Privacy policy

Last updated 13 May 2025

1. Introduction

Naturally Pri LLC, trading as “Priya Holistic Wellness” (“NP/PHW”, “we”, “us”, “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard personal information when you visit
www.priyaholisticwellness.com (the “Site”), enrol in our online courses hosted on Kajabi, or otherwise interact with us. It also sets out your rights under the United Arab Emirates Federal Decree‑Law No. 45 of 2021 on the Protection of Personal Data (“UAE PDPL”) and, where relevant, the EU / UK General Data Protection Regulation (“GDPR”).

2. Personal Information We Collect

We collect and process the following categories of personal information:

Device & Usage Data: IP address, browser type, device identifiers, referring pages, time‑zone, cookie identifiers, pages viewed, links clicked, and session duration.
Account & Course Data: name, email, password, profile photo, course progress, quiz scores, and certificates earned.
Transaction Data: billing name, address, email, telephone, partial payment card information, order history, and VAT/tax ID (if applicable).
Communications: emails, messages, survey responses, support tickets, webinar or coaching call recordings.
Marketing Preferences: newsletter opt‑in/out, cookie‑consent choices, and advertisement interaction data.

We do not intentionally collect information from anyone under 16. If you believe a child has provided us personal data, please email [email protected] and we will delete it promptly.

3. How We Use Your Information

We process personal information only when a lawful basis applies, including consent, performance of a contract, compliance with legal obligations, protection of vital interests, tasks carried out in the public interest, or our legitimate interests (which do not override your rights and freedoms).

4. Sharing Personal Information

We share personal information with carefully selected service providers who help us operate our business. These providers are contractually bound to safeguard your data:

Kajabi, LLC – course hosting, video streaming, and analytics (USA).
Stripe, Inc. – secure payment processing and strong customer authentication (USA/EU). Payments on the Site are processed through Stripe; we never store your full card details.
Calendly, LLC – scheduling private coaching calls (USA).
Google Analytics – website analytics (IP anonymisation enabled).
Meta Ads & Google Ads – targeted advertising (cookie‑based, subject to your consent).

We will also disclose data if required by UAE or other applicable law, court order, or to protect our legal rights.

5. International Transfers

Our primary servers are located in the United States (Kajabi & Stripe). Where data is transferred outside the UAE, EEA, or UK, we rely on Standard Contractual Clauses (SCCs), adequacy decisions, or your explicit consent.

6. Retention

We retain personal information only as long as necessary for the purposes described in this Policy:

Course and account data: until you delete your account or seven (7) years after your last purchase to meet accounting obligations.
Marketing data: until you opt‑out or two (2) years after your last interaction, whichever is sooner.
Cookies: see Section 8 for specific lifespans.

7. Your Rights

Depending on where you live, you may have rights to access, correct, delete, restrict, or object to certain processing of your personal data, as well as the right to data portability and to withdraw consent at any time. To exercise any rights, email [email protected]. We will respond within one calendar month (or 30 days under UAE PDPL).

9. Behavioural Advertising Opt‑Out

You may opt‑out of targeted advertising using the following links:

Google Ads: https://www.google.com/settings/ads/anonymous
Facebook / Instagram Ads: https://www.facebook.com/settings/?tab=ads
DAA Opt‑Out: http://optout.aboutads.info/

10. Security

We employ TLS encryption, encryption at rest, role‑based access controls, multi‑factor authentication, regular penetration testing, and incident‑response procedures aligned with ISO 27001 standards.

11. Automated Decision‑Making

Neither Kajabi nor NP/PHW engages in decisions based solely on automated processing that produce legal or similarly significant effects on you. Limited fraud‑prevention scoring by Stripe may occur before a transaction is accepted.

12. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will post the revised version with a new “Last updated” date and, where material, notify you by email or on the Site.

13. Contact Us

Naturally Pri LLC (trading as Priya Holistic Wellness)
Wadi Al Safa 3, Al Barari, Jasmine Leaf 5, Villa 10
Dubai, United Arab Emirates

Email: [email protected]

If you are unsatisfied with our response, you may lodge a complaint with the UAE Data Office or, if you reside in the EEA/UK, with your local supervisory authority.