Privacy Policy
Your privacy matters deeply — not just as a legal requirement, but as a foundation of the counselling relationship. This page explains clearly what information we collect, how we use it, and the important limits of confidentiality that apply in a counselling context.
1. Who we are
ANew Horizon Counselling is a private counselling practice based in Hong Kong, operated by Anaitha Nair. We provide individual, couples, and teen counselling sessions, both in person in Hong Kong and online worldwide.
Data controller: Anaitha Nair, ANew Horizon Counselling
Contact: hello@anewhorizoncounselling.com
Website: anewhorizoncounselling.com
This policy applies to personal data collected through this website, our intake and booking forms, and in the course of providing counselling services. It is written in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) (PDPO) of Hong Kong, and is consistent with the ethical guidelines of the Hong Kong Professional Counselling Association (HKPCA).
2. What personal data we collect
When you submit a booking or enquiry form
- Your name
- Email address
- Phone number (including WhatsApp contact preference)
- A brief note about what brings you to counselling (optional)
- Your preferred session format (in-person or online) and timing
When you complete the online intake form
- Personal details: name, date of birth, address, contact information
- Emergency contact information
- Reason for seeking counselling and relevant personal history
- Your digital signature (recorded as an image)
- Consent to the counselling agreement and confidentiality terms
When you make a payment
Payments are processed by Airwallex, a licensed financial services provider. We do not see, store, or have access to your card details. Payment data is handled entirely by Airwallex under their own privacy policy and PCI-DSS compliance framework. We receive only confirmation that a payment was completed.
Website usage
This website does not use tracking cookies or analytics software. No data is collected simply from browsing the site. We do not use Google Analytics, Facebook Pixel, or any other third-party tracking tools.
3. How we use your data
We collect and use personal data only for purposes directly related to providing counselling services. Specifically:
- To respond to your enquiry or booking request
- To schedule and manage counselling sessions
- To maintain a record of your intake and consent documentation
- To process payment for sessions
- To contact you about your appointment (by email, phone, or WhatsApp — where you have consented)
- To fulfil any legal or professional obligations
We will not use your data for marketing purposes, and we will not contact you with promotional material without your explicit consent.
4. Confidentiality in counselling
Everything you share within the counselling relationship is held in strict confidence. Your counsellor will not disclose any information about you — or even confirm that you are a client — to any third party without your written consent.
Exceptions to confidentiality. In keeping with the HKPCA Code of Ethics and Hong Kong law, there are a small number of circumstances where confidentiality may need to be broken without your consent. These are:
- Risk of serious harm to yourself or others — if your counsellor has reasonable grounds to believe that you or another person faces an imminent risk of serious physical harm, they may be required to take action to prevent that harm, which may include contacting appropriate services.
- Legal obligation — where a court of competent jurisdiction issues an order requiring disclosure, or where disclosure is required by statute under Hong Kong law.
- Child or vulnerable adult protection — where there are reasonable grounds to suspect that a child or vulnerable adult is at risk of abuse or neglect.
- Supervision — your counsellor participates in regular professional supervision as required by the HKPCA. Case material may be discussed with a supervisor in an anonymised or pseudonymised form for the purpose of maintaining professional standards and supporting your care. Supervisors are bound by equivalent confidentiality obligations.
Where possible, your counsellor will discuss with you before breaking confidentiality, unless doing so would put you or another person at risk.
5. How your data is stored and protected
Intake forms and session notes are stored securely by your counsellor. Electronic records are password-protected. Physical records (where applicable) are kept in a locked location accessible only to your counsellor.
Booking enquiries submitted through this website are transmitted via Web3Forms (a secure form processing service) and delivered by encrypted email. Intake form data is transmitted via EmailJS using TLS-encrypted connections.
We take reasonable technical and organisational measures to protect your personal data from unauthorised access, loss, or disclosure, in accordance with Data Protection Principle 4 of the PDPO.
How long we keep your data
In line with professional counselling practice guidelines, session records (including intake forms, notes, and consent documentation) are retained for a minimum of 7 years from the date of your last session, or until you reach the age of 25 if you were a minor at the time of treatment — whichever is later. After this period, records are securely destroyed.
Booking enquiries that do not proceed to a counselling engagement are deleted within 12 months of the enquiry date.
6. Who we share your data with
We do not sell, rent, or trade your personal data. We share your data only in the following limited circumstances:
- Professional supervisor — in anonymised form only, as described above
- Airwallex — payment processing only; they receive only the information needed to process a transaction
- Web3Forms / EmailJS — form delivery services; they transmit your data securely but do not store it beyond transit
- Legal or regulatory authorities — only where required by law
All third-party services we use are subject to their own privacy policies and appropriate data processing terms. None of our third-party providers are permitted to use your personal data for their own purposes.
Your data is processed primarily in Hong Kong. Where data is transferred outside Hong Kong (for example, via cloud-based email or form services), we take steps to ensure it receives equivalent protection.
7. Your rights under the PDPO
Under the Personal Data (Privacy) Ordinance (Cap. 486), you have the right to:
- Access — request a copy of the personal data we hold about you
- Correction — request that inaccurate or incomplete data is corrected
- Opt out of direct marketing — we do not use your data for direct marketing; if this ever changes, you will be asked for explicit consent first
To make a data access or correction request, please contact us in writing at hello@anewhorizoncounselling.com. We will respond within 40 days as required by the PDPO (Section 19).
Please note that in some circumstances, professional confidentiality obligations or legal requirements may limit our ability to disclose or delete certain information — for example, session records that we are required to retain for professional indemnity or legal purposes.
If you believe your rights under the PDPO have been infringed, you may lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD) at pcpd.org.hk or on +852 2827 2827.
8. Cookies and tracking
This website does not use cookies for tracking or analytics purposes. No cookie consent banner is shown because no tracking cookies are set. If this changes in the future, this policy will be updated and you will be notified appropriately.
9. Changes to this policy
We may update this Privacy Policy from time to time. Any material changes will be noted at the top of this page with an updated date. We encourage you to review this policy periodically. Your continued use of the website or our services after changes are posted constitutes your acceptance of the updated policy.
10. Contact us
If you have any questions about this Privacy Policy or how we handle your personal data, please get in touch:
- Email: hello@anewhorizoncounselling.com
- WhatsApp: +852 4449 9947
This policy is governed by the laws of the Hong Kong Special Administrative Region. ANew Horizon Counselling is operated in accordance with the HKPCA Code of Ethics and Practice for Counsellors (2021 revised).