Privacy Policy
Effective Date: 31 July 2025
Last Updated: 31 July 2025
Who We Are
Nine Cups (NZBN 9429051862183) is a family-owned natural health practice operating as a health agency under the Health Information Privacy Code 2020. We provide natural health practitioner services under Section 32 of the Medicines Act 1981 and manufacture herbal products under National Programme 3 (NP3) of the Food Act 2014.
Principal Practitioner: Sergei Arefev (20+ years experience in natural health)
Business Owner: Anastasiia Arefeva
Location: 8b Saturn Place, Rosedale, Auckland
Practice Framework: Natural health practitioner using LLLT diagnostic method with diverse knowledge base including herbal medicine, wellness coaching, and holistic health approaches
As a health agency, we are subject to enhanced privacy obligations for all health information collected, used, and disclosed. This policy applies across all Nine Cups domains and platforms:
• 9cups.nz
• nine-cups.com
• nine-cups.co.nz
• nine-cups-clinic.com
• ninecups-clinic.co.nz
Practitioner Consultation Model Declaration
Nine Cups follows a practitioner consultation model as defined in Section 32 of the Medicines Act 1981. This means:
• All personalised herbal remedies are only supplied following a one-on-one consultation with our qualified natural health practitioner
• No personalised remedies are available for general retail or public therapeutic claims
• Our practice distinguishes between professional consultation services and general wellness products in line with New Zealand’s regulatory standards
• Botanical blends are general wellness teas manufactured under NP3 (Food Act 2014) without therapeutic claims outside professional consultation
What Information We Collect (HIPC Rules 1–4)
Under Rules 1–4 of the Health Information Privacy Code 2020, we collect:
Personal Identification Information
• Full name and date of birth
• Contact details (address, phone, email)
• Emergency contact information
• Cultural and linguistic preferences
Health Information (Collected Only for Therapeutic Purposes)
• Comprehensive consultation notes using LLLT diagnostic method
• Traditional diagnostic observations (pulse, tongue, facial analysis)
• Health history and current concerns
• Family health patterns (where relevant for multi-generational consultations)
• Personalised herbal remedy formulations (powder and capsule formats)
• Custom botanical blend recommendations
• QiGong/TaiChi/mindful energy practice guidance notes
• Treatment progress notes and follow-up assessments
• Discovery consultation preliminary health information
Transactional and Service Data
• Consultation appointment records
• Order details for personalised remedies and botanical blends
• Payment information (processed securely, not stored)
• Consultation preferences and booking history
Digital Usage Data (Website Functionality Only)
• Cookies and session information
• IP address and browser information
• Website navigation patterns
• Contact form submissions
International Client Information
• Shipping addresses for export orders
• Customs declaration requirements
• Time zone preferences for virtual consultations
⚠️ Important Collection Principles:
• All health information is collected directly from you unless exceptional circumstances apply (HIPC Rule 2)
• You are informed of collection purposes and potential disclosures before collection (HIPC Rule 3)
• Collection is limited to information necessary for your health and wellness consultation and service provision
How We Use Your Information
1A. Health Practitioner Services (Section 32 Compliance)
Professional Consultations: Conduct comprehensive health assessments using LLLT diagnostic method. In accordance with Section 32 of the Medicines Act 1981, all personalised herbal remedies are formulated only after a professional consultation and are not available to the general public.
Personalised Remedies: Formulate and supply customised herbal remedies (powder and capsule formats) following consultation under Section 32 exemption requirements.
QiGong/Mindful Energy Guidance: Provide traditional wellness practices and energy work recommendations within natural health practitioner scope.
Treatment Support: Provide ongoing guidance and adjust formulations based on progress, maintaining consultation records as required under Medicines Act 1981 Section 32.
1B. General Wellness Products (NP3 Food Act Compliance)
Botanical Blend Sales: Nine botanical blend herbal teas manufactured under NP3 (Food Act 2014) as general wellness products without direct therapeutic claims. These products are available for general consumption without consultation requirements.
Product Information: Educational information about herbs and wellness approaches provided for general knowledge without therapeutic claims.
Universal Service Administration
• Process orders, manage appointments, and maintain consultation records
• Manufacturing Compliance: Maintain NP3 Food Act 2014 requirements for herbal product safety
Secondary Purposes (With Your Consent)
• Educational Communications: Send wellness newsletters and seasonal health guidance
• Research and Development: Anonymised data analysis to improve traditional medicine practices
• Quality Improvement: Service enhancement based on aggregated client feedback
Regulatory Requirements
• Maintain consultation records as required under Medicines Act 1981 Section 32
• Comply with professional documentation standards for natural health practitioners
• Support regulatory compliance audits and professional development requirements
Cultural Sensitivity
We respect the diverse knowledge base that informs our natural health practice, including elements drawn from various traditional healing systems. Our practitioner’s extensive experience encompasses multiple approaches to wellness, and we accommodate diverse cultural perspectives on health information sharing within our natural health practitioner framework.
Information Sharing and Disclosure (HIPC Rules 9–12)
Permitted Disclosures
We may share your information in the following circumstances:
Healthcare Referrals:
• With other natural health practitioners in our referral network (with explicit consent)
• To medical professionals when referral is recommended for your safety
• For laboratory testing or specialist consultations as part of your care plan
Professional Support Services:
• Trusted third-party service providers bound by confidentiality agreements:
• Outsourced accounting services (business transactions only, no health information)
• Secure payment processing systems
• Professional indemnity insurance providers (DUAL New Zealand coverage)
• Regulatory compliance advisors
• Export/import documentation services for international orders
Legal and Safety Requirements:
• When required by law or court order
• To protect your safety or the safety of others
• For regulatory compliance investigations
International Transfers:
For international clients, personal information may be transferred overseas for service provision. Such transfers comply with HIPC Rule 12 requirements, including:
• Adequate protection measures in the receiving country
• Contractual privacy safeguards with shipping and consultation service providers
• Client consent for international transfer of health information
What We Never Disclose
• Health information to marketing companies
• Client details to non-healthcare third parties
• Traditional diagnostic findings outside professional healthcare contexts
• Personal information for commercial purposes unrelated to your care
Information Security (HIPC Rule 5)
We implement comprehensive safeguards to protect all personal and health information against:
• Unauthorised access or disclosure
• Loss or destruction
• Unauthorised modification or transmission
• Misuse or inappropriate handling
Security Measures Include
Physical Security:
• Secure consultation rooms with soundproofing
• Locked filing systems for paper records
• Restricted access to premises during non-business hours
• Secure disposal protocols for all client materials
Digital Security:
• Encrypted storage systems for all electronic records
• Multi-factor authentication for practitioner access
• Regular security updates and system monitoring
• Secure backup systems with encryption
• Virtual consultations conducted through encrypted, secure video platforms
• No consultation sessions recorded without explicit consent
• Access restricted to practitioner and client with all privacy safeguards maintained
Staff Training:
• Comprehensive privacy training for all team members
• Regular updates on HIPC requirements and best practices
• Confidentiality agreements with all staff and contractors
• Cultural sensitivity training to respect diverse health perspectives and approaches
Business Continuity:
• Secure off-site backup systems
• Emergency access protocols for urgent client needs
• Disaster recovery procedures to protect client information
Information Retention and Disposal
Retention Periods
Consultation Records: Retained for a minimum of 7 years from last consultation
Financial Records: Retained for 7 years as required by business legislation
Marketing Preferences: Retained until withdrawal of consent
Research Data: Anonymised data may be retained indefinitely for traditional medicine research
Secure Disposal
• Paper records shredded using cross-cut industrial shredders
• Electronic data permanently deleted using secure erasure methods
• Third-party disposal services bound by confidentiality agreements
• Certificate of destruction provided for sensitive materials
All disposal occurs in compliance with Medicines Act 1981 requirements and professional natural health practitioner standards.
Your Privacy Rights (HIPC Rules 6–8)
Access Rights
You have the right to:
• Request access to all personal and health information we hold about you
• Receive copies of your consultation notes and remedy formulations
• Understand how your information has been used and shared
• Request information in accessible formats
Correction Rights
You may:
• Request correction of inaccurate personal or health information
• Add supplementary information to your health records
• Request updates to contact details and preferences
Additional Rights
• Withdrawal of Consent: Remove consent for newsletters, research participation, or information sharing
• Complaint Process: Lodge privacy complaints with our practice or the Privacy Commissioner
• Cultural Accommodation: Request culturally appropriate handling of your health information
How to Exercise Your Rights
Contact Details:
• Email: info@nine-cups.com
• Phone: +64 21 082 83825
• Post: 8b Saturn Place, Rosedale, Auckland
• In person: During consultation appointments
Response Timeframes:
• Acknowledgement within 5 business days
• Full response within 20 business days
• Complex requests may require additional time with progress updates
Special Considerations
Discovery Consultations
During free discovery consultations, we collect only essential contact information and basic health concerns. Discovery consultations do not constitute clinical care and are designed solely to introduce clients to the practice. No full diagnostic or health record is created during these initial contacts. Comprehensive health information collection occurs during full LLLT diagnostic consultations with explicit consent.
Product Manufacturing Privacy
Our herbal products (personalised remedies and nine botanical blends) are manufactured under NP3 Food Act 2014 compliance. Client information used in manufacturing is limited to formulation requirements and maintains the same privacy protections as consultation records. All product packaging complies with Medicines Regulations 1984 and NP3 labelling rules. No client health information is ever included on product labels or shipment packaging.
Family Consultations
For family consultations, we maintain separate records for each family member while respecting family health patterns and genetic considerations relevant to natural health approaches. Family consultation privacy considers multi-generational needs whilst maintaining individual privacy rights.
Children and Vulnerable Clients
Special privacy protections apply for:
• Clients under 16 years (parental consent required)
• Vulnerable adults requiring supported decision-making
• Clients with cognitive or communication challenges
Natural Health Practice Ethics
We honour the diverse knowledge traditions that inform our natural health practice, including:
• Holistic understanding of health information
• Respect for various traditional healing wisdom and approaches
• Ethical integration of multiple wellness methodologies
• Recognition of the interconnected nature of physical, mental, and wellness aspects
Professional Indemnity Insurance:
We maintain professional indemnity insurance (DUAL New Zealand, Policy NZ00031715-000) with $1M per claim and $2M aggregate coverage. Privacy breach incidents may be reported to our insurer as required by policy terms, with client notification provided according to legal requirements.
Export and International Services:
For international clients receiving our herbal products:
• Customs documentation may include product contents (without health information)
• International shipping providers receive only delivery information
• Virtual consultation records maintained within New Zealand privacy jurisdiction
• Cross-border privacy protection measures comply with HIPC Rule 12 requirements
Data Breach Response
In the unlikely event of a privacy breach:
• Immediate containment and assessment procedures
• Notification to affected clients within 72 hours where there is risk of harm
• Reporting to Privacy Commissioner as required by law
• Remedial action plan and prevention measures
• Support for affected clients including credit monitoring if appropriate
Cookies and Website Privacy
Essential Cookies
We use essential cookies for:
• Website functionality and navigation
• Secure appointment booking systems
• Shopping cart functionality for herbal products
• User session management
Analytics and Marketing
With your consent, we may use:
• Website analytics to improve user experience
• Email marketing tracking for newsletter engagement
• Social media integration for educational content sharing
You can manage cookie preferences through your browser settings or our website cookie consent tool.
Updates to This Policy
We review this privacy policy annually and update it to reflect:
• Changes in New Zealand privacy legislation
• Evolution of our services and technology
• Best practices in health information privacy
• Client feedback and regulatory guidance
This policy is reviewed annually as part of our regulatory compliance and audit cycle. It is updated in response to evolving legislation, industry standards, and internal data protection practices.
Significant changes will be communicated through:
• Email notification to registered clients
• Website announcements
• Notice during consultation appointments
• Updated effective date on this policy
Contact Information and Complaints
Privacy Enquiries
Nine Cups Privacy Officer
Email: info@nine-cups.com
Address: 8b Saturn Place, Rosedale, Auckland,0632
Phone: +64 210 828 3825
External Complaints
If you are not satisfied with our response to privacy concerns:
Office of the Privacy Commissioner
Website: privacy.org.nz
Phone: 0800 803 909
Email: enquiries@privacy.org.nz
Professional Body Complaints
As natural health practitioners, we are also accountable to relevant professional bodies for ethical practice standards.
Acknowledgement: This privacy policy reflects our commitment to protecting your personal and health information whilst providing exceptional natural health practitioner services. We welcome feedback on how we can continue improving our privacy practices.
Languages: This policy is available in multiple languages upon request to accommodate our diverse Auckland community.
Professional Standards: This policy supports our commitment to evidence-based natural health practice, cultural sensitivity, and the highest standards of professional wellness care within New Zealand’s natural health practitioner framework.
Marketing Compliance
Nine Cups adheres to the separation between general wellness marketing and therapeutic guidance as required under Section 32 of the Medicines Act 1981 and Medicines Regulations 1984. Therapeutic claims are only discussed in the context of private consultations. No public-facing materials (websites, social media, printed collateral) include unapproved therapeutic claims. All herbal teas are marketed as general wellness support without therapeutic claims outside professional consultation.
