Effective Date: 1 February 2025 · Last Updated: February 2025
In short: We collect only what we need to provide our services. We never sell your data. Your health information is treated with the highest level of confidentiality. You can access, correct, or delete your information at any time by contacting us.
1. Who We Are
Halo Journey Australia Pty Ltd (ACN 682 044 631) ("Halo Journey," "we," "us," or "our") provides online counselling, psychotherapy, life coaching, family dispute resolution (FDR), and mediation services across Australia.
We are committed to protecting your privacy and handling your personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).
Contact details:
2. What Information We Collect
The types of personal information we collect depend on how you interact with us.
Information you provide directly
- Contact information: Name, email address, phone number, and postal address.
- Booking information: Appointment details, preferred practitioner, scheduling preferences.
- Health and sensitive information: Information you share during sessions, intake forms, or assessments — including mental health history, presenting concerns, relationship details, and any other information relevant to your care.
- FDR and mediation information: Details related to your dispute, family circumstances, court requirements, and any information required to issue a Section 60I Certificate.
- Payment information: Billing details processed securely through our third-party payment provider. We do not store credit card numbers.
- Communication records: Emails, phone call notes, and messages you send us.
Information collected automatically
- Website analytics: IP address, browser type, device type, pages visited, and time spent on our website. This is collected via cookies and analytics tools (e.g., Google Analytics).
- Advertising data: If you arrive at our website via an advertisement, we may collect information about the source (e.g., Facebook Ads, Google Ads) to measure ad effectiveness. This data is aggregated and does not identify you individually.
3. How We Use Your Information
We use your personal information for the following purposes:
- To provide counselling, psychotherapy, life coaching, FDR, and mediation services.
- To book, manage, and follow up on appointments.
- To communicate with you about your care, appointments, and services.
- To process payments and issue invoices or receipts.
- To issue Section 60I Certificates (FDR clients).
- To comply with legal and regulatory obligations.
- To improve our website, services, and client experience.
- To send you information about our services, events, or the Halo Club newsletter — only with your consent, and you can unsubscribe at any time.
4. Sensitive Information
We understand that the information you share with us is deeply personal. Under the Privacy Act, health information is classified as sensitive information and receives a higher level of protection.
We only collect sensitive information:
- With your consent;
- Where it is directly related to providing our services to you; or
- Where required or authorised by law.
Confidentiality of sessions: The content of your counselling, coaching, FDR, or mediation sessions is strictly confidential. We will not disclose session content without your written consent, except where required by law (see Section 7).
5. How We Store and Protect Your Information
We take the security of your information seriously and implement the following safeguards:
- Secure telehealth platform: All sessions are conducted via secure, encrypted video conferencing.
- Practice management system: Client records are stored in Zanda Health (formerly Power Diary), a secure, Australian-hosted practice management system that complies with Australian privacy laws.
- Access controls: Only your assigned practitioner and authorised Halo Journey staff have access to your records.
- Encrypted communications: Electronic communications are encrypted where possible.
- Staff obligations: All practitioners and staff are bound by confidentiality agreements and professional codes of ethics.
While we take all reasonable steps to protect your information, no data transmission over the internet can be guaranteed to be 100% secure. If you become aware of any security breach, please contact us immediately.
6. Who We Share Your Information With
We do not sell, rent, or trade your personal information. We will never share your information for marketing purposes.
We may share your information with:
- Your practitioner: The counsellor, coach, mediator, or FDR practitioner assigned to your care.
- Practice management and payment providers: Zanda Health (record keeping), Stripe or other payment processors (payment processing). These providers are bound by their own privacy obligations.
- Courts and legal bodies: Where required by law — for example, issuing a Section 60I Certificate to a court (FDR clients only).
- Professional supervisors: Practitioners may discuss your case (in de-identified form) with their clinical supervisor as part of maintaining professional standards. Your identity is not disclosed.
- Referral partners: If we refer you to another service (with your consent), we may share relevant information to support continuity of care.
7. When We Are Required to Disclose Information
In limited circumstances, we may be legally required to disclose your information without your consent. These include:
- Mandatory reporting: Where there is a reasonable belief that a child or young person is at risk of significant harm, or where required under state or territory mandatory reporting laws.
- Risk of serious harm: Where we believe there is a serious and imminent threat to life, health, or safety — either yours or another person's.
- Court orders: Where we receive a valid subpoena or court order requiring disclosure.
- Legal obligations: Where disclosure is required under Australian law.
We will always act in accordance with the relevant professional codes of ethics and legal requirements.
8. Cookies and Website Analytics
Our website uses cookies and analytics tools to improve your experience and measure website performance.
- Essential cookies: Required for the website to function (e.g., booking system).
- Analytics cookies: Help us understand how visitors use our website (e.g., Google Analytics). This data is aggregated and does not personally identify you.
- Advertising cookies: Used to measure the effectiveness of our advertising campaigns on platforms such as Facebook and Google. These may use tracking pixels.
You can manage cookie preferences through your browser settings. Disabling cookies may affect website functionality.
9. Your Rights
Under the Australian Privacy Principles, you have the right to:
- Access: Request access to the personal information we hold about you.
- Correction: Request that we correct any inaccurate, out-of-date, or incomplete information.
- Deletion: Request that we delete your personal information where it is no longer needed for the purpose it was collected (subject to legal retention requirements).
- Withdraw consent: Withdraw your consent to marketing communications at any time by clicking "unsubscribe" in any email or contacting us directly.
- Complain: Lodge a complaint about how we have handled your personal information.
To exercise any of these rights, contact us at [email protected] or call 0414 975 728. We will respond within 30 days.
10. Retention of Information
We retain your personal information for as long as necessary to provide our services and comply with legal obligations.
- Client records (adults): Retained for a minimum of 7 years from the date of last contact, in accordance with professional guidelines and Australian health records legislation.
- Client records (children): Retained until the client turns 25 years of age, or 7 years from the date of last contact — whichever is later.
- FDR records: Retained in accordance with the Family Law Act 1975 (Cth) requirements.
- Financial records: Retained for 7 years as required by Australian tax law.
After the relevant retention period, records are securely destroyed.
11. Third-Party Links
Our website may contain links to third-party websites (e.g., booking platforms, social media). We are not responsible for the privacy practices of these websites. We encourage you to review their privacy policies before providing any personal information.
12. Children's Privacy
Where we provide counselling services to children and adolescents, we collect personal and health information with the consent of the child's parent or legal guardian. We take extra care to ensure that children's information is handled sensitively and in accordance with all applicable laws.
13. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The updated version will be posted on our website with the revised "Last Updated" date. We encourage you to review this page periodically.
14. Complaints
If you believe we have breached the Australian Privacy Principles or mishandled your personal information, please contact us:
We will investigate your complaint and respond within 30 days. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC):
15. Contact Us
For any questions, concerns, or requests relating to this Privacy Policy or your personal information, please contact us:
Halo Journey Australia Pty Ltd
ACN 682 044 631
Email: [email protected]
Phone: +61 414 975 728
Available: Monday to Sunday, 8:00am – 10:00pm AEST