Privacy Policy
Trauma Clinic 2.0 - Privacy Policy
(Hong Kong SAR)
Effective date: 01 September 2025
Operator: Trauma Clinic 2.0 is operated by Essentia Psychological Services Co. (Hong Kong SAR), Business Registration No. 56583587-000-08-19-6 (“Essentia,” “we,” “us,” “our”).
This Privacy Policy explains how we collect, use, disclose, store, and protect personal data when you use the Trauma Clinic 2.0 directory (the “Directory”).
We aim to handle personal data in accordance with Hong Kong’s Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”) and the Data Protection Principles (DPPs). Using the Directory signifies you agree to this Policy and our Terms & Conditions.
1) Who this applies to
Therapy-seekers / clients browsing or contacting therapists through the Directory.
Therapists / providers listing a profile in the Directory.
Website visitors interacting with our forms, emails, or resources.
Important: We are a directory and resources service. We do not provide healthcare, make matches, or handle bookings or payments. When you contact a therapist, any subsequent communication and services are off-directory and subject to that therapist’s own privacy practices.
2) What personal data we collect
A. Therapy-seekers / clients
Contact details you share (name, email, phone, preferred contact method).
Message content you send to us for support or enquiries.
Optional preferences used for filters (e.g., language, budget, online/in-person).
Technical data (IP address, device/browser, cookies/analytics—see Cookies Notice).
B. Therapists / providers
Profile and professional data (name, credentials, license/registration, training hours, modalities, languages, fees, availability, location/time zone, biography, links, images).
Vetting documentation you provide (e.g., certificates, supervision/insurance evidence).
Account/billing/contact details for listing plans (where applicable).
Communication with us (support, updates, compliance requests).
C. Website visitors
Basic usage analytics and cookie data (see Cookies Notice).
Contact details you submit via forms/newsletters.
We do not intentionally collect special categories beyond what therapists voluntarily provide in their profiles (e.g., approaches to trauma), nor do we ask clients to submit clinical information. Please do not send acute crisis details through the Directory.
3) Why we use personal data (purpose statements)
We use personal data only for the purposes notified at or before collection (PDPO DPP1), including to:
Operate and improve the Directory and associated resources.
Publish and manage therapist listings, tiers/badges, and search filters.
Review therapist training/experience for editorial tiers (informational, not certification).
Respond to enquiries and provide non-clinical user support.
Administer therapist subscriptions, notices, and account communications (if applicable).
Prevent abuse, enforce Terms, and maintain security and uptime.
Comply with legal obligations and reasonable internal governance.
Direct marketing: We will only use your personal data for direct marketing with your consent or where otherwise permitted by PDPO. You may opt out at any time (see Section 9).
4) Who we share personal data with
Service providers / data processors under contract (e.g., secure hosting, email/SMS, forms/surveys, analytics, error monitoring, payment processors for therapist listings). They may process data solely to provide us these services and are bound by confidentiality.
Professional advisers and insurers (if reasonably necessary, e.g., legal advice, risk management).
Authorities if required by law, court order, or to protect rights, safety, or compliance.
We do not sell your personal data.
5) Cross-border transfers
We may transfer personal data outside Hong Kong (e.g., to global hosting, email, analytics, or support tools). We take reasonable steps to ensure recipients provide a comparable standard of protection consistent with PDPO’s requirements.
6) Data retention
We keep personal data only for as long as reasonably necessary for the stated purposes, to meet legal/accounting requirements, or to resolve disputes. Illustratively:
Basic enquiry records: typically 12–24 months.
Therapist listing and vetting records: while the listing is active and up to 6 years after removal, unless longer retention is required by law or regulatory guidelines.
Analytics/cookie data: per our Cookies Notice and provider defaults.
7) Security
We use appropriate technical and organisational measures to protect personal data (e.g., access controls, encryption in transit, least-privilege access, staff confidentiality). No system is 100% secure; please avoid sending sensitive clinical or crisis details via general forms.
8) Directory vs therapist responsibilities
The Directory publishes therapist profiles and provides non-clinical filtering guidance. We do not supervise clinical practice or maintain client clinical records. When you contact a therapist, they become the data user/controller for their independent practice and must provide their own privacy information, consent forms, and records management.
9) Your rights (PDPO)
Subject to PDPO and applicable exemptions, you may:
Request access to personal data we hold about you.
Request correction of inaccurate data.
Opt out of direct marketing at any time.
Withdraw consent where processing is based on consent (this won’t affect prior processing).
We may require verification of identity and are permitted to charge a reasonable fee for data access requests (not for correction). We will respond within a reasonable period as required by PDPO.
How to exercise your rights: See Section 12 (Contact).
10) Children
The Directory is intended for adults (18+). We do not knowingly collect personal data from children. If you believe a minor has provided personal data, please contact us to request deletion.
11) Cookies and similar technologies
We use cookies and similar technologies to operate the site and understand usage. See our Cookies Notice for details and your choices.
12) Changes to this Policy
We may update this Privacy Policy from time to time. Material changes will be posted with a new effective date. Continued use of the Directory indicates acceptance of the updated Policy.
13) Contact
Essentia Psychological Services Co. (Hong Kong SAR)
Trading as: Trauma Clinic 2.0
Business Registration No.: 56583587-000-08-19-6
Email: [hello@yourdomain.com]
Postal address: [Insert registered or correspondence address]
Trauma Clinic 2.0
Cookies Notice
1) What are cookies?
Cookies are small text files placed on your device to help the site function and to understand how it’s used. Similar technologies (e.g., local storage, pixels) may also be used.
2) How we use cookies
Strictly necessary cookies (essential): enable core site functionality (security, page navigation). The site cannot function properly without these; consent is not required.
Functional cookies: remember choices (e.g., language).
Analytics/performance cookies: help us understand how the Directory is used (page views, device types) so we can improve usability and reliability. Data is aggregated.
Advertising cookies: Not used by default. If we ever introduce them, we will update this Notice and request consent where required.
3) Your choices
Consent/controls: Where required, we will show a cookie banner that lets you accept or manage non-essential cookies.
Browser settings: You can block or delete cookies via your browser. This may affect site functionality.
Withdraw consent: If you previously accepted non-essential cookies, you can change your preferences at any time via the cookie settings link [add link] or your browser controls.
4) Third-party analytics/tools
We may use reputable analytics or service providers (e.g., privacy-focused analytics, uptime/error monitoring). These providers may set their own cookies. We aim to limit data collection and retain aggregated usage insights only.
5) Retention
Cookie duration varies: some expire at session end; others persist for a defined period (typically 1–24 months) unless you clear them earlier.
6) Updates
We may update this Cookies Notice periodically. Material changes will be reflected with a new effective date.
Contact: [hello@yourdomain.com]
