Politique de confidentialité

NAYA HEALING

Last updated: 2 October 2026

Naya Healing respects your privacy and is committed to handling personal information responsibly, securely and transparently.

This Privacy Policy explains how Naya Healing collects, uses, stores and discloses personal information when you:

  • visit or use https://nayahealing.me;

  • contact Naya Healing;

  • make an enquiry;

  • book or purchase a Service;

  • complete an intake or consent form;

  • participate in a session or programme; or

  • otherwise interact with Naya Healing in connection with its Services.

For the purposes of this Privacy Policy, “Naya Healing”, “we”, “us” and “our” means the sole trader operating under the Naya Healing trading name.

Naya Healing is established in the United Kingdom.

Where applicable, Naya Healing processes personal information in accordance with the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018, applicable electronic-communications and cookie rules, and, where the territorial scope of the relevant legislation applies, the EU General Data Protection Regulation (“EU GDPR”) and other applicable data-protection laws.

This Privacy Policy does not create contractual rights beyond those provided by applicable law.

1. DATA CONTROLLER

For data-protection purposes, the controller of personal information processed by Naya Healing is:

Trading name: Naya Healing
Legal structure: Sole trader
Email: naya@nayahealing.me
Website: https://nayahealing.me

Naya Healing is a trading name and is not a separate legal entity from the sole trader operating the business.

Depending on the particular processing activity, another organisation may act as an independent controller or processor of personal information. Examples may include payment providers, booking platforms and video-conferencing providers.

2. WHAT PERSONAL INFORMATION WE COLLECT

We aim to collect personal information that is relevant, proportionate and reasonably necessary for the purposes described in this Privacy Policy.

The information we may process includes the following.

2.1 Identity and contact information

This may include:

  • name;

  • email address;

  • telephone number;

  • postal or billing address;

  • age or date of birth where relevant;

  • country of residence or current location where relevant to the Service; and

  • information needed to identify or communicate with you.

2.2 Booking and service information

This may include:

  • appointment information;

  • Service purchased;

  • package information;

  • booking history;

  • cancellation or rescheduling information;

  • communications concerning the Service;

  • preferences relevant to the Service; and

  • information you voluntarily provide in connection with your sessions.

3. HEALTH, WELLBEING AND OTHER SPECIAL CATEGORY DATA

Some Services may involve Clients voluntarily providing information concerning their health, wellbeing or personal circumstances.

Depending on what you disclose, this may include information relating to:

  • physical health;

  • mental or emotional wellbeing;

  • stress or burnout;

  • trauma or difficult experiences;

  • neurodivergence;

  • disability;

  • medication or treatment information;

  • relevant personal circumstances; or

  • other information that qualifies as special category data under applicable data-protection law.

We do not seek to collect sensitive information merely because it is interesting or potentially useful. We seek to limit collection to information reasonably necessary for the relevant purpose.

Special category data is subject to additional legal protections under UK GDPR and, where applicable, EU GDPR. The lawful basis and additional Article 9 condition relied upon will depend on the particular processing activity and applicable law. Explicit consent may be used where appropriate and legally suitable. Other lawful conditions may apply where permitted by law.

Where Naya Healing relies upon explicit consent to process special category information, that consent will be obtained through an appropriate affirmative process separate from this Privacy Policy.

You may withdraw consent where processing is based on consent. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

Withdrawal of consent may mean that Naya Healing is unable to continue providing a Service where the relevant information is reasonably necessary for that Service.

4. PAYMENT AND FINANCIAL INFORMATION

When you purchase a Service, we may process information concerning:

  • transaction amount;

  • currency;

  • payment status;

  • invoice information;

  • billing information;

  • refunds; and

  • payment-provider transaction identifiers.

Payment-card information is generally processed directly by the relevant payment provider.

Unless expressly stated otherwise, Naya Healing does not intentionally store complete payment-card numbers or security codes.

Examples of payment providers may include Stripe, PayPal or another provider made available at checkout.

The relevant payment provider may process your information under its own privacy notice and terms.

5. TECHNICAL AND WEBSITE INFORMATION

When you use our Website, certain technical information may be collected automatically, depending on the Website configuration and technologies in use.

This may include:

  • IP address;

  • browser type;

  • operating system;

  • device information;

  • approximate location derived from technical information;

  • pages viewed;

  • referring pages;

  • timestamps;

  • Website interaction information;

  • security logs; and

  • information concerning cookies and similar technologies.

The exact information collected depends on the technical configuration of the Website.

We do not use this Privacy Policy to claim that a particular category of technical data is collected if the relevant technology is not actually enabled.

6. INFORMATION YOU PROVIDE DIRECTLY

We may receive personal information when you:

  • contact us by email;

  • complete an enquiry form;

  • book a Service;

  • complete an intake or consent form;

  • participate in a session;

  • communicate with us concerning a booking;

  • request a refund;

  • make a complaint;

  • subscribe to communications;

  • submit information through the Website; or

  • otherwise voluntarily provide information.

7. INFORMATION FROM THIRD PARTIES

We may receive limited information from third parties where reasonably necessary and lawful.

Examples may include:

  • payment providers;

  • booking platforms;

  • website or hosting providers;

  • professional advisers;

  • insurers;

  • authorised representatives;

  • parents or guardians where applicable;

  • referral sources where authorised; or

  • competent authorities where legally required.

We do not intentionally seek sensitive personal information from third parties unless there is a lawful and appropriate reason to do so.

8. WHY WE USE PERSONAL INFORMATION

Depending on the circumstances, we may process personal information for the following purposes:

  1. to respond to enquiries;

  2. to arrange and manage bookings;

  3. to provide and administer Services;

  4. to communicate about appointments;

  5. to process payments and refunds;

  6. to issue invoices and maintain financial records;

  7. to administer packages and subscriptions where applicable;

  8. to maintain appropriate business and service records;

  9. to address complaints;

  10. to protect the security of our Website, systems and Services;

  11. to prevent fraud, abuse or unlawful activity;

  12. to comply with legal, tax, accounting, insurance or regulatory obligations;

  13. to establish, exercise or defend legal claims;

  14. to address safeguarding or serious safety concerns;

  15. to administer professional supervision where applicable and lawful;

  16. to improve our Website and Services using appropriate information, including aggregated or anonymised information where reasonably possible; and

  17. to send marketing communications where we have a lawful basis to do so.

We do not sell or rent personal information to third parties for their own marketing purposes.

9. LAWFUL BASES FOR PROCESSING

Depending on the circumstances, Naya Healing may rely upon one or more of the following lawful bases under applicable data-protection law:

  • performance of a contract – for example, administering and providing Services you have purchased;

  • legitimate interests – for example, managing the business, maintaining security, preventing fraud, responding to enquiries or establishing and defending legal claims, where those interests are not overridden by applicable rights;

  • legal obligation – where processing is necessary to comply with a legal obligation;

  • consent – where we request consent and consent is the appropriate legal basis;

  • explicit consent – where required or appropriate for certain special category processing; and

  • vital interests or another legally recognised condition where applicable in exceptional circumstances.

The precise lawful basis depends upon the particular processing activity.

Where processing is based on consent, you may withdraw consent at any time. Withdrawal does not affect processing that was lawful before withdrawal.

10. SAFEGUARDING AND SERIOUS RISK

Naya Healing may process or disclose information where reasonably necessary to:

  • protect an individual from serious harm;

  • respond to an emergency;

  • address a safeguarding concern;

  • comply with a legal obligation;

  • respond to a lawful request from a competent authority; or

  • establish, exercise or defend legal rights.

We will seek to limit such processing and disclosure to what is reasonably necessary in the circumstances.

Naya Healing is not an emergency service and should not be relied upon for crisis response.

11. WHO WE MAY SHARE INFORMATION WITH

We may disclose limited personal information to organisations or individuals where reasonably necessary and lawful.

These may include:

Payment providers

For processing payments, refunds and transaction administration.

Booking and scheduling providers

For appointment management, reminders and related administration.

Video-conferencing providers

For the delivery of online sessions.

Website, hosting and security providers

For hosting, maintaining and securing the Website and related systems.

Email and communications providers

For sending administrative communications and, where applicable, marketing communications.

Professional advisers

This may include solicitors, accountants, insurers, professional advisers or other advisers where reasonably necessary.

Professional supervision

Where professional supervision is used, information will be limited and handled confidentially and lawfully, with anonymisation or pseudonymisation used where reasonably practicable.

Authorities and legal bodies

Information may be disclosed where required or permitted by law, including to courts, regulators, law-enforcement bodies or other competent authorities.

We do not authorise third-party providers to use personal information for their own unrelated purposes merely because they provide services to Naya Healing.

12. DATA PROCESSORS AND THIRD-PARTY PROVIDERS

Some organisations process personal information on our behalf.

Where required by applicable law, we will use appropriate contractual arrangements with processors and take reasonable steps to ensure that personal information is processed appropriately.

Third-party providers may process information in accordance with their own privacy notices where they act as independent controllers.

Examples of technology providers may include payment, booking, hosting, email, analytics and video-conferencing providers.

The actual providers used by Naya Healing may change over time.

Where appropriate, Clients should consult the privacy information of the relevant provider for further information about its own processing.

13. INTERNATIONAL DATA TRANSFERS

Naya Healing may use service providers located outside the United Kingdom or the EEA.

Where a transfer of personal information is subject to UK GDPR restricted-transfer rules, we will use an applicable lawful transfer mechanism, which may include:

  • a UK adequacy regulation;

  • an applicable adequacy decision;

  • the UK International Data Transfer Agreement (“IDTA”);

  • the UK Addendum to the EU Standard Contractual Clauses;

  • another legally recognised appropriate safeguard; or

  • a legally available derogation where the conditions for relying upon it are satisfied.

The appropriate mechanism depends on the particular recipient, country, data and legal circumstances. We do not represent that one transfer mechanism applies to every provider.

The UK currently recognises certain international transfer arrangements, including the UK Extension to the EU-US Data Privacy Framework for eligible participating US organisations. Where applicable, this may provide a lawful transfer mechanism without requiring additional safeguards.

Where an appropriate safeguard is used, additional transfer assessments or measures may be required. The ICO’s current guidance recognises the IDTA and UK Addendum as appropriate safeguards and requires appropriate assessment of restricted transfers.

For transfers from the EEA to the UK, the European Commission has renewed the EU adequacy decision for the UK.

14. RETENTION OF PERSONAL INFORMATION

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, subject to legal, regulatory, insurance, accounting and other legitimate requirements.

Retention periods may therefore vary according to the type of information.

Factors considered may include:

  • the nature of the information;

  • the purpose for which it was collected;

  • whether an ongoing relationship exists;

  • legal and regulatory requirements;

  • professional or insurance requirements;

  • limitation periods for potential legal claims;

  • safeguarding considerations; and

  • whether the information can reasonably be deleted or anonymised.

Naya Healing does not adopt a universal retention period merely because a particular period is common in another profession.

Specific retention periods may be documented internally in our records-retention procedures.

Where personal information is no longer required, we will take reasonable steps to delete, securely destroy or appropriately anonymise it.

15. CHILDREN AND YOUNG PEOPLE

Naya Healing may provide certain Services to children or young people where expressly offered.

Where a Client is a minor, additional safeguards may apply concerning:

  • parental responsibility;

  • consent;

  • safeguarding;

  • confidentiality;

  • communication;

  • access to information; and

  • disclosure.

The precise arrangements depend upon the Client’s age, maturity, location, the nature of the Service and applicable law.

Where processing is based upon consent, the applicable legal rules concerning children’s consent will be considered according to the relevant jurisdiction and type of service.

For example, the GDPR rules concerning children’s consent in relation to information-society services allow Member States to establish an age between 13 and 16 at which a child may consent independently; this does not create a universal age rule for every type of service.

Where appropriate, Naya Healing may require consent or authorisation from a parent, guardian or person with lawful parental responsibility.

16. COOKIES AND SIMILAR TECHNOLOGIES

The Website may use cookies and similar technologies.

These may include:

  • strictly necessary cookies;

  • security cookies;

  • functionality cookies;

  • preference cookies;

  • analytics cookies; and

  • other technologies used only where legally permitted.

The actual cookies used depend upon the technical configuration of the Website and the services integrated into it.

Where applicable law requires consent before non-essential cookies or similar technologies are used, we will request consent before activating those technologies.

You may also manage cookies through your browser settings.

Disabling certain cookies may affect Website functionality.

A separate Cookie Policy or cookie-management tool may provide further information about specific technologies used on the Website.

17. EMBEDDED THIRD-PARTY CONTENT

The Website may contain embedded content or links to third-party services, such as videos, social-media content, maps or other materials.

Third-party content may cause your browser or device to communicate with the relevant third party.

Those third parties may collect information in accordance with their own privacy policies.

Naya Healing does not control the privacy practices of independent third parties.

Where required, we will take appropriate measures before activating non-essential third-party technologies.

18. MARKETING

We may send marketing communications where we have a lawful basis to do so.

Where consent is required, we will obtain appropriate consent.

You may unsubscribe from marketing communications at any time by using the unsubscribe mechanism provided or by contacting us.

Administrative or transactional communications relating to Services, bookings, payments, security or legal matters are not necessarily marketing communications and may continue where necessary.

19. YOUR DATA PROTECTION RIGHTS

Depending on applicable law and the circumstances, you may have rights including:

  • the right to be informed;

  • the right of access;

  • the right to rectification;

  • the right to erasure;

  • the right to restrict processing;

  • the right to data portability;

  • the right to object to certain processing;

  • rights relating to automated decision-making and profiling where applicable; and

  • the right to withdraw consent where processing is based on consent.

These rights are not absolute.

For example, we may be required to retain certain information because of legal, accounting, insurance, professional, safeguarding or legal-claim requirements.

20. HOW TO EXERCISE YOUR RIGHTS

To exercise a data-protection right, contact:

Email: naya@nayahealing.me

Please provide sufficient information to allow us to identify you and understand the request.

Where reasonably necessary, we may request additional information to verify identity and protect personal information from unauthorised disclosure.

We normally respond to valid data-protection requests within one month.

Where permitted by applicable law, the response period may be extended where a request is particularly complex or multiple requests have been made.

Where an extension applies, we will inform you as required by law.

21. AUTOMATED DECISION-MAKING AND PROFILING

Naya Healing does not intend to make decisions producing legal or similarly significant effects about Clients solely through automated processing.

If this changes, we will provide additional information and apply any safeguards required by applicable law.

22. DATA SECURITY

We take reasonable technical and organisational measures designed to protect personal information against:

  • unauthorised access;

  • accidental loss;

  • destruction;

  • alteration;

  • unauthorised disclosure; and

  • other unlawful or unauthorised processing.

Depending on the systems used, security measures may include:

  • access controls;

  • strong passwords;

  • multi-factor authentication where available;

  • device security;

  • encrypted connections;

  • secure hosting;

  • restricted access;

  • backups; and

  • appropriate third-party security measures.

No internet transmission, electronic storage system or third-party technology can be guaranteed to be completely secure.

Accordingly, we do not promise absolute security.

23. DATA BREACHES

If Naya Healing becomes aware of a personal-data breach, we will assess the incident and take appropriate steps in accordance with applicable data-protection law.

Where notification to a supervisory authority or affected individuals is legally required, we will make the relevant notification within the applicable legal timeframe.

24. CONFIDENTIALITY

Privacy and confidentiality are related but distinct concepts.

Naya Healing will treat information received through the Services as confidential subject to:

  • applicable law;

  • safeguarding obligations;

  • serious risks of harm;

  • lawful requests from competent authorities;

  • legal claims;

  • professional or insurance requirements; and

  • other circumstances in which disclosure is legally required or permitted.

Further information concerning confidentiality may also be contained in the applicable Terms & Conditions or client consent documentation.

25. YOUR RESPONSIBILITY WHEN USING THIRD-PARTY SERVICES

Where you use a third-party platform to communicate with Naya Healing, including a video-conferencing, messaging or payment platform, that provider may process personal information under its own terms and privacy policy.

Naya Healing cannot control processing carried out independently by such third parties.

Clients should review the relevant provider’s privacy information where appropriate.

26. COMPLAINTS

If you have a concern about how Naya Healing processes your personal information, please contact us first:

Email: naya@nayahealing.me

We will consider the concern and attempt to resolve it appropriately.

You may also have the right to complain to a competent data-protection supervisory authority.

For UK GDPR matters, the relevant supervisory authority is generally the Information Commissioner’s Office (ICO).

If the EU GDPR applies to the relevant processing, you may also have the right to complain to an EU/EEA supervisory authority, including the authority in the jurisdiction in which you live, work or where the alleged infringement occurred.

27. INTERNATIONAL CLIENTS

Naya Healing accepts clients internationally where Services can lawfully and appropriately be provided.

Different data-protection laws may apply depending upon:

  • where Naya Healing is established;

  • where the Client is located;

  • whether Naya Healing offers goods or services to individuals in a particular jurisdiction;

  • whether Naya Healing monitors behaviour in a particular jurisdiction;

  • the nature of the processing;

  • the location of service providers; and

  • other factors established by applicable law.

The application of a particular jurisdiction’s data-protection legislation does not necessarily mean that all provisions of that legislation apply to every processing activity.

Naya Healing will seek to comply with mandatory data-protection obligations that apply to its processing.

28. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in:

  • our Services;

  • technology;

  • third-party providers;

  • legal requirements;

  • data-protection practices; or

  • other relevant circumstances.

The updated version will be published on the Website with a revised “Last updated” date.

Where required by law, we will provide additional notice concerning material changes.

29. CONTACT

Naya Healing
Independent sole-trader business
Royaume-Uni

Email: naya@nayahealing.me
Website: https://nayahealing.me

Last updated: 1 October 2026