LEGAL

Privacy Policy

Last updated: 21 September 2026

This Privacy Policy explains how HabFORGE (“HabFORGE,” “we,” “us” or “our”) collects, uses, stores, discloses and otherwise processes personal information and personal data in connection with the HabFORGE website, consultations, Blueprints, coaching programmes, and related services.

This Privacy Policy should be read together with the HabFORGE Terms & Conditions.

A. Who This Policy Applies To

A1. Scope

This Privacy Policy applies to information collected through:

  • the HabFORGE website;
  • consultations;
  • coaching programmes;
  • Blueprints;
  • communications with HabFORGE;
  • scheduling and booking processes;
  • payment processes; and
  • other interactions with HabFORGE.

Where a third-party service provider independently processes personal data under its own terms, that provider’s privacy policy may also apply to the relevant processing activity.

B. Information We Collect

B1. Identity and Contact Information

HabFORGE may collect:

  • name;
  • email address;
  • telephone number;
  • communication details;
  • booking information; and
  • information voluntarily supplied during enquiries or consultations.

B2. Coaching Information

HabFORGE may collect information relating to:

  • fitness goals;
  • dietary preferences;
  • lifestyle;
  • exercise history;
  • training environment;
  • programme participation;
  • progress;
  • assessments; and
  • information necessary to provide personalised services.

B3. Health and Laboratory Information

Clients may voluntarily provide:

  • health information;
  • fitness information;
  • nutrition information;
  • information concerning injuries;
  • medication-related information;
  • allergies or intolerances;
  • laboratory reports;
  • blood-test reports; and
  • other health-related information relevant to the service.

HabFORGE seeks to collect only information reasonably necessary for the relevant coaching or service purpose.

B4. Technical Information

HabFORGE may collect information concerning:

  • browser type;
  • device information;
  • pages visited;
  • interactions with the website;
  • approximate location;
  • cookies and similar technologies; and
  • website engagement information.

C. Purposes of Processing

C1. Service Delivery

HabFORGE may process information to:

  • respond to enquiries;
  • conduct consultations;
  • assess suitability;
  • prepare personalised Blueprints;
  • provide coaching;
  • monitor programme progress;
  • communicate with Clients;
  • process payments;
  • maintain business records; and
  • provide customer support.

C2. Business Operations

HabFORGE may process information where reasonably necessary to:

  • maintain and improve services;
  • understand website usage;
  • maintain security;
  • detect misuse;
  • administer business operations;
  • maintain records;
  • comply with legal obligations; and
  • establish, exercise, or defend legal claims.

C3. Communications

HabFORGE may contact Clients regarding:

  • purchased services;
  • bookings;
  • consultations;
  • programme administration;
  • service updates;
  • important notices; and
  • other communications permitted by applicable law.

Where marketing communications require consent or another specific lawful basis, HabFORGE shall process such communications in accordance with applicable law.

D. Legal Basis and Data Protection

D1. Applicable Law

HabFORGE processes personal data in accordance with applicable privacy and data-protection laws in force from time to time, including the Digital Personal Data Protection Act, 2023 (“DPDP Act”) and the Digital Personal Data Protection Rules, 2025, to the extent applicable to HabFORGE and in force from time to time.

Where another applicable privacy, data-protection, consumer, regulatory or other legal requirement applies to a particular processing activity, HabFORGE shall comply with such requirement to the extent applicable.

D2. Notice and Consent

Where consent is required under applicable law, HabFORGE shall seek consent in accordance with the requirements applicable to the relevant processing activity.

Where applicable law permits processing without consent, or provides another lawful basis or permitted ground for processing, HabFORGE may process personal data on that basis to the extent permitted by applicable law.

HabFORGE may update its processing practices, notices, consent mechanisms and procedures where reasonably necessary to comply with changes in applicable law or regulatory requirements.

D3. Withdrawal of Consent

Where processing is based on consent under applicable law, the Client may withdraw such consent through the mechanism specified by HabFORGE or by contacting HabFORGE, subject to applicable law.

Withdrawal of consent will not affect the lawfulness of processing carried out before such withdrawal and may not affect processing that HabFORGE is otherwise permitted or required to carry out under applicable law.

E. Health and Laboratory Information

E1. Voluntary Submission

Health and laboratory information is generally supplied voluntarily by Clients for the purpose of personalised coaching.

E2. Limitation of Use

HabFORGE shall seek to limit the use of health and laboratory information to purposes reasonably connected with providing, administering, improving, or protecting the relevant service, or as otherwise permitted or required by applicable law.

E3. Medical Status

HabFORGE is not a medical provider merely by receiving health information.

Receipt or review of health or laboratory information does not itself constitute a diagnosis, medical consultation, or doctor-patient relationship.

E4. Transmission of Health Information

Clients should use the specific communication or submission method identified by HabFORGE when providing laboratory reports or other sensitive health information.

Clients should not intentionally submit such information through website analytics, advertising or other technical channels not intended for health information.

F. Analytics and Cookies

F1. Google Analytics

HabFORGE uses Google Analytics 4 (“GA4”) to understand website usage and engagement.

GA4 may collect information such as:

  • interactions;
  • pages viewed;
  • device and browser information;
  • approximate location;
  • cookies or similar identifiers; and
  • engagement information.

HabFORGE does not intentionally configure website analytics to collect blood-test reports, coaching records or health information submitted directly for personalised services.

F2. Cookies

HabFORGE may use cookies and similar technologies for website functionality, security, analytics and, where applicable, other purposes permitted by law.

Where applicable law requires consent for a particular category of cookies or similar technologies, HabFORGE shall provide an appropriate mechanism for obtaining or managing that consent.

G. Third-Party Service Providers

G1. Service Providers

HabFORGE may use third-party providers for:

  • scheduling;
  • payment processing;
  • banking;
  • website hosting;
  • analytics;
  • communications;
  • storage;
  • technology infrastructure; and
  • other business functions.

Some service providers may process personal data from or outside India.

G2. Calendly

HabFORGE may use Calendly for scheduling consultations and appointments.

Information submitted through Calendly may be processed in accordance with Calendly’s applicable privacy terms in addition to this Privacy Policy.

G3. Payment Providers

Payment information may be processed through applicable payment gateways, banks, or other payment providers.

HabFORGE does not ordinarily require Clients to provide complete payment-card credentials directly to HabFORGE where the payment is processed through a third-party payment provider.

H. Sharing and Disclosure

H1. Service Providers

HabFORGE may disclose personal information to service providers where reasonably necessary to provide or administer the services.

H2. Legal Requirements

HabFORGE may disclose personal data where reasonably necessary to comply with applicable law, lawful governmental requests, court orders, regulatory requirements or to establish, exercise or defend legal rights.

H3. Business Transfers

In connection with a merger, acquisition, restructuring, financing, sale of assets or transfer of the relevant business, personal data may be transferred as part of the relevant transaction, subject to applicable law and appropriate safeguards.

I. Data Security

I1. Safeguards

HabFORGE shall implement reasonable technical and organisational safeguards appropriate to the nature of the personal data processed.

These may include:

  • access controls;
  • authentication measures;
  • restricted access;
  • secure storage;
  • confidentiality obligations; and
  • reasonable organisational procedures.

I2. Data Breaches

Where a personal data breach occurs, HabFORGE shall take reasonable steps to contain, assess, and respond to the incident and provide notifications required by applicable law.

Applicable notification requirements may depend on the nature of the breach, affected data and provisions of law in force at the relevant time.

J. Data Retention

J1. Retention Period

HabFORGE shall retain personal data only for as long as reasonably necessary for the relevant purpose, subject to:

  • legal requirements;
  • accounting requirements;
  • dispute resolution;
  • contractual obligations;
  • legitimate business requirements; and
  • establishment, exercise, or defence of legal claims.

J2. Deletion

When personal data is no longer required and there is no applicable legal or legitimate reason for retention, HabFORGE may delete, anonymise, or otherwise appropriately dispose of the information.

K. Data Principal Rights

K1. Rights

Subject to applicable law and the provisions in force from time to time, Clients may have rights concerning their personal data, including rights relating to:

  • access to information about personal data;
  • correction, completion or updating of personal data;
  • erasure of personal data, subject to applicable retention requirements;
  • withdrawal of consent, where processing is based on consent;
  • grievance redressal; and
  • any other rights available under applicable privacy or data-protection laws.

The availability, scope and manner of exercising such rights may depend on the applicable law, the nature of the processing and the provisions in force at the relevant time.

K2. Exercising Rights

Requests may be made using the contact details specified in this Privacy Policy.

HabFORGE may need to verify the identity of the requesting person before acting on a request.

K3. Effect of Erasure

Where information is deleted or erased at the Client’s request, HabFORGE may retain information where retention is required or permitted by applicable law.

L. Children

L1. Children’s Data

HabFORGE services are primarily intended for adults.

HabFORGE does not knowingly seek to collect personal data from children in circumstances where applicable law requires parental or lawful guardian consent unless the required consent and safeguards are obtained.

Where HabFORGE becomes aware that personal data has been collected contrary to applicable legal requirements, it shall take reasonable steps appropriate to the circumstances.

M. International Processing

M1. Third-Party Processing

Certain third-party service providers used by HabFORGE may process information outside India.

Where personal data is transferred or made available outside India, HabFORGE shall do so subject to applicable law and any restrictions or conditions applicable to such transfer.

N. Marketing

N1. Marketing Communications

HabFORGE may send service-related communications necessary for the administration of an existing relationship.

Promotional communications shall be sent subject to applicable law and any consent or opt-out requirements applicable to such communication.

N2. Withdrawal from Marketing

Clients may request to stop receiving promotional communications through the mechanism provided in the relevant communication or by contacting HabFORGE.

O. Client Content and Testimonials

O1. Reviews and Testimonials

If a Client voluntarily provides a review, testimonial, photograph, progress story, or other content, HabFORGE may use the content for the purpose for which it was submitted, subject to any consent or restrictions applicable to that submission.

O2. Marketing Consent

HabFORGE shall seek an appropriate consent or other lawful basis where identifiable Client information is used for public marketing or promotional purposes where required by law.

P. Data From Other Sources

P1. Information Provided by Others

HabFORGE may receive information concerning a Client from another person where the Client has authorised such sharing or where such processing is otherwise permitted by applicable law.

Q. Third-Party Links

Q1. External Websites

The HabFORGE website may contain links to third-party websites, platforms, or services.

HabFORGE is not responsible for the privacy practices of third-party websites that it does not control.

Clients should review the privacy policies of third-party services before providing personal information.

R. Privacy Complaints

R1. Internal Grievance

Clients may raise privacy-related questions, complaints, or requests with HabFORGE using the contact details below.

HabFORGE shall maintain an appropriate mechanism for receiving and addressing privacy-related grievances in accordance with applicable law.

S. Changes to This Policy

S1. Amendments

HabFORGE may update this Privacy Policy from time to time to reflect:

  • changes in services;
  • changes in technology;
  • changes in processing practices;
  • legal or regulatory requirements; or
  • operational changes; and
  • other changes as necessary.

Where required by applicable law, HabFORGE shall provide an appropriate notice of material changes.

S2. Applicable Law Qualification

References in these Terms or the Privacy Policy to the Digital Personal Data Protection Act, 2023 (“DPDP Act”), the Digital Personal Data Protection Rules, 2025, or any other specific privacy or data-protection law or regulatory framework are references to such law or framework to the extent applicable to HabFORGE and in force from time to time.

Where another applicable privacy, data-protection or other legal or regulatory requirement applies to a particular processing activity, HabFORGE’s obligations shall be determined by that applicable requirement.

Nothing in these Terms or the Privacy Policy shall be interpreted as an admission that a particular law or regulatory framework applies to HabFORGE where it is not otherwise legally applicable.

Contact

Privacy-related requests, rights requests, and complaints should be directed to the above contact details.