CoachMi Privacy Policy

Last Updated: September 2026 Effective Date: [25th September 2026] Jurisdiction: India

TABLE OF CONTENTS

1. Introduction & Scope

2. Information We Collect

3. How We Use Your Information

4. Legal Basis for Processing

5. Data Sharing & Third Parties

6. Children's Data

7. Your Rights & Choices

8. Data Security

9. Data Retention & Deletion

10. International Data Transfers

11. Cookies & Tracking Technologies

12. Contact & Grievance Redressal

1. INTRODUCTION & SCOPE

1.1 About This Policy

This Privacy Policy explains how CoachMi ("we," "us," "our") collects, uses, discloses, and protects information when you use the CoachMi Platform (including the User App, Partner App/GoChat, Web Admin Dashboard, and related services).

1.2 Legal Framework

CoachMi complies with:

• Information Technology Act, 2000 (India)

• Information Technology Rules, 2000 (India), including Data Protection Rules

• Applicable Indian Data Protection Standards (privacy and security)

• *Industry best practices* for personal data protection

1.3 Who We Are

SportOdyssey Pvt. Ltd. Address: [91 SPRINGBOARD BUSINESS, 74 TECHNO PARK 74 II,C, Chakala Midc, Mumbai, Mumbai- 400093, Maharashtra] Email: admin@coachmi.com Phone: [7208007548]

Data Protection Officer: [Name & Email]

1.4 Your Consent

By using CoachMi, you consent to the collection, use, and disclosure of your information as described in this Policy. If you do not agree, please do not use CoachMi.

2. INFORMATION WE COLLECT

2.1 Information You Provide Directly

Account Registration:

• Name, email address, phone number

• Date of birth (if registering as student)

• Gender (optional)

• State/city of residence

• Profile photo (optional)

• Password (encrypted)

Parent/Guardian Account:

• Parent's name, email, phone number

• Student's name, age, date of birth, gender

• Student's sports interests

• Emergency contact information

Academy Owner Account:

• Academy name, registration number, address

• Academy owner's name, email, phone number

• GST registration number (if applicable)

• Bank account details (for payment settlement)

• Business license or certificate

Coach Account:

• Coach's name, phone, email address

• Years of experience

• Sports expertise and specializations

• Certifications and qualifications

• Achievement history

• Bio and photo

Nutritionist Account:

• Full name, license number, qualifications

• Specializations and certifications

• Contact details

• Professional credentials

• Bank account (for payment)

2.2 Health & Nutrition Data

When using nutrition services or fitness assessments:

Health Intake Information:

• Current weight, height, BMI

• Medical conditions and diagnoses

• Allergies and food restrictions

• Medications and supplements

• Recent blood work or health reports

• Fitness level and exercise history

• Dietary preferences (vegetarian, vegan, religious, ethical)

• Weight loss/muscle gain goals

Meal Tracking Data:

• Photos of meals

• Meal descriptions and ingredients

• Portion sizes

• Timing of meals

• Daily nutrient intake (macros & micros)

• Adherence to meal plan

Fitness Assessment Data:

• Beep Test results (level, shuttle, time, VO2max)

• Age and gender (for fitness norms)

• Assessment date and location

• Coach's observations or notes

• Historical fitness test results

2.3 Academic & Performance Data

For Students:

• Batch/class enrollment and progress

• Attendance records

• Performance assessments (Beep Test, learning pathways)

• Video recordings of sessions (if applicable)

• Coaching notes and observations

• Progress reports and feedback

• Leaderboard rankings and statistics

For Coaches:

• Sessions conducted (date, time, batch/student)

• Session notes and observations

• Student performance feedback

• Match records and tournament results

2.4 Video Content

• Coach intro videos (1080×1080, profile videos)

• Training or coaching session recordings

• Match or tournament videos

• Student performance videos

• User-uploaded photos and videos

2.5 Payment & Transaction Data

• Payment method (card, UPI, wallet used)

• Transaction amounts and dates

• Invoice details

• Subscription plan and billing cycle

• Refund or dispute records

• Card last 4 digits (NOT full card number)

• GST invoices and tax information

2.6 Communications & Support

• Email messages, chat conversations

• Support tickets and complaints

• Feedback and reviews (ratings, comments)

• Survey responses

• Messaging between users (parents, coaches, students)

2.7 Device & Usage Information

Device Information:

• Device type (iOS, Android, web)

• Operating system version

• Device identifiers (UDID, IMEI)

• IP address

• Browser type

Usage Information:

• Pages or features accessed

• Time spent on Platform

• Clicks, taps, and interactions

• Features used

• Content viewed

• Search queries

• Error logs and crash reports

2.8 Location Information

Collected Through:

• GPS/location services (if enabled on your device)

• IP address geolocation

• Manually provided address/city

Used For:

• Showing nearby facilities and services

• Connecting coaches and users in your area

• Rental booking location identification

3. HOW WE USE YOUR INFORMATION

3.1 Providing Services

We use your information to:

• Create and manage your account

• Process bookings and subscriptions

• Deliver coaching, nutrition, and fitness services

• Generate progress reports and assessments

• Track attendance and performance

• Calculate fitness metrics (VO2max, etc.)

• Create leaderboards and rankings

• Process payments and settle fees to service providers

3.2 Communication

We use your information to:

• Send you account notifications (booking confirmations, reminders, updates)

• Respond to your customer support requests

• Send administrative messages (policy changes, account alerts)

• Send marketing communications (newsletters, promotions) — with your consent only

• Notify parents/guardians of student progress

3.3 Service Improvement

We use your information to:

• Analyze usage patterns and Platform performance

• Identify and fix bugs and technical issues

• Develop new features and improvements

• Conduct research on sports training and fitness

• Generate anonymous statistical reports

• Train machine learning models (on anonymized data only)

3.4 Safety & Compliance

We use your information to:

• Detect fraud, abuse, or policy violations

• Verify user identity and prevent unauthorized access

• Comply with legal obligations and law enforcement requests

• Enforce our Terms of Use

• Investigate complaints or disputes

• Maintain audit trails and security logs

3.5 Sharing With Relevant Stakeholders

Academy Owners can see:

• Student roster and enrollment status

• Student attendance and progress

• Student performance assessments

• Batch and coach schedules

Parents/Guardians can see:

• Student's progress and assessments

• Coaching notes and feedback

• Attendance and attendance records

• Performance reports and videos

Coaches can see:

• Student roster in their assigned batch

• Student attendance

• Student performance history

• Leaderboards and rankings

• Booking and scheduling information

Nutritionists can see:

• Client's health intake information

• Meal logging and adherence

• Health history and medical notes

• Personalized meal plans they created

4. LEGAL BASIS FOR PROCESSING

4.1 Contract Performance

We process your information to perform our agreement with you:

• Creating accounts and managing subscriptions

• Processing payments and refunds

• Providing coaching, nutrition, and assessment services

• Fulfilling booking requests

4.2 Legitimate Interests

We process your information for legitimate business purposes:

• Improving our services and user experience

• Conducting analytics and market research

• Detecting fraud and ensuring platform security

• Complying with legal and regulatory obligations

• Enforcing our Terms and policies

4.3 Consent

For certain processing, we ask for your explicit consent:

• Marketing communications

• Health data processing (nutrition & fitness)

• Video recording and publishing

• Leaderboard & ranking display

You can withdraw consent anytime via account settings or by contacting us.

4.4 Legal Obligation

We process your information to comply with laws:

• Tax authorities (GST, income tax)

• Law enforcement and court orders

• Financial and banking regulations

• Consumer protection laws

• Anti-fraud and anti-money laundering laws

5. DATA SHARING & THIRD PARTIES

5.1 Service Providers & Partners

We share information with third-party providers who assist us:

Payment Processing:

• Razorpay (payment gateway): Payment details, transaction information, refund data

Cloud Storage & Hosting:

• Google Cloud or other cloud providers: All user data (encrypted)

Video & Communications:

• Zoom (if used for nutritionist intake calls): Names, email, meeting recordings

• Twilio or similar (SMS/notifications): Phone number, message content

Analytics & Monitoring:

• Google Analytics or similar: Usage data, device info, IP address

• Error tracking services: Crash reports, error logs

Communication & Support:

• Email service providers: Email address, messages

5.2 Legal Requirements & Enforcement

We may disclose information if required by law:

• Court orders or legal judgments

• Subpoena or official investigation

• Law enforcement requests (police, CBI, etc.)

• Tax authority requests (income tax, GST)

• Child safety concerns (reporting suspected abuse)

5.3 Business Transfers

If CoachMi is:

• Merged with another company

• Acquired or sold

• Undergoes bankruptcy or asset sale

Your information may be transferred as part of that transaction (with notice provided).

5.4 Aggregate & Anonymized Data

We may share anonymized, aggregate data publicly:

• "₹X million in subscriptions in Month Y"

• "Average student fitness levels by age group"

• "Sports participation trends in India"

• Statistical reports and research papers

This data cannot identify individuals.

5.5 No Sale of Personal Data

We do NOT sell your personal information to marketers, advertisers, or third parties for profit. Your information is used only as described in this Policy.

6. CHILDREN'S DATA

6.1 Age Restrictions

• CoachMi is NOT intended for children under 6 years old

• Students under 18 must have parent/guardian account with parental consent

• Parents are responsible for student's use of CoachMi

6.2 Parental Rights

Parents/guardians of students under 18 have the right to:

• Access their student's information

• Request deletion of student's data

• Restrict how student data is used

• Withdraw consent for marketing or data processing

• Request we contact them (not the student) regarding data

6.3 Student Data Protection

• Student information is never shared with third parties for marketing

• Photos/videos of students are only shared with authorized parents/coaches

• Student's full name may be withheld from leaderboards (at parent request)

• Health data is strictly confidential (nutritionist and coaches only)

7. YOUR RIGHTS & CHOICES

7.1 Right to Access

You have the right to:

• Request a copy of all your personal information we hold

• Know what information we collect and why

• Know how long we keep your information

To request: Email admin@coachmi.com with "Data Access Request" Timeline: Provided within 30 days

7.2 Right to Rectification

You have the right to:

• Correct inaccurate or incomplete information

• Update your account details

• Edit health data or personal information

To request: Use account settings or email admin@coachmi.com Timeline: Corrected within 5 business days

7.3 Right to Deletion ("Right to Be Forgotten")

You have the right to request deletion of your data, with exceptions:

Can be deleted:

• Account and personal details

• Health intake information

• Meal logs and nutritional data

• Non-essential performance data

Cannot be deleted (legal requirement):

• Payment and transaction records (tax compliance, 7 years)

• Attendance records (if student in batch program)

• Academic progress records (if Academy Owner requests retention)

• Court-ordered or legally required records

To request: Email admin@coachmi.com with "Data Deletion Request" Timeline: Processed within 30 days (non-legally required data)

7.4 Right to Restrict Processing

You can request we restrict (pause) processing of your data:**

• For marketing and promotions (opt-out)

• For analytics and improvement (opt-out)

• For leaderboard/public display (opt-out)

To request: Email admin@coachmi.com Timeline: Honored within 5 business days

7.5 Right to Data Portability

You have the right to:

• Download your data in a common, portable format (CSV, PDF)

• Transfer your data to another platform

• Know what data we hold in a machine-readable format

To request: Email admin@coachmi.com with "Data Portability Request" Timeline: Provided within 30 days

7.6 Right to Withdraw Consent

If you gave consent for processing, you can withdraw it at any time:

• Marketing and promotional emails (click unsubscribe)

• Health data processing (opt-out in account settings)

• Video recording and storage

• Location data (disable in device settings)

Withdrawal doesn't affect data processed before withdrawal.

7.7 No Automated Decision-Making

CoachMi does NOT make automated decisions that significantly affect you (e.g., account suspension, service termination). Decisions are made by humans after review.

8. DATA SECURITY

8.1 Security Measures

We implement industry-standard security practices:

Technical Controls:

• Encryption in transit: TLS/SSL encryption for all data transmitted

• Encryption at rest: Sensitive data encrypted in databases

• Access controls: Role-based permissions; employees can only access necessary data

• Firewalls & intrusion detection: Monitor and block unauthorized access

• Regular backups: Daily backups with encrypted storage

• Security updates: Regular patching and vulnerability management

Administrative Controls:

• Employee training: All staff trained in data protection and confidentiality

• Non-disclosure agreements: Staff sign confidentiality agreements

• Background checks: Employees vetted before access to data

• Audit trails: Logging of all data access for monitoring

Physical Controls:

• Secure data centers: Controlled access, surveillance, climate control

• Device security: Passwords, encryption, auto-lock policies

8.2 Limitations on Security

While we implement security, no system is 100% secure. Risks include:

• Hacking or unauthorized access despite security measures

• Insider threats (employee or contractor misconduct)

• Malware or ransomware attacks

• Data breaches despite best efforts

• Device theft or loss (if your device is compromised)

You are responsible for:

• Protecting your password

• Enabling two-factor authentication (if available)

• Securing your device

• Logging out on shared devices

8.3 Breach Notification

If a data breach occurs:

• We will notify affected individuals without undue delay (within 72 hours)

• Notice will include breach description, data affected, and recommendations

• We will report to authorities if legally required

• We will provide credit monitoring or identity theft protection (if appropriate)

9. DATA RETENTION & DELETION

9.1 Retention Schedule

9.2 Deletion Process

When data is deleted:

1. Removed from active systems within 7 business days 2. Removed from backup systems within 30 days

3. Permanently destroyed (not recoverable)

4. Confirmation provided to user upon request

9.3 Data Retention for Legal Compliance

We may retain data longer than above periods if:

• Required by law (tax, legal hold, court order)

• Necessary for ongoing litigation or investigation

• Necessary to establish, exercise, or defend legal claims

• Anonymized for research or analytics

10. INTERNATIONAL DATA TRANSFERS

10.1 Data Location

Your data is stored in India (primarily in data centers located in India):

• Primary cloud: Google Cloud or similar, with servers in India

• Backup systems: Also located in India when possible

10.2 Transfer Restrictions

CoachMi does NOT intentionally transfer personal data outside India except:

• If legally required by court order or government request

• For cloud service providers that may replicate data across regions (only for backup)

• If user explicitly consents to international transfer

10.3 Your Consent

By using CoachMi, you acknowledge:

• Your data may be processed in India

• Cloud providers may have data centers globally

• You consent to necessary data transfers for service provision

11. COOKIES & TRACKING TECHNOLOGIES

11.1 Cookies Used

Essential Cookies:

• Session cookies (allow you to stay logged in)

• Security cookies (CSRF protection, fraud detection)

• Preference cookies (remember your language or settings)

Analytics Cookies:

• Google Analytics (tracks usage patterns, page views)

• Error tracking (monitors crashes and bugs)

No cookies are used for third-party advertising on CoachMi.

11.2 Cookie Management

You can:

• Disable cookies in your browser settings (may affect functionality)

• Delete cookies after each session

• Use privacy mode/incognito (cookies not saved)

• Opt-out of analytics via Google Analytics opt-out extension

11.3 Third-Party Cookies

CoachMi does NOT use third-party cookies for tracking or advertising.

12. CONTACT & GRIEVANCE REDRESSAL

12.1 Data Protection Officer

For privacy questions or complaints, contact:

Email: privacy@coachmi.com Address: CoachMi Sports Technology Pvt. Ltd., [Office Address], Mumbai, India Phone: [9702105269]

12.2 Grievance Redressal Process

1. Submit complaint via email or support form with details

2. Acknowledgment: We'll acknowledge within 3 business days 3. Investigation: We'll investigate and gather information (up to 30 days) 4. Response: We'll provide detailed response and resolution (within 30 days) 5. Appeal: If unsatisfied, you can escalate to the Data Protection Officer

12.3 Legal Remedies

If you believe CoachMi has violated your data protection rights, you have the right to:

• File a complaint with the Ministry of Electronics & Information Technology (India)

• Pursue legal action under Information Technology Act, 2000

• Seek compensation for damages or losses

13. POLICY UPDATES

13.1 Changes to This Policy

CoachMi may update this Policy at any time. Changes are:

• Posted on the CoachMi Platform with effective date

• Effective immediately upon posting (or 30 days for material changes)

• Your continued use = acceptance of updated Policy

13.2 Notification of Changes

For material changes:

• Email notification to registered email address

• In-app notification banner

• SMS alert (if enabled)

ACKNOWLEDGMENT

By using CoachMi, you acknowledge:

1. You have read and understood this Privacy Policy 2. You consent to the collection and use of information as described 3. You understand your rights and choices regarding your data 4. You accept this Policy as binding on you

If you do NOT agree, please discontinue use of CoachMi.

END OF PRIVACY POLICY

*Version: 1.0* *Last Updated: September 2026* *Jurisdiction: India*