Privacy Notice
Last updated 3 August 2026
Who we are
Xin Shui is a trading name of Consilium Growth Project Management Services, a sole establishment licensed in Dubai, United Arab Emirates (licence number 1641120). Consilium Growth Project Management Services is the data controller responsible for the personal information described in this notice. In this notice, "we", "us" and "our" refer to that entity, operating as Xin Shui.
If you have any question about this notice or about how your information is handled, you can contact us at privacy@claritybyxinshui.com.
What this notice covers
This notice explains what personal information we collect when you enquire about or attend a Xin Shui session, why we collect it, how it is handled, how long we keep it, and the rights you have. It applies to our website at claritybyxinshui.com and to sessions arranged with us.
The information we collect
Enquiry details. When you complete the enquiry form or contact us, we collect your name, email address, telephone number, and anything you choose to write in your message.
Session details. To prepare and deliver your profile, we collect your date of birth, time of birth, and place of birth, together with notes relevant to your session. You provide these before or during a session. This information is used only to prepare and discuss your profile.
Payment records. Where you pay for a session, we keep a record of the payment, such as the amount, the date, and confirmation that it was made.
We do not collect more than we need for the purposes set out below.
How we use your information
We use your information to:
- respond to your enquiry and arrange your session;
- prepare and deliver your profile and any written report;
- take and keep a record of payment; and
- meet our legal, tax, and accounting obligations.
Our legal basis
Under the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021), we rely on the following. We rely on your consent to collect and use your enquiry details and your birth details, which you may withdraw at any time. We rely on the performance of the service you have asked us to provide in order to prepare and deliver your session. We rely on our legal obligations to keep certain financial and tax records.
Who can access your information
Your information is seen by the practitioner and the operator of Xin Shui, so that your session can be prepared and delivered.
We use a small number of service providers who process information on our instructions and only for us, namely our website hosting provider and our email provider, which together allow the enquiry form to reach us. These providers act on our behalf, are required to protect your information, and are not permitted to use it for their own purposes.
We do not sell your information, and we do not share it with any third party for that party's own marketing.
Where your information is held
Our website is hosted on servers operated by our hosting provider, which are located outside the United Arab Emirates. This means your information may be processed outside the UAE. Where information is handled outside the UAE, we take reasonable steps to see that it remains protected to a standard consistent with UAE law.
Marketing
We do not send marketing messages. We use your contact details only to reply to you and to arrange and deliver your session.
How long we keep your information
We keep your enquiry details, personal details, and birth details for as long as needed to provide your session, and then delete them twelve months after your last session or your last contact with us, whichever is later.
We keep records that we are required to hold for financial, tax, or legal reasons, such as proof of payment, for five years, after which they are deleted.
Your rights
Under the UAE Personal Data Protection Law you have the right to:
- ask for a copy of the information we hold about you;
- ask us to correct information that is wrong or incomplete;
- ask us to delete your information;
- withdraw your consent at any time;
- object to, or ask us to restrict, certain uses of your information;
- ask us to transfer your information; and
- make a complaint about how your information is handled.
To exercise any of these, contact us at privacy@claritybyxinshui.com. Withdrawing consent does not affect anything done before you withdrew it.
How we protect your information
We take reasonable measures to keep your information secure and to limit access to it to those who need it to provide your session.
Cookies and analytics
At present, our website does not use analytics or advertising cookies, and we do not track visitors. Only what is necessary to run the website is used. If this changes, we will update this notice and provide a cookie notice and a way to manage your choices.
Children
Our sessions are for adults. We do not knowingly collect information from anyone under the age required in the applicable jurisdiction.
Changes to this notice
We may update this notice from time to time. The date at the top shows when it was last changed.
Contact and governing law
This notice, and our handling of your information, are governed by the laws of the United Arab Emirates. For any question or request, contact us at privacy@claritybyxinshui.com.