CultFit Smart Mirror

In-Gym AR/VR Integration Strategy

Presenter's Full Script
FY 2025–28 | 3-Year Rollout Plan | Confidential
Team: Priyanka Sharma | Nirmitee Gaonkar | Arti Chelkani | Rohanshi Sethi

Slide 1 — Title Slide

⏱ Suggested time: 1–2 minutes

Good [morning/afternoon], everyone. Thank you for being here today.

My name is [Presenter Name], and I'm here on behalf of our team — Priyanka Sharma,
Nirmitee Gaonkar, Arti Chelkani, and Rohanshi Sethi — to walk you through a strategic
proposal that we believe can fundamentally transform the in-gym experience for over one million
CultFit members across India.

What we are presenting today is the CultFit Smart Mirror Initiative — a plan to deploy 2,100 AI-
powered Smart Mirrors across 700 CultFit gyms over the next three years, embedding
Augmented Reality and Virtual Reality directly into the gym floor.

This is not an incremental upgrade. It is a step-change in how CultFit members experience

fitness — from passive workouts to real-time, personalised, immersive training sessions. By the
end of this presentation, you will understand the problem we are solving, the strategy we are
proposing, the technology choices we have made, the financial investment required, and the
return we expect to deliver.

Let's begin.

Slide 2 — Problem Statement: The In-Gym Experience Gap

⏱ Suggested time: 3–4 minutes

Before we talk about solutions, let us talk about the problem — because the problem is real, it is
significant, and it is costing CultFit members and the business alike.

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The Scale of CultFit
CultFit today operates over 700 gyms across more than 60 cities in India — from Bengaluru,
Mumbai, and Delhi to Hyderabad and Chennai. It is one of the largest organised gym networks
in the country, with more than one million active members paying between ₹714 and ₹1,178 per
month for membership.

That is a significant financial commitment from members — and it comes with an expectation of
quality. But here is what those members are actually getting on the gym floor.

The Core Problems

• Trainer-to-member ratios during peak hours average 1 to 30 or more. That means one
trainer is responsible for up to thirty people simultaneously. Real-time, individual form
correction — the kind that prevents injury and maximises results — is simply not
possible at that scale.
• Members receive generic, one-size-fits-all training sessions. There is no personalisation
for individual fitness levels, goals, or technique.
• There is zero visibility into individual form, posture, or workout efficiency on the gym
floor. A member could be performing a deadlift with dangerous form and no one would
flag it in the moment.
• And critically — 55% of CultFit members stop attending within 90 days of joining. That is
a majority of new members disengaging in under three months. Lack of progress
visibility and lack of engagement are the leading reasons cited.

The Competitive Pressure

This is not happening in a vacuum. Globally, competitors like Gold's Gym and Anytime Fitness
are investing heavily in technology-led gym experiences. If CultFit does not move now, it risks
falling behind — not just in features, but in member perception and retention.

The Core Problem — In One Sentence

Despite having the largest gym footprint in India, CultFit currently has zero AI coaching
capability and zero immersive engagement technology inside its gym floors. That gap is the
opportunity this proposal addresses.

Slide 3 — Proposed Strategy: CultFit In-Gym Smart Mirror

⏱ Suggested time: 4–5 minutes

So what is our solution? The CultFit Smart Mirror.

The proposal is to deploy 2,100 Smart Mirror units across all 700 CultFit gyms — three mirrors
per gym — in a phased rollout over three financial years: FY25 through FY28.

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Each Smart Mirror is a 43-inch 4K touchscreen display unit with embedded depth camera, AI
processing, AR/VR capabilities, and always-on connectivity. Think of it as a personal AI trainer
installed directly onto the gym wall — visible, interactive, and always available.

Each mirror carries eight core features, which I will walk you through now.

Feature 1 — AI Posture Correction

Using real-time skeleton tracking via the embedded depth camera, the mirror analyses every
rep a member performs and delivers instant feedback on form. It can identify a misaligned knee
in a squat, a collapsed spine in a deadlift, or an incorrect shoulder position in a press — all
without a trainer needing to be present.

Feature 2 — AR Trainer Overlay

An Augmented Reality virtual trainer is projected directly onto the mirror surface. Members can
follow movement cues and technique demonstrations in real-time, overlaid on their own
reflection. It is the closest experience to having a personal trainer standing next to you.

Feature 3 — VR Workout Zones

Each gym will include a designated VR zone where members can put on HTC Vive Focus
headsets and enter fully immersive workout environments — an outdoor arena, a mountain trail,
or a studio setting. This transforms a routine session into an experience.

Feature 4 — Personal Analytics

A live dashboard on the mirror surface shows each member their real-time metrics — reps
completed, sets done, calories burned, heart rate, and a proprietary form score. For the first
time, members can actually see their performance as they work out.

Feature 5 — Live and On-Demand Classes

The entire CultFit class library — including live sessions — is accessible directly on the mirror.
Remote trainers can guide members through workouts in real-time, extending the value of
CultFit's existing content investment to the gym floor.

Feature 6 — Gamification
Gym-wide leaderboards, member streaks, personal bests, and a loyalty rewards engine. These
features create the social and competitive engagement loops that drive consistent attendance
— directly addressing the 55% drop-off problem.

Feature 7 — Voice AI Coaching

Hands-free voice prompts guide members through their workouts — counting reps, timing rest
periods, and offering motivational cues — without requiring any screen interaction during the
session.

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Feature 8 — Wearables and App Sync
Every mirror syncs continuously with the CultFit mobile app, Apple Watch, and Garmin devices,
ensuring that workout data flows seamlessly across the member's entire health ecosystem.
Progress is tracked whether a member is in the gym or at home.

Together, these eight features transform a standard gym visit into a connected, personalised,
gamified fitness experience. No CultFit competitor in India currently offers anything close to this
on their gym floors.

Slide 4 — Implementation Plan: Buy vs. Build

⏱ Suggested time: 4–5 minutes

One of the most important decisions in this programme was determining which components to
buy off-the-shelf, and which to build in-house. This decision directly impacts cost, timeline, IP
ownership, and long-term flexibility.

We evaluated every component against three criteria: availability of commercial-grade solutions,

total cost over three years, and the strategic value of owning the IP ourselves. Here is what we
decided.

What We Are Buying

Hardware and third-party licensed technology will be procured from established vendors:

• Smart Mirror Units: We have selected the Portl 43-inch 4K holographic display mirrors at
a B2B price of ₹1,47,500 per unit. These are commercially proven, Android-embedded,
and touch-enabled.
• Depth Camera: The Microsoft Azure Kinect DK provides Time-of-Flight depth sensing
with commercial support and will be bundled with each unit.
• AR SDK: PTC Vuforia Engine on an enterprise licence — the industry standard for AR
overlay in commercial environments.
• VR Platform: Unity XR asset packs combined with HTC Vive Focus gym-grade headsets
— one headset per gym VR zone.
• Voice Engine: Google Dialogflow CX on its enterprise tier for natural language voice
interaction.
• Wearables Integration: Apple HealthKit and Garmin Connect developer APIs, with a one-
time approval fee of ₹4,15,000 for Garmin.
• All hardware comes with a 3-year B2B warranty and support contract.

What We Are Building

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The intelligence and uniqueness of the CultFit Smart Mirror will come from what we build in-
house:

• AI Posture Engine: A custom machine learning model built on MediaPipe and

TensorFlow Lite, running on-device — no cloud dependency, no latency, full data
privacy.
• CultFit Mirror OS: An Android 12-based firmware layer with a centralised content
management system for all 700 gyms.
• Analytics Dashboard: Fully integrated with the CultFit member app and gym CRM for
seamless data continuity.
• Gamification Backend: [Link] microservices powering leaderboards, streak tracking,
and the rewards engine.
• Content Streaming Layer: Deep integration with CultFit's existing class library and live
session infrastructure.
• Data Privacy Layer: All processing happens on-device, ensuring full compliance with
India's Digital Personal Data Protection Act 2023.
• Central Device Management: Remote OTA update capability and real-time monitoring
across all 2,100 units from a single console.

The Decision
Our recommendation is a Hybrid approach. We buy the commodity hardware and licensed
SDKs where world-class solutions already exist — avoiding the cost and risk of reinventing
them. We build the AI, firmware, analytics, and gamification layers in-house — because these
are the differentiating capabilities that create IP, enable gym-level customisation, and compound
in value over time.

This approach gives us the speed of buying and the strategic value of building.

Slide 5 — Cost & Financial Estimation

⏱ Suggested time: 3–4 minutes

Let's talk numbers. All figures are in Indian Rupees, and the deployment is structured across
three phases aligned to our gym rollout.

Phase Structure
• Phase 1 (Year 1): 150 gyms, 450 mirror units — Total CAPEX: ₹10.21 Crore
• Phase 2 (Year 2): 300 gyms, 900 mirror units — Total CAPEX: ₹16.44 Crore
• Phase 3 (Year 3): 250 gyms, 750 mirror units — Total CAPEX: ₹13.42 Crore

Key Cost Drivers

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The largest single cost item is the Smart Mirror hardware itself — Portl B2B units at ₹1,47,500
each, totalling approximately ₹30.98 Crore across the three phases. This is the unavoidable
backbone of the programme.

Our AI Posture Engine and firmware development is a one-time investment of ₹1.20 Crore in
Phase 1, with lower ongoing enhancement costs of ₹40 Lakh and ₹20 Lakh in Phases 2 and 3
respectively. Similarly, Analytics, Gamification, and CMS development is front-loaded at ₹80
Lakh in Phase 1.

VR headsets at ₹55,000 per gym zone add up to approximately ₹3.90 Crore over all three
phases. Installation, fit-out, and staff training add a further ₹1.40 Crore — lean costs for a
deployment of this scale.

Total Investment Summary

Total 3-Year CAPEX ₹40.07 Crore

Annual OPEX (licences, ₹4.80 Crore per year
support, content)
Total Cost of Ownership (3 ₹54 Crore
Years)
AR/VR SDK Licences ₹1,200 per unit
Garmin API (one-time) ₹4.15 Lakh

The Hybrid Buy-and-Build strategy is what keeps this cost efficient. If we had attempted to build
the mirror hardware ourselves, the engineering and manufacturing costs alone would have
dwarfed the ₹40 Crore CAPEX figure. By buying commodity hardware and building software IP
in-house, we optimise for both speed and long-term cost control.

Slide 6 — Impact & ROI

⏱ Suggested time: 3–4 minutes

Now for the question that matters most — what does CultFit get in return for this ₹54 Crore
investment?

Phase-by-Phase Impact
• Phase 1 (Year 1 — 150 gyms): ₹10.21 Crore deployed. Pilot results are projected to
show an 18% improvement in member retention at participating gyms — a meaningful
early proof point.

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 • Phase 2 (Year 2 — 300 gyms): ₹16.44 Crore deployed. Retention improves to 32%
above baseline. Incremental membership revenue from retained members reaches ₹9.6
Crore in this phase alone.
• Phase 3 (Year 3 — 250 gyms): ₹13.42 Crore deployed. The full 700-gym network is live.
Incremental annual revenue from the programme reaches ₹28 Crore per year at full
deployment.

Key Performance Indicators

The strategic KPIs we are targeting across the full deployment:

• Member Retention: From the current 45% to a projected 80% — a 35 percentage point
improvement. This single metric drives the majority of revenue upside.
• Session Duration: A 28% increase in average workout session length per member —
meaning members are more engaged and spending more time in the gym.
• Premium Plan Upsell: A 22% lift in members upgrading to premium membership tiers,
driven by the enhanced experience.
• Net Promoter Score: A projected NPS of +72, reflecting high member satisfaction and
word-of-mouth referral potential.

Financial Return

Total 3-Year Incremental ₹420 Crore

Revenue
Total Cost of Ownership (3 ₹54 Crore
Years)
3-Year ROI 2.1×
Payback Period ~32 months
Break-even Point 350 gyms live

A 2.1× return on a ₹54 Crore investment, with payback in under three years. These are
conservative projections — based on retention improvement alone, without factoring in premium
upsell or new member acquisition driven by word-of-mouth from an enhanced gym experience.

The Smart Mirror is not a cost centre. It is a revenue and retention engine.

Closing Remarks
⏱ Suggested time: 1–2 minutes

To summarise what we have presented today:

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 • CultFit has a significant and measurable in-gym experience gap — 55% member drop-
off in 90 days, no real-time coaching, and no immersive engagement technology.
• The Smart Mirror initiative deploys 2,100 AI-powered units across 700 gyms, delivering
eight core AR/VR features to every member on the gym floor.
• A Hybrid Buy-and-Build strategy allows us to move quickly using proven hardware, while
building proprietary AI, analytics, and gamification capabilities in-house.
• The total investment is ₹54 Crore over three years, generating ₹420 Crore in
incremental revenue — a 2.1× ROI with payback in approximately 32 months.

CultFit has the network scale to make this work. It has the member base to benefit from it. And it
has the strategic imperative to act now before competitors close the technology gap.

The Smart Mirror is how CultFit goes from India's largest gym network to India's most intelligent
gym experience.

We welcome your questions.

Glossary of Terms

The following terms are used throughout this presentation. This section provides clear
definitions for all audience members, regardless of technical background.

• AI (Artificial Intelligence): Software that uses data and algorithms to perform tasks that
normally require human intelligence — such as recognising body posture, understanding
voice commands, or predicting member behaviour.
• AR (Augmented Reality): Technology that overlays digital content — such as animated
trainer demonstrations or form-correction cues — onto a real-world view. In the Smart
Mirror context, AR graphics are projected onto the mirror surface while members see
their own reflection.
• VR (Virtual Reality): Fully immersive digital environments experienced through a
headset. Unlike AR (which overlays on reality), VR replaces the visual field entirely —
transporting a member to a virtual arena, mountain trail, or studio during their workout.
• Smart Mirror: A large-format interactive display (in this case, a 43-inch 4K screen)
embedded with a depth camera, processor, and connectivity — designed to function as
an AI fitness coach on the gym wall.
• Depth Camera / ToF Sensor: A camera that measures the distance between itself and
objects in its field of view using Time-of-Flight (ToF) technology. Used here to capture
3D body position and movement for skeleton tracking.
• Skeleton Tracking: The real-time identification and mapping of key body joints
(shoulders, elbows, hips, knees, ankles) to analyse movement, detect posture errors,
and score exercise form.

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• MediaPipe: An open-source AI framework from Google used for real-time body
landmark detection. The foundation of CultFit's custom AI Posture Engine.
• TensorFlow Lite: A lightweight version of Google's TensorFlow machine learning
framework, optimised for on-device inference on mobile and embedded hardware —
enabling AI processing without cloud dependency.
• On-Device Inference: Processing AI model outputs directly on the hardware unit (the
Smart Mirror), rather than sending data to a remote server. Ensures low latency, privacy,
and offline capability.
• OTA Update (Over-The-Air): The ability to remotely push software updates to devices
over the internet — allowing all 2,100 mirror units to be updated, patched, or upgraded
without physical access to each gym.
• CMS (Content Management System): A platform for managing and distributing digital
content. In this context, the CultFit CMS allows the team to control what is displayed
across all 700 gym mirrors from a central console.
• SDK (Software Development Kit): A pre-built set of tools, libraries, and APIs that
developers use to build features on top of a platform. PTC Vuforia and Unity XR are
examples of third-party SDKs used in this project.
• PTC Vuforia: An enterprise AR SDK used by CultFit to power the AR Trainer Overlay
feature. It enables stable, high-accuracy AR content rendered on the mirror surface.
• Unity XR: A cross-platform VR/AR development framework from Unity Technologies,
used to build the immersive VR Workout Zone environments.
• HTC Vive Focus: A standalone VR headset (no PC required) designed for enterprise
and commercial use. Used in CultFit gym VR zones for immersive workout sessions.
• Google Dialogflow CX: An enterprise-grade natural language processing platform from
Google that powers the Smart Mirror's Voice AI Coaching feature — understanding
spoken commands and delivering voice responses.
• Apple HealthKit: Apple's framework for accessing and sharing health and fitness data
from iPhone and Apple Watch. Enables seamless data sync between the Smart Mirror
and a member's Apple devices.
• Garmin Connect: Garmin's health and fitness data platform. Integration enables Smart
Mirror sync with Garmin wearables, broadening the wearables ecosystem support.
• DPDP Act 2023: India's Digital Personal Data Protection Act 2023 — the primary
legislation governing how personal data is collected, processed, and stored by
organisations operating in India. All Smart Mirror data processing is designed to be
compliant.
• CAPEX (Capital Expenditure): One-time spending on physical assets or technology
infrastructure — such as hardware procurement, software development, and installation
costs. The total 3-year CAPEX for this project is ₹40.07 Crore.
• OPEX (Operating Expenditure): Recurring costs of running the system after
deployment — including software licence renewals, content production, and technical
support. Annual OPEX is ₹4.80 Crore.
• TCO (Total Cost of Ownership): The complete cost of deploying and operating a
system over its life — CAPEX plus OPEX combined. The 3-year TCO for this project is
₹54 Crore.
• ROI (Return on Investment): A measure of the financial return generated relative to the
cost of investment. A 2.1× ROI means for every ₹1 invested, ₹2.10 is returned.

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 • NPS (Net Promoter Score): A customer satisfaction metric based on how likely
members are to recommend CultFit to others, scored from -100 to +100. A projected
NPS of +72 is considered excellent.
• Payback Period: The time required for the cumulative financial returns from the
investment to equal the total investment cost. The Smart Mirror programme is projected
to reach payback in approximately 32 months.
• Gamification: The application of game-like elements — leaderboards, streaks, badges,
challenges, and rewards — to non-game contexts. Used here to increase member
engagement and attendance frequency.
• B2B (Business-to-Business): Commercial transactions between two businesses, as
opposed to business-to-consumer. The Portl mirror hardware is procured at B2B pricing,
which is lower than retail rates.
• [Link]: A JavaScript runtime used for building fast, scalable backend services. Used in
CultFit's Gamification Backend microservices architecture.
• Hybrid Strategy: In the context of this proposal, the decision to Buy commercially
available hardware and licensed SDKs, while Building proprietary AI, firmware, and
software layers in-house — optimising for speed, cost, and IP ownership simultaneously.

Anticipated Questions & Answers

This section prepares presenters for the most likely questions from stakeholders — investors,
senior management, gym operations teams, and technology reviewers.

Q1: Why not use cheaper, off-the-shelf smart TVs instead of dedicated
Smart Mirror units?
Standard smart TVs lack the key elements that make this initiative technically possible: an
embedded depth camera for skeleton tracking, robust commercial-grade durability for a gym
environment, integrated touch capability, and the form factor of a mirror. The Portl units were
selected specifically because they meet all of these requirements at a B2B price that is still
competitive. A workaround using TVs would require separate camera mounts, custom housings,
and a far more complex integration — likely exceeding the cost of the Portl units while delivering
a worse member experience and a less reliable product.

Q2: What happens if a vendor like Portl or Microsoft discontinues the

hardware?
We have designed the software architecture to be hardware-agnostic at the OS and application
layer. The CultFit Mirror OS runs on Android 12, which means it can be ported to alternative
hardware relatively quickly if a vendor change becomes necessary. All critical intellectual
property — the AI Posture Engine, analytics platform, gamification backend, and CMS — is built
and owned by CultFit. Our 3-year B2B warranty contracts also provide commercial protection
and advance notice requirements before any product discontinuation.

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Q3: How will member data privacy be protected?
Privacy is embedded into the architecture, not bolted on. Our AI Posture Engine runs entirely
on-device — meaning skeleton tracking and movement analysis data is processed on the Smart
Mirror unit itself and never transmitted to an external server. No video footage is stored or
streamed. Aggregate, anonymised analytics data is used for the CRM dashboard. The entire
system has been designed for full compliance with India's Digital Personal Data Protection Act
2023. Members will also be able to opt out of analytics tracking without losing access to the core
training features.

Q4: What is the risk if member adoption is low in Phase 1?

Phase 1 is deliberately sized as a pilot — 150 gyms, 450 units. This phasing gives us a real-
world adoption signal before committing the full budget for Phases 2 and 3. Our ROI model
breaks even at 350 gyms, meaning Phase 1 and Phase 2 combined already cover the break-
even threshold. If Phase 1 pilot data shows adoption below target, we have defined decision
gates that allow us to course-correct — including modifications to onboarding programmes, UX
adjustments, or a revised deployment pace — before committing Phase 2 capital. The
programme is designed to be iterative, not all-or-nothing.

Q5: Why build the AI Posture Engine in-house rather than licensing an
existing solution?
Two reasons: cost and customisation. Off-the-shelf fitness AI solutions come with per-user
licensing fees that, at CultFit's scale of one million-plus members, would generate ongoing
OPEX well above our in-house development costs within 18 months. More importantly, a
licensed solution cannot be customised for CultFit's specific exercise library, terminology,
equipment setup, and member profiles. Our custom MediaPipe and TensorFlow Lite model can
be trained on CultFit-specific workout data, making it significantly more accurate for our use
case over time. This is a genuine source of IP differentiation.

Q6: How does this integrate with the existing CultFit app experience?
The Smart Mirror and the CultFit app are designed as connected endpoints of the same fitness
data ecosystem. Workout sessions initiated on the mirror sync automatically to the app — reps,
calories, form scores, and session summaries. Members can pre-configure their workout
preferences in the app and have them appear on the mirror when they arrive at the gym. Apple
HealthKit and Garmin Connect APIs ensure continuity with wearable devices. The gamification
features — streaks, leaderboards, rewards — are visible and actionable in both the app and on
the mirror. There is no siloed experience.

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Q7: What is the trainer's role in a Smart Mirror gym? Does this replace
trainers?
No — it elevates trainers rather than replacing them. The Smart Mirror handles the tasks that
trainers cannot perform at scale: monitoring form for every member simultaneously, providing
real-time feedback during sets, and tracking individual progress over time. Trainers are freed
from high-frequency, low-complexity correction tasks and can instead focus on programme
design, motivation, injury management, and personal training relationships — the high-value
interactions that members actually pay premium prices for. Our model projects trainer
productivity and member satisfaction improving simultaneously, not in opposition.

Q8: How long will Phase 1 deployment actually take from approval to go-
live?
Based on our implementation plan, from budget approval to the first 150 gyms going live, we
estimate approximately 9 to 12 months. This accounts for hardware procurement and delivery
lead times (approximately 6 to 8 weeks for 450 units at B2B scale), gym fit-out and installation
(approximately 2 weeks per batch), staff training, and software QA. A detailed Gantt-level
project plan is available for review, and our phasing approach allows early-adopter gyms to go
live progressively while remaining gyms are being prepared — minimising the operational
disruption of a big-bang rollout.

Q9: What does the ₹420 Crore revenue projection assume?

The ₹420 Crore incremental 3-year revenue figure is based on member retention improvements
alone — it does not include premium upsell revenue or new member acquisition driven by the
enhanced experience. Specifically, the model assumes: an improvement in the 90-day retention
rate from 45% to 80%, applied to the current base of 1 million-plus members, at an average
monthly spend of ₹900. Even at modest retention gains below our 80% target, the model
remains significantly ROI-positive. A full sensitivity analysis with bear, base, and bull scenarios
is available as a supporting appendix.

Q10: Has any other gym network deployed Smart Mirrors at this scale?
No gym network in India has deployed AI-powered Smart Mirrors at this scale. Globally, some
premium boutique studio chains in the US and UK — including Mirror (acquired by Lululemon)
and Tonal — have deployed home-use smart fitness hardware, but these are consumer
products for home environments, not gym-floor installations across a large multi-city network.
This is precisely the whitespace CultFit can own. Being first at this scale in India creates a
significant and difficult-to-replicate competitive advantage — both in the member experience it
delivers and in the proprietary fitness data asset it will generate over time.

Q11: What is the contingency plan if there are significant cybersecurity

risks?
Cybersecurity has been addressed at the architecture level. On-device processing eliminates
the largest attack vector — member data is not in transit between mirrors and external servers.

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All inter-system communication (mirror to CMS, mirror to app) uses TLS-encrypted APIs. The
Central Device Management system enables rapid security patches via OTA updates across all
2,100 units simultaneously — meaning a vulnerability can be patched network-wide within hours
of discovery. We have also structured vendor contracts to include security SLA commitments.
An independent security audit is planned prior to Phase 1 go-live.

Q12: What are the key risks to this programme, and how are they
mitigated?
We have identified four primary risks. First, hardware supply chain risk — mitigated by locking in
B2B contracts with Portl at the start of each phase and maintaining a buffer inventory. Second,
technology adoption by members — mitigated by in-gym onboarding staff during Phase 1,
tutorial content on the mirrors, and progressive feature rollouts that do not overwhelm first-time
users. Third, build cost overruns on the in-house software — mitigated by using established
open-source frameworks (MediaPipe, TensorFlow Lite, [Link]) and a fixed-cost development
sprint model. Fourth, regulatory changes to DPDP Act — mitigated by on-device processing
architecture that already exceeds current compliance requirements, providing a buffer against
future regulatory tightening.

End of Document

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