Privacy
Policy.

How we collect, use, and protect your personal information.

Last updated: May 2026
GDPR (EU) POPIA (South Africa) LGPD (Brazil) Online Worldwide

Your privacy matters deeply. This practice handles sensitive personal information with the highest standard of care, discretion, and respect — consistent with our therapeutic values and our legal obligations.

1. Who We Are

This Privacy Policy applies to Third Culture by Milenne Cervi, a bilingual intercultural therapeutic consulting practice operated by Milenne Cervi, based in Cape Town, South Africa, serving clients online worldwide and in-person in Cape Town.

For the purposes of applicable data protection law, Milenne Cervi is the data controller responsible for your personal information.

Contact Details

Third Culture by Milenne Cervi
Cape Town, South Africa
hello@thirdculturebymilenne.com
+27 76 920 2866

2. Data We Collect

We collect only the personal information necessary to provide our services. This may include:

Information you provide directly

  • Full name, email address, and phone number (via the contact form or WhatsApp)
  • Information about your situation, background, relationship, or reason for enquiring
  • Country of residence and cultural background (relevant to the nature of our work)
  • Language preference (English or Portuguese)
  • Any other information you choose to share during enquiry or sessions

Sensitive personal information

Given the therapeutic nature of this practice, we may process sensitive personal data including information about your mental and emotional health, relationships, cultural identity, migration history, and family circumstances. This information is handled with the utmost discretion and processed only on the basis of your explicit consent.

Information collected automatically

This website does not currently use analytics or tracking software. Basic technical data (such as browser type and approximate location) may be logged by the web hosting provider. See Section 10 (Cookies) for details.

3. How We Use Your Information

We use your personal information only for the following purposes:

  • To respond to your enquiry and assess whether our services are appropriate for your needs
  • To deliver mentoring and therapeutic consulting sessions, both online and in-person
  • To maintain records necessary for professional practice and continuity of care
  • To communicate with you about appointments, follow-up, or resources relevant to your work together
  • To comply with our legal and professional obligations

We do not use your information for marketing, profiling, or automated decision-making. We do not send unsolicited communications.

5. Confidentiality

Everything shared in sessions is treated as strictly confidential. Confidentiality is a core professional and ethical commitment of this practice.

Confidentiality may only be broken in the following exceptional circumstances, and only to the minimum extent necessary:

  • Where there is a serious and imminent risk of harm to you or to another person
  • Where we are legally required to disclose information by a court order or applicable law
  • Where you have given your explicit written consent for disclosure

In any such situation, you would be informed wherever possible prior to any disclosure.

6. Sharing Your Data

We do not sell, rent, or trade your personal information. We do not share your information with third parties for marketing purposes.

Limited data sharing may occur only in the following circumstances:

  • With video conferencing platforms (e.g. Zoom, Google Meet) used to deliver online sessions — these are subject to their own privacy policies
  • With professional supervisors or consultants, strictly under professional confidentiality obligations, and without identifying information where possible
  • Where legally required, as described in Section 5 above

All third-party tools used in this practice are selected with privacy in mind and are used in accordance with their respective data protection agreements.

7. Data Retention

We retain your personal data only for as long as necessary for the purposes for which it was collected, and in compliance with our professional and legal obligations.

  • Enquiry records (no engagement): deleted or anonymised within 12 months of last contact
  • Client session records: retained for a minimum of 5 years from the date of last session, in line with professional practice standards and South African legal requirements
  • Financial records: retained for 7 years in compliance with South African tax legislation

After the applicable retention period, personal data is securely deleted or permanently anonymised.

8. Your Rights

Depending on your country of residence, you may have some or all of the following rights regarding your personal data:

Access

Request a copy of the personal data we hold about you.

Rectification

Request correction of inaccurate or incomplete data.

Erasure

Request deletion of your data, where we are not required to retain it by law.

Restriction

Request that we limit how we use your data in certain circumstances.

Portability

Receive your data in a structured, commonly used format (where technically feasible).

Objection

Object to processing based on legitimate interests.

Withdraw Consent

Withdraw consent at any time where processing is based on consent.

Complain

Lodge a complaint with the relevant supervisory authority in your country.

To exercise any of these rights, please contact us using the details in Section 13. We will respond within 30 days. We may need to verify your identity before processing your request.

Supervisory Authorities

  • South Africa: Information Regulator — www.inforegulator.org.za
  • Brazil: ANPD (Autoridade Nacional de Proteção de Dados) — www.gov.br/anpd
  • EU/EEA clients: the supervisory authority in your member state

9. Security

We take reasonable technical and organisational measures to protect your personal information from unauthorised access, disclosure, alteration, or destruction. These include:

  • Encrypted communication channels for all online sessions
  • Password-protected devices and accounts used to store client information
  • Secure storage of physical notes and records, with restricted access
  • Use of reputable, privacy-compliant platforms for video sessions and communication

No method of electronic transmission or storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security. In the event of a data breach that affects your rights and freedoms, we will notify you as required by law.

10. Cookies

This website currently uses only essential functional cookies — specifically, a cookie to remember your language preference (English or Portuguese) between visits. No tracking, advertising, or analytics cookies are used.

You can clear cookies at any time through your browser settings. Disabling cookies will not affect your ability to use this website, though your language preference will not be saved.

If analytics or third-party tools are added to this website in future, this policy will be updated and a cookie consent mechanism will be implemented.

11. Minors

Our services are intended for adults (18 years and older). We do not knowingly collect personal information from individuals under 18 without verified parental or guardian consent.

In the context of parental consultation services, information relating to children may be discussed. In such cases, only the minimum necessary information is recorded, and it is handled with the same level of confidentiality and care as all other client data.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practice, technology, or legal requirements. The date of the most recent revision is shown at the top of this page.

Where changes are significant, we will take reasonable steps to notify existing clients. Continued use of our website or services after any changes constitutes acceptance of the updated policy.

13. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact:

Milenne Cervi

Third Culture by Milenne Cervi

Cape Town, South Africa

hello@thirdculturebymilenne.com

+27 76 920 2866

We aim to respond to all privacy-related enquiries within 30 days.