sessions
  • To manage rehearsals, auditions, workshops, and performances
  • To provide educational recordings where applicable
  • To support catering and dietary arrangements
  • To protect health, safety, welfare, and safeguarding
  • To respond to medical emergencies
  • To manage complaints, incidents, disputes, and disciplinary matters
  • To comply with legal, tax, accounting, safeguarding, insurance, and regulatory obligations
  • To protect Vocal Excellence, the Owner/Founder, staff, faculty, contractors, and participants
  • To maintain business records
  • To improve the Programme and future services
  • To send marketing communications where permitted
  • To produce promotional materials where valid consent has been given
  • To enforce the Terms of Use & Participation Agreement
  • To defend or bring legal claims where necessary

9. Children and Participants Under 18

The Vocal Excellence School accepts Participants from the age of six, with no upper limit. The Summer Programme and the Vocal Excellence Choir accept Participants aged 11–21. The Masterclass Series accepts Participants aged 11 and over, with no upper limit. All four therefore admit both children and adults aged 18 and over, and the School admits children well below the age at which any of the others begins. All activities are subject to the Terms of Use & Participation Agreement, the Safeguarding Policy, and required parental or guardian consent where the Participant is a child.

Where a Participant is aged 18 or over, they are an adult: they give their own consent, exercise their own data protection rights, and we do not share their personal data with a parent or guardian without their agreement.

9.1 Parental or Guardian Consent

For Participants under 18, a parent or legal guardian must complete the required consent forms.

For Participants under 14, online application and consent processes must be completed by or authorised by a parent or legal guardian.

Cyprus Law 125(I)/2018 sets the child consent age at 14 for information society services offered directly to a child where processing is based on the child's consent.

9.2 Best Interests of the Child

Where we process personal data relating to a child, we take particular care to protect the child's privacy, safety, welfare, and dignity.

We may refuse, restrict, or remove content involving a minor where we consider this necessary to protect the minor, Vocal Excellence, other participants, or the lawful interests of the Programme.

9.3 Media Involving Minors

Promotional use of a minor's identifiable image, voice, name, likeness, testimonial, interview, or performance requires a separate Media Consent Form completed by a parent or legal guardian.

Refusing promotional media consent does not affect admission to the Programme.

Vocal Excellence may still process certain images or recordings for non-promotional purposes, such as educational delivery, safeguarding, legal records, insurance, quality assurance, internal archives, or where otherwise lawful.

9.4 Withdrawal of Media Consent for Minors

A parent or legal guardian may withdraw promotional media consent prospectively by emailing:

info@vocalexcellence.cy

Withdrawal does not affect lawful use before the withdrawal was received.

Vocal Excellence will make reasonable efforts to stop future promotional use, but may not be able to remove material already printed, lawfully published, archived for legal reasons, shared by third parties, distributed outside our control, or included incidentally in crowd or background footage.

10. Photography, Filming, Audio, and Performance Recordings

The Programme may include photography, filming, audio recording, mock audition recording, rehearsal recording, interview recording, testimonial recording, and final showcase recording.

10.1 Educational and Portfolio Recordings

Where recordings are part of the Programme, they may be used to provide educational feedback, portfolio material, internal review, quality assurance, and Programme delivery.

Participants are responsible for ensuring that any further use of recordings complies with copyright, music licensing, platform rules, and applicable law.

10.2 Promotional Use

Promotional use requires a separate Media Consent Form.

Promotional use may include use on:

  • Vocal Excellence website
  • Social media
  • Email marketing
  • Brochures
  • Posters
  • Digital advertisements
  • Press materials
  • Future Programme promotion
  • Student success features

10.3 Crowd and Background Footage

Even where a person has opted out of promotional media use, they may appear incidentally in crowd shots, audience images, group footage, or background footage where exclusion is impractical.

For minors, Vocal Excellence will take reasonable care to avoid unnecessary, unsafe, misleading, or inappropriate publication.

10.4 No Biometric Identification

Vocal Excellence does not use photographs, videos, or audio recordings for biometric identification unless this is expressly stated and separately agreed.

11. Marketing Communications

We may send marketing communications where we have consent or another lawful basis.

Marketing communications may include:

  • Future Programme announcements
  • Application reminders
  • Alumni updates
  • Vocal training news
  • Events
  • Offers
  • Scholarship information
  • Related educational opportunities

You can unsubscribe at any time by:

We may still send non-marketing communications where necessary, including application updates, payment reminders, Programme information, safety notices, legal notices, or administrative messages.

12. Cookies and Tracking Technologies

Our website may use cookies and similar technologies.

Cookies may be used for:

  • Website functionality
  • Security
  • Form operation
  • Load balancing
  • Analytics
  • User preferences
  • Marketing and advertising measurement

12.1 Strictly Necessary Cookies

Strictly necessary cookies are required for the website to work properly and may be used without consent.

The security check on our masterclass sign-up form (Cloudflare Turnstile, section 14.1) is strictly necessary in this sense: it starts only when you begin filling in that form, and we use it only to tell people from automated programs. Cloudflare says the information its check collects is strictly necessary for detecting and blocking automated programs, so the check runs whatever you answer in the cookie banner. The device type we save with a sign-up comes from what your browser sends with every visit, and we use it only for the checks in section 4.7.

12.2 Optional Cookies

Analytics, marketing, preference, and similar non-essential cookies will be used only where required consent has been obtained.

12.3 Cookie Settings

Where available, you may manage cookie preferences through the Cookie settings button in the website footer.

You may also control cookies through your browser settings.

12.4 Third-Party Tools

The optional outside tools on our website are Google Analytics, Google Ads and the Meta Pixel, loaded through Google Tag Manager. They set or read their cookies only if you allow them in the cookie banner (“Allow”, or the matching box under “Choose what you allow”). You can change your choice at any time through the Cookie settings button in the website footer.

Google Tag Manager, Google Analytics and Google Ads load on our pages whatever you answer (but never on a personal enrolment link or an email confirmation link). If you choose “Don’t allow”, or do not answer, they set no cookies and use no cookie ID, but they still send Google basic signals without one: for example that a page was viewed or a form was sent, the page address, the page you came from, the time and the type of browser. Google calls this consent mode. Like any connection, each signal also shows Google your internet address. The Meta Pixel does not load at all unless you allow Advertising. The website works the same whatever you choose.

If you allow Analytics, Google Analytics counts which pages you visit and how you use them, with a cookie ID. If you allow Advertising, Meta (Facebook, Instagram) and Google receive your visit: they see which ad brought you and whether you sign up (ad measurement), and they can show you our ads after you leave this site (personalised ads).

The cookies and other stored items involved, and how long they last:

  • “_ga” and “_ga_85Q3F9X5XW”: Google Analytics, only if you allow Analytics. A cookie ID that tells one visitor’s visits apart from another’s. Up to 2 years.
  • “_gcl_au”, and “_gcl_aw” if you came from a Google ad: Google Ads, only if you allow Advertising. They link a visit and a sign-up to the ad that brought you. 90 days. Google Ads also keeps “_gcl_ls” in your browser’s local storage until you clear it.
  • “_fbp”, and “_fbc” if you came from a Facebook or Instagram ad: Meta, only if you allow Advertising. The same, for Meta. 90 days. The Meta Pixel also keeps “lastExternalReferrer”, “lastExternalReferrerTime” and, after an ad, “multiFbc” in local storage until you clear it.
  • “ve_consent”: our website, in local storage, whatever you answer. Your answer in the cookie banner, so we do not ask on every page. 180 days, then we ask again.
  • “ve_lead_counted”: our website, in local storage, only if you allow Analytics or Advertising. Which of our forms already counted a sign-up from this browser, and when, so one sign-up is not counted twice. It holds no name, email or phone number. Each entry is ignored after 180 days.

The cookies above sit on our website’s own address. Google’s and Meta’s tags on our pages read them and send them to Google and Meta. Google and Meta may also use their own cookies on their own addresses, for example if you are signed in to Google, Facebook or Instagram; their own policies explain those.

Google explains what it does with information from websites like ours on its page How Google uses information from sites or apps that use our services.

Everything else the website needs to work, such as remembering your cookie choice, runs without consent. The outside services we use are named in section 14.1.

12.5 Our Own Sign-up Step Counter

On the masterclass sign-up page, and only if you allow analytics, your browser tells our own server which steps of the form were reached (for example, that the form was shown or that step one was sent), which fields needed correcting (the field's name, never what was typed), roughly how long the page was open, and whether the visit came from TikTok, Facebook, Instagram, Google, somewhere else or nowhere in particular. Our server only adds one to a total for that day. It keeps nothing about you: no internet address, no browser details, nothing you type and no cookie, and it sends nothing to anyone else.

Allowing analytics means choosing “Allow”, or ticking Analytics under “Choose what you allow”, in the cookie banner. If you choose “Don’t allow”, or do not answer, nothing is sent.

13. Sharing Personal Data

Vocal Excellence does not sell personal data.

We may share personal data where necessary, lawful, and proportionate.

Recipients may include:

  • Vocal Excellence staff
  • Faculty
  • Guest teachers
  • Accompanists
  • Contractors
  • Chaperones
  • Administrative support providers
  • Website hosting providers
  • Cloud storage providers
  • Email providers
  • Payment processors
  • Accounting providers
  • Legal advisers
  • Insurers
  • Venues
  • Caterers
  • Photographers
  • Videographers
  • IT support providers
  • Marketing service providers
  • Emergency contacts
  • Parents or guardians
  • Medical professionals
  • Emergency services
  • Cyprus Police, Social Welfare Services, safeguarding bodies, regulators, or public authorities where necessary or lawful
  • Courts, tribunals, mediators, arbitrators, or dispute-resolution bodies where necessary
  • Business successors, buyers, or restructuring advisers if Vocal Excellence is sold, transferred, reorganised, or incorporated into another legal entity

We share only the data reasonably necessary for the relevant purpose.

14. Processors and Service Providers

Where third-party processors process personal data on our behalf, we take reasonable steps to ensure they provide appropriate protection and process data only under our instructions.

Processors may include:

  • Website hosting providers
  • Cloud storage providers
  • Form providers
  • Email delivery providers
  • Payment processors
  • CRM or administration tools
  • Accounting tools
  • Analytics tools
  • Consent management tools
  • IT support providers
  • Video storage or file-sharing providers

Where required, Vocal Excellence will use appropriate data processing agreements.

14.1 The services we use

These are the outside services that handle personal data for us today:

  • Replit: Hosts our website and its database, in North America (the United States).
  • Stripe: Processes card payments. We never see or store your full card number.
  • Resend: Delivers the emails our website sends, such as confirmations, receipts and enrolment links.
  • Zoho Mail: Hosts our mailbox, info@vocalexcellence.cy.
  • Cloudflare: Manages our web address (domain name) and protects the system that sends lesson reminders to Vocal Excellence School families. Its Turnstile service may also run a quick security check on our masterclass sign-up form, to tell people from automated programs. The check starts only when you begin filling in the form. For it, Cloudflare receives technical details such as your internet address, details of your browser and device, and which website asked for the check.
  • seven.io: Delivers text-message lesson reminders to Vocal Excellence School families.
  • Google: Google Fonts supplies the typefaces on our pages, so your browser connects to Google when a page loads. Google Tag Manager, Google Analytics and Google Ads measure visits and the results of our adverts. They load on our pages whatever you answer in the cookie banner, but set cookies only if you allow them there; section 12.4 says what they send if you do not.
  • Meta: The Meta Pixel measures the results of our Facebook and Instagram adverts, and loads only if you allow Advertising in the cookie banner. If you choose to message us on WhatsApp, which Meta owns, WhatsApp carries that conversation.

Google and Meta also use advertising data under their own privacy policies. We will update this list when we start or stop using a service.

Cloudflare describes what its Turnstile security check collects, and how it uses it, in its Turnstile Privacy Addendum. Cloudflare runs the check for us. It says it also uses what the check collects to improve its check, and that for this it is responsible for that information itself (a “controller”), under its own privacy notice.

15. International Data Transfers

We aim to store and process personal data within the European Economic Area where reasonably practical.

However, some service providers may process personal data outside the EEA, including in the United Kingdom, the United States, or other countries.

In particular, our website and its database are hosted by Replit in North America (the United States), and Google and Meta may process data in the United States. The services we use are named in section 14.1.

Where personal data is transferred outside the EEA, we will use appropriate safeguards where required, such as:

  • European Commission adequacy decisions
  • Standard Contractual Clauses
  • Transfer risk assessments where appropriate
  • Supplementary technical or organisational measures where appropriate
  • Other lawful transfer mechanisms available under GDPR

If a service provider is located in a country that does not provide an adequate level of protection, we will take reasonable steps required by law to protect the data.

16. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including Programme administration, legal compliance, safeguarding, tax, accounting, insurance, dispute resolution, record keeping, and protection of Vocal Excellence's lawful interests.

The retention periods below are general guidelines. We may retain data for a longer period where necessary for legal claims, safeguarding, insurance, regulatory requests, fraud prevention, accounting, tax, dispute handling, or where otherwise permitted by law.

Data CategoryTypical Retention Period
Enquiry recordsUp to 2 years after last contact
Unsuccessful applicationsUp to 2 years after decision
Successful applicant and participant recordsUp to 7 years after Programme completion
Financial, invoice, payment, and tax recordsUp to 7 years or longer if legally required
Consent formsUp to 7 years after Programme completion or longer where needed
Medical, dietary, access, and welfare informationUp to 7 years where necessary, or shorter where no longer needed
Safeguarding and serious incident recordsAs long as necessary for safeguarding, legal, insurance, and child-protection purposes
Educational recordingsUp to 5 years unless a longer period is justified or agreed
Promotional mediaUntil consent is withdrawn prospectively or until no longer needed
Marketing dataUntil unsubscribe, withdrawal, or inactivity-based deletion
Website logsNormally up to 12 months unless needed for security or investigation
Cookie consent recordsNormally up to 24 months or as required for compliance evidence
Device type and coded internet address saved with a masterclass sign-upDeleted automatically after 30 days
Checks on a masterclass sign-up (marks for details that look made up, the security check result, and whether a confirmation email was sent)Kept with the sign-up they belong to, and deleted with it
Email confirmation records (masterclass sign-ups)Kept with the sign-up they belong to, and deleted with it; a record for an address no longer on any sign-up is deleted after a day
Legal claims and dispute recordsFor the duration of the dispute and applicable limitation periods

Where data is no longer needed, we will delete, anonymise, restrict, or archive it as appropriate.

17. Data Security

Vocal Excellence takes reasonable and appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration, disclosure, or destruction.

These measures may include:

  • Password protection
  • Access controls
  • Limiting access to those who need the data
  • Secure cloud services
  • Staff confidentiality obligations
  • Secure storage of sensitive documents
  • Use of reputable payment processors
  • Email and account security measures
  • Device security
  • Secure deletion where appropriate
  • Internal privacy and safeguarding procedures
  • Incident-response procedures

No website, email system, cloud service, payment platform, or digital communication method is completely secure. Vocal Excellence cannot guarantee absolute security, but it will take reasonable steps to protect personal data.

Participants and Guardians are responsible for ensuring that the information they send to Vocal Excellence is accurate and sent through appropriate channels.

18. Data Breaches

If Vocal Excellence becomes aware of a personal data breach, it will assess the breach and take appropriate steps.

Where legally required, Vocal Excellence will notify the Cyprus Commissioner for Personal Data Protection without undue delay and, where required, within 72 hours of becoming aware of the breach.

Where a breach is likely to result in a high risk to the rights and freedoms of affected individuals, Vocal Excellence will notify affected individuals without undue delay, unless an exemption applies.

Vocal Excellence may also notify insurers, legal advisers, processors, authorities, or other relevant parties where necessary to investigate, contain, or respond to a breach.

19. Your Data Protection Rights

Subject to legal conditions, exemptions, and limitations, you may have the following rights under GDPR:

  • Right of access
  • Right to rectification
  • Right to erasure
  • Right to restriction of processing
  • Right to data portability
  • Right to object
  • Right to withdraw consent
  • Right not to be subject to certain solely automated decisions with legal or similarly significant effects
  • Right to complain to a supervisory authority

These rights are not absolute. Vocal Excellence may refuse or limit a request where permitted by law, including where data must be retained for legal, safeguarding, contractual, insurance, tax, accounting, dispute-resolution, or legitimate-interest reasons.

20. How to Exercise Your Rights

To exercise your rights, contact:

info@vocalexcellence.cy

We may ask for information needed to verify your identity.

We will normally respond within one month. Where permitted by law, this period may be extended by up to two further months for complex or multiple requests.

Requests are usually free of charge. However, where a request is manifestly unfounded, excessive, repetitive, or abusive, we may charge a reasonable fee or refuse to act, where permitted by law.

For Participants under 18, rights requests may need to be made or authorised by a parent or legal guardian, depending on the age, maturity, nature of the request, and applicable law.

21. Accuracy of Information

Participants, Guardians, staff, contractors, and other individuals are responsible for providing accurate, complete, and up-to-date information.

You must notify Vocal Excellence promptly if relevant information changes, especially:

  • Contact details
  • Emergency contact details
  • Guardian details
  • Medical information
  • Allergy information
  • Access needs
  • Safeguarding or welfare information
  • Payment details
  • Travel or attendance information

Vocal Excellence is not responsible for problems caused by inaccurate, incomplete, outdated, or withheld information, except where required by law.

23. Automated Decision-Making

Vocal Excellence does not make decisions producing legal or similarly significant effects based solely on automated processing.

We may use basic digital tools to organise applications, communications, payments, website forms, analytics, or marketing preferences, but admission decisions are not made solely by automated means.

On the masterclass sign-up form, if the automated security check cannot confirm that a person is using the form, we may ask you to try again, or hold the sign-up back for us to review instead of adding it to the waitlist straight away. We look at every sign-up we hold back and write to anyone who appears to be a real person. Our other checks only mark an entry for us to look at. When we send booking links, we may hold back, for that round, a sign-up whose details look made up or whose email address has not been confirmed. We look at each one before deciding.

24. Records of Processing and Accountability

Vocal Excellence maintains appropriate internal records of processing activities where required by GDPR.

Because Vocal Excellence may process personal data regularly and may process special category data such as health, allergy, access, or safeguarding information, it may need to keep appropriate records even if it is a small organisation. GDPR Article 30 provides limited exemptions for organisations with fewer than 250 employees, but those exemptions do not apply in several situations, including non-occasional processing or special-category processing.

Vocal Excellence may maintain internal policies, consent records, processor records, safeguarding records, retention records, and other compliance documentation as appropriate.

25. Data Protection Impact Assessments

Vocal Excellence will consider whether a Data Protection Impact Assessment is required where processing is likely to result in a high risk to individuals.

This may include new technology, high-risk processing, large-scale special category processing, or other situations where a formal assessment is legally required or considered appropriate.

Vocal Excellence is not promising that every processing activity requires a Data Protection Impact Assessment.

26. Third-Party Websites and Links

The Vocal Excellence website may contain links to third-party websites, including payment providers, social media platforms, video platforms, venues, faculty websites, travel resources, or other external services.

Vocal Excellence is not responsible for the privacy practices, security, content, or policies of third-party websites.

You should read the privacy policies of any third-party websites or services you use.

27. Social Media

If you interact with Vocal Excellence on social media, the relevant social media platform may process your personal data under its own privacy policy.

Vocal Excellence may view, respond to, share, or retain social media interactions where relevant to enquiries, marketing, reputation management, safeguarding, complaints, or legal protection.

Do not send sensitive personal data through public social media channels.

28. Complaints

If you have a privacy concern, please contact Vocal Excellence first so we can try to resolve it:

info@vocalexcellence.cy

You also have the right to lodge a complaint with the Cyprus Commissioner for Personal Data Protection.

Office of the Commissioner for Personal Data Protection

Office address: Kypranoros 15, Nicosia 1061, Cyprus

Postal address: P.O. Box 23378, 1682 Nicosia, Cyprus

Telephone: +357 22 818 456

Email: commissioner@dataprotection.gov.cy

Website: dataprotection.gov.cy

29. Changes to This Policy

Vocal Excellence may update this Privacy Policy from time to time.

Updates may be made to reflect changes in:

  • Law
  • Regulatory guidance
  • Programme operations
  • Website functions
  • Service providers
  • Data processing activities
  • Security practices
  • Business structure
  • Contact information

The version published on the website is the current version.

Where changes are material and where legally required or reasonably appropriate, Vocal Excellence may notify affected individuals by email or other suitable means.

Continued use of the website, application process, or Programme services after an updated Policy is published means that the updated Policy applies from its effective date, subject to mandatory legal rights.

30. Governing Law

This Privacy Policy is governed by the laws of the Republic of Cyprus.

Nothing in this Policy limits any mandatory rights under GDPR, Cyprus data protection law, or other applicable law.

Subject to mandatory legal rights and applicable data protection complaint mechanisms, disputes connected with this Policy shall be handled under the governing law and jurisdiction provisions in the Vocal Excellence Terms of Use & Participation Agreement.

31. Contact

For privacy questions, rights requests, consent withdrawals, or data protection concerns, contact:

Vocal Excellence

Privacy Contact: Andreas Aroditis

Email: info@vocalexcellence.cy

General email: info@vocalexcellence.cy

Telephone: +357 25 775 885

Address: Ναυπλίου 12, Χριστοδουλίδης Κόρτ, Κατάστημα 1, Limassol, 3025