Applicable law: This policy is drafted in compliance with India's Digital Personal Data Protection Act, 2023 (DPDP Act) and the Digital Personal Data Protection Rules, 2025, as well as the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 under the IT Act, 2000. Full DPDP Act compliance is being implemented in phases through May 2027.
01 Identity of the Data Fiduciary

Business name: The Athlete Code

Operated by: Abhay Kedari (CSCS)

Address: Pune, Maharashtra, India

Website: theathletecode.com (hosted on Netlify)

Contact for privacy matters: abhay@theathletecode.com

Under the DPDP Act 2023, The Athlete Code acts as the Data Fiduciary — the entity that determines the purpose and means of processing your personal data.

02 Personal Data We Collect

Identity and contact data: name, email address, WhatsApp number, date of birth, city

Physical and health data (sensitive): height, weight, sitting height, injury history, medical clearance status, physical limitations and health conditions relevant to training

Performance data: heart rate variability (HRV) readings, video recordings of movement and athletic performance submitted for assessment, training load and compliance records

Parent/guardian data: name, contact details, and consent records for clients under 18

Payment data: transaction reference numbers and payment status. We do not store card numbers, bank account details, or UPI IDs — these are handled entirely by Cashfree Payments under their own data security standards.

Communication data: messages, voice notes, and video calls exchanged via WhatsApp and other channels

03 Purpose of Processing

Your personal data is processed only for the following specific purposes:

We do not process your data for marketing to third parties, profiling for advertising, or any purpose beyond those listed above.

04 Legal Basis for Processing

Under the DPDP Act 2023, we process your personal data on the following legal bases:

How We Obtain Your Consent
We obtain your consent through clear, affirmative actions, including:
  • A mandatory checkbox at the time of booking or checkout confirming that you have read and agree to our Terms & Conditions, Privacy Policy, and Refund Policy
  • Signed or submitted intake and health questionnaires acknowledging the collection and use of your personal and health information for coaching purposes
  • For athletes under 18, a separate parental/guardian consent form completed by a verifiable parent or legal guardian

We retain records of consent for the duration of our relationship with you and for the applicable retention periods described in this Policy.

Withdrawing Your Consent

You may withdraw your consent to our processing of your personal data at any time by emailing abhay@theathletecode.com with the subject line "Consent Withdrawal – The Athlete Code".

We will acknowledge your request within 48 hours and process it within 30 days, subject to our legitimate business interests and legal obligations (for example, retaining certain records for tax and accounting purposes).

If you withdraw consent, we may no longer be able to provide some or all of our services to you.

05 Sensitive Personal Data
Health and injury data is sensitive personal data under both the IT Rules 2011 and the DPDP Act 2023. We apply heightened care to this category of information. It is used exclusively for the purpose of coaching and is never shared with third parties without your explicit consent, except as required by law.

For clients under 18, health and performance data is shared with the named parent or guardian as part of the service. This is disclosed at onboarding and covered by parental consent.

If a programme is paused due to injury or health concerns, we may recommend consulting a physiotherapist or medical professional. We will not share your data with those professionals without your explicit consent.

06 Third-Party Data Processors

We share your data only with the following platforms, strictly for the purpose of delivering our services. Each operates under its own privacy and security standards:

We do not share your data with any other third party without your explicit consent.

06A Cross-Border Data Transfer

Your personal data may be stored and processed on servers located outside India, including but not limited to:

Note: Cashfree Payments is headquartered in India and processes payment data domestically under RBI regulations.

We use these providers only for the purposes described in this Privacy Policy and implement appropriate safeguards, including contractual data protection obligations, encryption of data in transit and at rest, and access controls limiting access to authorised personnel only.

By using our services, you consent to such cross-border transfers of your personal data under the safeguards described above, subject to any restrictions notified by the Government of India under the Digital Personal Data Protection Act, 2023.

07 Data Retention

We retain your personal and performance data for as long as you are an active client and for 3 years after your last engagement, to allow for continuity of coaching if you return.

Financial transaction records are retained for 7 years as required under Indian tax law (Income Tax Act, 1961 and GST Act, 2017 where applicable).

Assessment videos submitted to Google Drive are retained for 2 years after your last engagement and then permanently deleted unless you request earlier deletion.

Upon expiry of the retention period, personal data is securely deleted or anonymised.

08 Your Rights as a Data Principal

Under the DPDP Act 2023, you have the following rights:

To exercise any of these rights, email abhay@theathletecode.com with the subject line "Data Rights Request". We will acknowledge within 48 hours and respond fully within 30 days.

09 Complaint to the Data Protection Board

If you are unsatisfied with our response to a data rights request or have a complaint about our data practices, you may escalate to the Data Protection Board of India, established under the DPDP Act 2023.

The Board was constituted on November 13, 2025. Complaint procedures will be available at the Board's official website once operational. Further information: meity.gov.in

10 Children's Data

For clients under 18 years of age, we require verifiable consent from a parent or legal guardian before collecting any personal or health data. This consent is obtained through a written consent form signed at onboarding.

We do not knowingly collect data from children under 8 years of age. Future Champions and Growth Check services are available for children aged 8 and above, with mandatory parental consent.

Parents and guardians have the same data rights listed in Section 08 with respect to their child's data.

11 Data Security

We implement the following reasonable security practices in accordance with the IT Rules 2011 and DPDP Rules 2025:

In the event of a personal data breach that is likely to affect you, we will notify you and the Data Protection Board as required under the DPDP Act, without undue delay.

12 Policy Updates

We may update this policy periodically to reflect changes in our services or applicable law. Material changes will be communicated to active clients via email or WhatsApp at least 14 days before they take effect. The "Last Updated" date at the top of this page will reflect any changes. Continued use of our services after the effective date constitutes acceptance of the updated policy.

Privacy & Data Rights

Email: abhay@theathletecode.com

Subject: "Data Rights Request" or "Privacy Query"

The Athlete Code · Abhay Kedari · Pune, Maharashtra, India

Acknowledgement within 48 hours · Refund issues: 7 business days · All other matters: 30 days

Applicable law: This policy is drafted in compliance with the Consumer Protection Act, 2019 and the Consumer Protection (E-Commerce) Rules, 2020. Refunds are processed via Cashfree Payments in accordance with Reserve Bank of India guidelines.
Please read before purchasing. Our refund terms vary by service type. If you have questions before purchasing, book a free 15-minute call at theathletecode.com — there is no obligation.
01 Decode — Performance Assessment (₹4,900)
Situation Refund
Cancelled before submitting any video or dataAnalysis not yet started 50% refund within 7 days of cancellation request
Analysis has begunAny video or HRV data submitted No refund
Active injury flagged — session cannot safely proceed Full refund within 7 days
Poor video quality requiring reshoot One free reshoot within 48 hours — no refund applicable
Analysis is considered to have "begun" once you have submitted video or HRV data to the shared folder. Submission of the intake form alone does not constitute the start of analysis.
02 Performance Code — Online Coaching
Situation Refund
3-Month Block — cancelled before programme is deliveredBefore CoachRx programme is built Full refund of entire block payment
3-Month Block — cancelled within 14 days of programme startSatisfaction window — programme delivered but not right for you Refund of block payment minus one month's fee (₹9,900). Net refund: ₹17,099 within 7 days.
3-Month Block — cancelled after 14 daysProgramme delivered and satisfaction window passed No refund for current month. Remaining months refunded pro-rata.
Monthly payment — cancellation within 24 hours of paymentBefore intake form submitted Full refund within 7 days
Monthly payment — after 24 hours or intake form submitted Programme design begins. No refund once programme is delivered.
Medical emergency supported by documentation Pro-rata refund for unused portion, assessed case by case within 7 days
Service cancelled by The Athlete CodeFor reasons unrelated to client conduct Full pro-rata refund for unused period

A programme is considered "delivered" once the CoachRx programme has been built and the WhatsApp video walkthrough has been sent to the client.

14-day satisfaction window for 3-month blocks: If within 14 days of your programme starting you feel the service isn't right for you, you pay only for the first month (₹9,900) — the same as if you had paid monthly. This makes the upfront block option risk-free. You can also pay the block in 3 EMIs of approximately ₹9,000 via credit or debit card at checkout through Cashfree Payments.
Why a 24-hour window for monthly? Monthly clients pay at the start of each month and programme design begins promptly. The 24-hour window accommodates genuine errors or immediate second thoughts — not a general cooling-off period for recurring coaching.

14-Day Satisfaction Window — Upfront Block payments only

If you pay the 3-month upfront block (₹26,999) and decide within 14 days of programme start that the service is not right for you, you will be refunded the block payment minus one month's fee (₹9,900). You pay only for the time you used.

Scenario Refund
Cancel within 14 days of programme start
Upfront block payments only
₹17,099 refunded within 7 days
(₹26,999 block minus ₹9,900 for Month 1)
Cancel after day 14 No refund for current month. Remaining unused months refunded pro-rata within 14 days.
The 14-day window applies to the upfront block payment only. Monthly clients have the flexibility of monthly billing and the 24-hour cancellation window instead.
03 Rising Stars — Youth Coaching

The same refund policy as Performance Code applies, including the 14-day satisfaction window for 3-month blocks. Additionally:

04 The Lab — In-Person Assessment, Pune (₹9,900)
Cancellation timing Refund
48 hours or more before session Full refund within 7 days
Less than 48 hours before session 50% refund within 7 days
No-show without prior notice No refund
Equipment unavailable on session dayHawkin or Output subscription inactive Full refund or rescheduling at client's choice, within 7 days
Active injury identified at session Rescheduling offered within 60 days at no charge. Full refund available if rescheduling is not suitable.
05 Future Champions (₹3,000) & Growth Check (₹3,000)
Situation Refund
Cancelled 48+ hours before call Full refund within 7 days
Cancelled less than 48 hours before call Reschedule offered once within 30 days. No cash refund.
No-show without prior notice No refund
06 Return to Performance — 12-Week Programme (₹24,999)
Situation Outcome
Cancelled before programme commencementBefore Week 1 baseline session Full refund within 7 days
Cancelled after Week 1 baseline — by client choice No refund for elapsed weeks. Unused weeks refunded at ₹2,083/week within 14 days.
Medical setback requiring temporary suspensionSupported by documentation from a medical professional Programme placed on hold for up to 12 weeks. No charge during hold. Client resumes from where they left off with no penalty or restart fee.
Medical hold exceeds 12 weeks and client does not resume Pro-rata refund for unused weeks at ₹2,083/week, issued within 14 days of hold expiry.
Medical hold: client decides not to resume within hold window Client may notify at any time during the hold period. Pro-rata refund for unused weeks issued within 14 days.
Hold policy rationale: Return to Performance exists precisely because injury recovery is non-linear. A medical setback is not a reason to end the programme — it is part of the process. The hold option protects both the client's investment and their long-term outcome. Refund is available only if the client chooses not to resume.
Pro-rata refund formula: For all pro-rata refunds under this programme, the refund amount is calculated as: Refund = Number of unused weeks × ₹2,083, based on the original programme fee of ₹24,999 over 12 weeks. All amounts are rounded to the nearest rupee.

Example: If you cancel after completing 4 weeks — 8 unused weeks × ₹2,083 = ₹16,664 refunded.

Note: This formula applies to the Return to Performance programme only. Performance Code and Rising Stars block refunds are calculated on a monthly basis as described in their respective sections above.
07 Deficient or Misrepresented Service

Under the Consumer Protection Act 2019, if a service is materially deficient or significantly misrepresented relative to what was described at the time of purchase, you are entitled to raise a complaint regardless of the standard refund terms above.

Examples of deficiency: assessment report not delivered within the stated timeframe without valid reason; programme delivered substantially differs from what was agreed at onboarding.

Raise such complaints to abhay@theathletecode.com with the subject "Service Complaint". We will acknowledge within 48 hours and resolve within 30 days, in accordance with the Consumer Protection (E-Commerce) Rules 2020.

08 How to Request a Refund

Email abhay@theathletecode.com with the subject: "Refund Request — [Service Name]"

Include in your email:

Acknowledgement: We will acknowledge all refund requests within 48 hours.

Resolution: We aim to resolve all refund requests within 7 business days.

Processing: Approved refunds are processed back to the original payment method via Cashfree Payments, in accordance with RBI guidelines. Bank processing typically takes 5–7 business days after initiation. Refund requests are not accepted more than 120 days after the original transaction date, in line with Cashfree's payment processor limits.

09 Grievance Redressal

In accordance with the Consumer Protection (E-Commerce) Rules 2020, the Grievance Officer for The Athlete Code is:

Grievance Officer: Abhay Kedari
Email: abhay@theathletecode.com
Address: Pune, Maharashtra, India
Acknowledgement within: 48 hours
Resolution: Refund-related issues within 7 business days; all other grievances within 30 days

If you are not satisfied with our resolution, you may escalate your complaint to the Consumer Disputes Redressal Commission (Consumer Forum) at the district, state, or national level depending on the value of your claim.

Refund & Grievance Contact

Email: abhay@theathletecode.com

Subject: "Refund Request — [Service Name]" or "Service Complaint"

Acknowledgement within 48 hours · Refund issues: 7 business days · All other matters: 30 days

Applicable law: These Terms are governed by the Indian Contract Act, 1872; the Consumer Protection Act, 2019; the Consumer Protection (E-Commerce) Rules, 2020; the Information Technology Act, 2000; and the Digital Personal Data Protection Act, 2023.
Please read carefully. By purchasing any service from The Athlete Code, you confirm that you have read, understood, and agree to these Terms & Conditions. These Terms form a legally binding contract between you and The Athlete Code. This is a draft document — we recommend review by a qualified Indian lawyer before final publication.
01 Business Information

Business name: The Athlete Code

Operated by: Abhay Kedari

Qualification: Certified Strength and Conditioning Specialist (CSCS), NSCA — Certification No. 7248444275

Address: Pune, Maharashtra, India

Email: abhay@theathletecode.com

Website: theathletecode.com

PAN: BIYPK4742A

GST status: Not currently registered for GST as annual turnover is below ₹20,00,000 (the applicable registration threshold under the Central Goods and Services Tax Act, 2017).

As required under Rule 5(3) of the Consumer Protection (E-Commerce) Rules 2020, the above business information is disclosed to all consumers prior to purchase.
02 Services Offered

The Athlete Code offers the following performance coaching services:

All prices are in Indian Rupees (₹). GST not applicable — current annual turnover is below the GST registration threshold under the Central Goods and Services Tax Act, 2017. Prices are subject to change; the price confirmed at booking is binding for that booking.

03 Purchase and Consent

In accordance with Rule 4(11) of the Consumer Protection (E-Commerce) Rules 2020, your consent to purchase is recorded only through an explicit and affirmative action — clicking a payment button after reviewing the service description and price. No consent is recorded automatically or via pre-ticked checkboxes.

A booking is confirmed only upon receipt of full payment and a confirmation communication from The Athlete Code.

By completing payment, you confirm that you have read and agree to these Terms, the Refund Policy, and the Privacy Policy.

04 Payment

All payments are processed securely by Cashfree Payments India Pvt. Ltd., a licensed Payment Aggregator regulated by the Reserve Bank of India. We accept UPI, credit/debit cards, and net banking.

Payment is due in full at the time of booking for all one-time services. For coaching programmes, payment is due at the start of each billing period.

For any payment disputes or chargebacks, you may also contact Cashfree's grievance redressal mechanism at cashfree.com/support.

05 Coaching Programme Terms

Minimum commitment: Performance Code and Rising Stars require a minimum 3-month commitment. Month-to-month payment is available but does not reduce or waive this minimum. Cancellation before the end of the 3-month minimum does not entitle the client to a refund for the remaining minimum period, unless covered by the Refund Policy.

Pauses: One pause of up to 4 consecutive weeks is permitted per 3-month block, agreed in advance. The programme end date extends by the pause duration only if agreed in writing.

Continuation: After the initial 3-month block, the programme continues month-to-month unless you notify us of cancellation at least 7 days before the next billing date.

Programme delivery: Programmes are delivered via CoachRx. You are responsible for maintaining internet access and a compatible device. Temporary platform outages do not entitle the client to a refund, provided the outage is resolved within 48 hours.

06 Medical Disclaimer
Coaching is not a medical service. The Athlete Code provides strength and conditioning coaching and athletic performance testing. We do not diagnose medical conditions, provide physiotherapy, or give medical advice. Our services are not a substitute for qualified medical care.

Before commencing any coaching programme, you confirm that:

Providing false information about your health status absolves The Athlete Code of liability for any resulting injury. If the coach determines that continued participation poses a health risk, the programme will be paused and a referral made to an appropriate professional.

07 Youth Athletes — Additional Terms

For all clients under 18:

08 Client Responsibilities

We reserve the right to terminate any coaching relationship without refund if a client is abusive, persistently dishonest, or consistently non-compliant with the programme without valid reason.

09 Intellectual Property

All coaching programmes, assessment reports, educational content, and materials created by The Athlete Code are the intellectual property of Abhay Kedari / The Athlete Code and are protected under the Copyright Act, 1957 (India).

Materials are licensed to you for personal use only during the term of your programme. You may not reproduce, distribute, sell, or share coaching materials with third parties without prior written permission.

10 Limitation of Liability

To the fullest extent permitted by applicable Indian law, The Athlete Code and Abhay Kedari shall not be liable for:

Our total aggregate liability to you for any claim arising from these services shall not exceed the total amount paid by you for the specific service giving rise to the claim, in the 12 months preceding the claim.

Nothing in this clause limits liability for death or personal injury caused by negligence, or for fraud or fraudulent misrepresentation.

11 Force Majeure

Neither party shall be liable for any failure to perform obligations under these Terms where such failure results from circumstances beyond their reasonable control, including but not limited to natural disasters, pandemic, government orders, internet or platform outages beyond 48 hours, or other events of force majeure.

In the event of a force majeure affecting service delivery, we will notify you promptly and offer rescheduling or a pro-rata refund for the affected period.

12 Grievance Redressal

As required under the Consumer Protection (E-Commerce) Rules 2020, the Grievance Officer for The Athlete Code is:

Grievance Officer: Abhay Kedari
Email: abhay@theathletecode.com
Address: Pune, Maharashtra, India
Response within: 48 hours · Resolution: Refund issues: 7 business days; all other matters: 30 days

If not resolved to your satisfaction, you may approach the Consumer Disputes Redressal Commission (Consumer Forum) under the Consumer Protection Act 2019, or for payment-related disputes, the RBI Integrated Ombudsman Scheme.

13 Governing Law and Jurisdiction

These Terms are governed by and construed in accordance with the laws of the Republic of India.

Any disputes arising from or in connection with these Terms that cannot be resolved amicably within 30 days shall be subject to the exclusive jurisdiction of the civil courts of Pune, Maharashtra, India.

Consumers retain all rights available to them under the Consumer Protection Act 2019, including the right to approach the appropriate Consumer Disputes Redressal Commission regardless of this jurisdiction clause.

14 Updates to These Terms

We may update these Terms periodically to reflect changes in our services, pricing, or applicable law. Material changes will be communicated to active clients at least 14 days before taking effect, via email or WhatsApp. Continued use of our services after the effective date constitutes acceptance.

The "Last Updated" date at the top of this page reflects the most recent revision.

Legal Queries & Grievances

Grievance Officer: Abhay Kedari

Email: abhay@theathletecode.com

The Athlete Code · Pune, Maharashtra, India

Acknowledgement within 48 hours · Refund issues: 7 business days · All other matters: 30 days