Privacy Policy

Effective Date: September 23rd, 2026

1. INTRODUCTION

Joya ("Joya," "we," "our" or "us") respects your privacy and is committed to protecting the personal information entrusted to it.

This Privacy Policy explains how we collect, use, disclose, retain and protect your personal information when you visit joya.center (the "Website"), create an account, become a Member, participate in the Joya Community, register for or participate in our Services, communicate with us or otherwise interact with Joya.

Our Services may include memberships, meditation sessions, community features, private programs, personal guidance, workshops, events, retreats, corporate programs, educational resources and digital content.

We seek to collect only the personal information that is reasonably necessary for legitimate and appropriate purposes connected with our Services and operations.

Joya's processing of your personal information is subject to applicable privacy laws, including Quebec's Act respecting the protection of personal information in the private sector.

2. ACCOUNTABILITY FOR PERSONAL INFORMATION

Joya is responsible for the personal information under its control.

The person exercising the highest authority within Joya is responsible for the protection of personal information unless that responsibility has been delegated in writing in accordance with applicable law.

Our Privacy Officer oversees Joya's privacy practices, including requests concerning personal information and privacy-related questions or complaints.

Joya

Email: info@joya.center

Website: joya.center

3. PERSONAL INFORMATION WE MAY COLLECT

The personal information we collect depends on how you interact with Joya and the Services you use.

We may collect the following categories of information:

Identification and Contact Information

• name;

• email address;

• telephone number;

• mailing or billing address, when necessary;

• other contact details that you choose to provide.

Account and Membership Information

• account credentials;

• profile information;

• details relating to a Membership or Program;

• registration information;

• membership status;

• preferences;

• registrations for classes, events or sessions;

• participation history;

• information related to your use of Membership or Community features.

Transaction Information

• purchases;

• amounts paid;

• billing status;

• transaction history;

• refunds or credits;

• information reasonably necessary to administer payments.

Payment card information is generally processed directly by third-party payment service providers. Joya does not intend to retain full payment card numbers.

Communications and Community Content

• emails, messages and other communications you send to us;

• support requests;

• survey responses;

• feedback;

• testimonials when you submit them voluntarily;

• comments, posts, images or other content you choose to share in Joya's community spaces;

• communications related to your participation in our Services.

Program and Well Being Information

When relevant to a Service and voluntarily provided by you, we may collect information concerning:

• your goals;

• your habits;

• your meditation experience;

• your preferences;

• your well-being;

• your lifestyle;

• concerns relevant to your participation;

• other information shared during onboarding, private sessions, Programs, workshops or related Services.

Some of this information may constitute sensitive personal information, depending on its nature and context. We seek to limit the collection of sensitive information to what is reasonably necessary for the relevant Service.

Appointment and Participation Information

• appointment history;

• scheduling information;

• cancellations;

• participation in sessions, events or Programs;

• related administrative records.

Audio and Video Recordings and Photographs

Certain classes, workshops, community sessions or events may be photographed or recorded.

When personal information is collected through a recording or photograph, Joya will provide appropriate notice and obtain any consent required by applicable law.

Private or personalized guidance sessions will not be recorded unless you have been informed in advance and have provided your consent.

Technical and Website Information

Depending on your choices and the technologies used on our Website or platforms, we may collect:

• IP address;

• browser type;

• device type;

• operating system;

• pages viewed;

• referring pages;

• dates and times of visits;

• cookie identifiers or similar technologies;

• information about your interactions with our Website and digital Services.

4. HOW WE COLLECT PERSONAL INFORMATION

We may collect personal information:

Directly from You

For example, when you:

• complete a form;

• subscribe to our newsletter;

• create an account;

• purchase a Membership or another Service;

• register for an event;

• book an appointment;

• participate in a Program or the Community;

• communicate with us;

• voluntarily provide information during a session or onboarding process.

Automatically Through Technology

Certain information may be collected through cookies, analytics tools, server logs and similar technologies when you use our Website or digital Services, subject to your choices and applicable law.

From Service Providers or Other Third Parties

We may receive information from service providers involved in delivering our Services, including payment, community, scheduling, website or registration platforms.

We may also collect information from another source when you have consented to the collection or when it is otherwise permitted by law.

5. PURPOSES FOR WHICH WE USE PERSONAL INFORMATION

We may use your personal information to:

• provide, administer and improve our Services;

• create and manage accounts;

• administer Memberships and subscriptions;

• operate Community features;

• register Participants for classes, events, workshops or retreats;

• provide meditation sessions, Programs and other Services;

• personalize certain Services when appropriate;

• schedule and administer appointments;

• process transactions and maintain related records;

• provide support and respond to inquiries;

• communicate important information about your account, Membership, purchases or Services;

• provide the educational resources and content you request;

• manage cancellations, refunds and billing matters;

• maintain the security, integrity and proper functioning of our Community;

• prevent fraud, abuse or unlawful activity;

• maintain business, tax, accounting and legal records;

• protect Joya, our Members, our Participants and other persons;

• comply with applicable laws and legal obligations;

• understand and improve the operation and performance of our Website and Services;

• fulfil other purposes disclosed to you at or before the time of collection.

Where required by law, we will obtain your consent before using your personal information for a new purpose that is incompatible with the purpose for which it was originally collected.

6. CONSENT AND YOUR CHOICES

Where consent is required, Joya seeks to obtain valid consent under applicable law that is appropriate to the nature and degree of sensitivity of the personal information concerned.

You may withdraw your consent to certain uses or disclosures of your personal information, subject to applicable legal or contractual restrictions.

Withdrawing your consent may affect our ability to provide a Service when the personal information concerned is necessary to deliver that Service.

You may contact our Privacy Officer at info@joya.center to ask a question about consent or to withdraw it, where applicable.

7. NEWSLETTERS AND MARKETING COMMUNICATIONS

Where you have consented, or where otherwise permitted by applicable law, Joya may send you:

• newsletters;

• educational content;

• information about upcoming events;

• Joya news and updates;

• other promotional communications.

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

Unsubscribing from marketing communications does not prevent us from sending transactional or Service-related communications that are necessary, including purchase confirmations, account notices or important information about your Membership.

Our commercial electronic messaging practices are also subject to applicable Canadian anti-spam requirements.

8. COOKIES ANALYTICS TOOLS AND SIMILAR TECHNOLOGIES

Our Website and digital Services may use cookies and similar technologies, including to:

• enable essential Website functionality;

• maintain security;

• remember settings or preferences;

• understand Website performance;

• measure Website traffic;

• understand how visitors interact with the Website;

• improve our Website and Services.

Certain technologies may include functions that identify a visitor, track the visitor's activities or create a profile of the visitor's interests or behaviour.

When applicable law requires these functions to be optional, they will not be enabled by default. You will be given a means to enable or consent to them.

You may also be able to manage certain cookies through our consent tools or your browser settings.

Disabling certain cookies may interfere with the operation of some Website features.

Joya does not intend to collect precise geolocation data through the Website unless the collection is expressly disclosed to you and, where required, enabled or authorized by you.

9. DISCLOSURE OF PERSONAL INFORMATION

Joya does not sell or rent your personal information.

We may disclose personal information when reasonably necessary to deliver or operate our Services, including to the following categories of service providers:

• payment service providers;

• web hosting and infrastructure providers;

• community platforms;

• scheduling and booking platforms;

• videoconferencing providers;

• email and communications service providers;

• cloud storage and data hosting providers;

• analytics and web service providers;

• customer support or operations software providers;

• professional advisers, including lawyers, accountants and other consultants.

Service providers receive only the information reasonably necessary to perform the services they provide on our behalf.

Where required by law, Joya uses contractual or other measures designed to require its service providers to protect personal information and use it only for authorized purposes.

We may also disclose personal information:

• with your consent;

• where required or permitted by law;

• in connection with legal proceedings or lawful requests;

• when reasonably necessary to protect the rights, security or safety of Joya or another person;

• in connection with a business transaction when permitted by law and subject to applicable safeguards.

10. PROCESSING AND STORAGE OUTSIDE QUEBEC

Some service providers used by Joya may process, host or store personal information outside Quebec, including elsewhere in Canada or in other countries.

As a result, your personal information may be subject to the laws of the jurisdiction in which it is processed or stored and may, where permitted by law, be accessible to the courts, law enforcement agencies or government authorities of that jurisdiction.

Before disclosing personal information outside Quebec, Joya will conduct the assessment required under applicable Quebec privacy laws and implement appropriate safeguards where required.

We seek to work with service providers whose privacy and security practices are appropriate having regard to the nature of the information concerned.

11. RETENTION AND DESTRUCTION

Joya retains personal information only for as long as reasonably necessary for the purposes for which it was collected, subject to applicable legal, contractual, tax, accounting and regulatory requirements.

Retention periods may vary depending on:

• the type and degree of sensitivity of the information;

• the Service concerned;

• the purpose for which the information is held;

• applicable legal requirements;

• the need to establish, exercise or defend rights.

Once the purposes for which personal information was collected or used have been fulfilled and any applicable retention period has expired, Joya will securely destroy the information or anonymize it where permitted and appropriate under applicable law.

De-identified information that can still be associated with an individual will continue to be treated as personal information where required by law.

12. SECURITY

Joya maintains administrative, technical and organizational safeguards designed to protect personal information against loss, theft, unauthorized access, use, disclosure, modification and other breaches of confidentiality.

The safeguards used depend in particular on the sensitivity, quantity, purpose, distribution and medium of the information.

Access to personal information within Joya is limited to persons who reasonably require it in the performance of their duties.

Despite our safeguards, no electronic system, transmission method or storage medium can be guaranteed to be entirely secure.

13. PRIVACY INCIDENTS

Joya maintains procedures for responding to privacy incidents involving personal information.

When Joya becomes aware of an incident, we will take reasonable measures to reduce the risk of harm and prevent similar incidents from occurring.

When an incident presents a risk of serious injury, Joya will notify the Commission d'accès à l'information du Québec and the individuals concerned in accordance with applicable legal requirements.

Joya also maintains a register of privacy incidents in accordance with applicable Quebec legal requirements.

14. YOUR PRIVACY RIGHTS

Subject to the conditions and exceptions provided by applicable law, you may have the following rights:

Access

Request access to the personal information Joya holds about you.

Correction

Request the correction of personal information that is inaccurate, incomplete or equivocal.

Withdrawal of Consent

Withdraw your consent to certain uses or disclosures of personal information when consent is the applicable basis for the activity, subject to legal or contractual restrictions.

Data Portability

Request that eligible computerized personal information collected from you be provided to you in a structured and commonly used technological format and, in certain circumstances, that it be communicated to an authorized person or organization.

Cessation of Dissemination or De Indexing

In the circumstances provided by applicable Quebec law, request that Joya cease disseminating certain personal information or de-index a hyperlink associated with your name that provides access to personal information.

Automated Decisions

If Joya uses personal information to make a decision based exclusively on automated processing, you are entitled to the information and review mechanisms provided by applicable law, including the opportunity to submit observations to a person who is in a position to review the decision.

Questions and Complaints

Ask questions or submit a complaint about how Joya handles your personal information.

Requests must be submitted in writing to our Privacy Officer:

info@joya.center

We may request information reasonably necessary to verify your identity before responding to a privacy request.

Joya will respond to access and correction requests within the time limits prescribed by applicable law. For businesses subject to the applicable Quebec private-sector law, the applicable period is generally 30 days after receipt of the request.

When Joya refuses a request, in whole or in part, we will provide the information and recourse guidance required by applicable law.

15. CHILDREN AND MINORS

Joya does not knowingly collect personal information directly from a child under 14 years of age without the consent of a parent or person having parental authority, except where the collection is otherwise permitted by applicable law.

If Joya offers Services intended for minors, we will implement consent and privacy practices appropriate to their age and to applicable legal requirements.

If you believe that a child has provided personal information to Joya contrary to this Policy or applicable law, please contact our Privacy Officer.

16. THIRD PARTY WEBSITES AND SERVICES

Our Website or Services may contain links to, integrate with or rely on third-party websites, applications or platforms.

These third parties may process personal information in accordance with their own privacy policies and terms of use.

This Privacy Policy applies to personal information under Joya's control. It does not govern the independent practices of third parties when they determine the purposes and means of processing themselves.

We encourage you to review the privacy practices of the third-party services you choose to use.

17. PERSONAL INFORMATION GOVERNANCE

Joya maintains policies and practices designed to govern the protection of personal information throughout its life cycle.

These practices include:

• roles and responsibilities relating to personal information;

• access to personal information;

• retention and secure destruction;

• management of privacy incidents;

• handling privacy requests and complaints;

• agreements with service providers;

• privacy assessments where required;

• safeguards appropriate to the nature of the information we hold.

Additional information about Joya's privacy governance practices may be requested from our Privacy Officer.

18. CHANGES TO THIS PRIVACY POLICY

Joya may update this Privacy Policy from time to time to reflect changes to our Services, technologies, privacy practices, service providers or applicable legal requirements.

The most recent version will be posted on joya.center and will indicate its effective date.

Where required by applicable law, we will provide appropriate notice of any material change and obtain any required consent.

19. PRIVACY INQUIRIES AND COMPLAINTS

For any question, request or complaint concerning this Privacy Policy or Joya's personal information protection practices, you may contact:

Joya

Website: joya.center

Email: hi@joya.center

We will review privacy requests and complaints in accordance with our obligations under applicable law.

If you are not satisfied with our response, you may have the right to contact or seek recourse from the Commission d'accès à l'information du Québec.