We propose a new conceptual model for XML data called XSEM as a combination of several approaches in the area of the conceptual modeling for XML. The model divides the conceptual modeling process of XML data to two levels. On the first level, a designer designs an overall non-hierarchical conceptual schema of a domain. On the second level, he or she derives different hierarchical representations of parts of the overall conceptual schema using transformation operators. These hierarchical representations describe how the data is organized in an XML form.