This Privacy Policy governs the collection, use, storage, and disclosure of personal data by Noble Paul ("The Kultt", "we", "us", "our"), an individual resident of India who independently owns and operates The Kultt platform, in accordance with the Digital Personal Data Protection Act, 2023 (DPDPA), the Digital Personal Data Protection Rules, 2025 (DPDP Rules), the Information Technology Act, 2000, and other applicable Indian laws.
By accessing or using The Kultt platform ("Platform"), you ("Data Principal") consent to the practices described herein. If you do not agree, please discontinue use of the Platform immediately.
Noble Paul, operating as The Kultt, is the Data Fiduciary as defined under Section 2(i) of the DPDPA, 2023. We determine the purpose and means of processing your personal data. The Kultt is currently operated as an independent proprietorship and may later be transferred to or operated by a corporate entity, in which case users will be notified and this Policy will be updated accordingly.
We collect only such personal data as is necessary and proportionate for the purposes described below, consistent with the data minimisation principle under the DPDPA.
NOTE — We do not collect Sensitive Personal Data as defined under the Information Technology (Reasonable Security Practices) Rules, 2011, such as passwords (stored only as hashed values), financial data, health data, or biometric data.
We process your personal data strictly for the following purposes, each supported by an appropriate legal basis under the DPDPA:
We do not use your personal data for automated decision-making that produces legal or similarly significant effects on you without human review.
Under the DPDPA, 2023, we rely on the following legal bases for processing your personal data:
We obtain your free, specific, informed, unconditional, and unambiguous consent at the point of account registration and for any optional processing. You may withdraw consent at any time via your account settings. Withdrawal does not affect the lawfulness of prior processing.
Certain processing is permitted without consent where required by the State or necessary to comply with Indian law, court orders, judgments, or decrees, or where processing is necessary to prevent imminent harm to public order or safety.
Processing necessary to perform the contract between you and The Kultt (i.e., providing the Platform services you signed up for), consistent with the Indian Contract Act, 1872.
We do not sell, rent, or trade your personal data. We share personal data only in the following limited circumstances:
Third-party vendors engaged to operate the Platform (e.g., cloud hosting, email delivery, analytics). These processors are contractually bound to process data only on our instructions and in compliance with the DPDPA.
The Platform integrates with public APIs to display trending content metadata. We transmit only the minimum query parameters required to retrieve requested content information; no personal account data is shared with these services as part of normal Platform operation.
Where required by law, court order, or government direction under applicable Indian statutes including the IT Act, 2000, or a direction from the Data Protection Board of India.
In the event of a transfer of The Kultt to a corporate entity or successor operator, your data may be transferred accordingly. Users will be notified of any such transfer, and the successor will be bound to this Privacy Policy or a policy no less protective.
We retain personal data only for as long as is necessary to fulfil the stated purposes, in accordance with the purpose limitation principle under the DPDPA, and as required by applicable Indian law.
On expiry of the retention period or upon a valid erasure request, personal data is securely deleted or anonymised.
Under the DPDPA, 2023, you have the following rights in respect of your personal data processed by us:
You may request a summary of the personal data we hold about you and the processing activities carried out on it.
You may request correction of inaccurate or incomplete personal data and deletion of data that is no longer necessary for the stated purpose, subject to our legal retention obligations.
You may withdraw consent at any time via your account settings. Withdrawal does not affect prior lawful processing. Withdrawal may result in inability to use certain features of the Platform.
You may raise a grievance with our Grievance Officer. If unsatisfied, you may escalate to the Data Protection Board of India.
You may nominate another individual to exercise your rights in the event of death or incapacity.
To exercise any of the above rights, please contact our Grievance Officer using the details in Section 12. We will respond within the timeframes prescribed by the DPDP Rules.
We implement reasonable security safeguards as required under Section 8(5) of the DPDPA and the IT (Reasonable Security Practices) Rules, 2011, including:
BREACH NOTIFICATION — In the event of a personal data breach that is likely to adversely affect your rights or interests, we will notify the Data Protection Board of India and affected Data Principals in the manner and within the timeframes prescribed under the DPDP Rules, 2025.
The Kultt is not directed at children under the age of 18 years. In compliance with Section 9 of the DPDPA, we do not knowingly collect or process the personal data of children without verifiable parental or guardian consent.
Where a user is identified as a child (under 18), we will seek verifiable consent from the parent or lawful guardian prior to processing, and will not subject the child to any targeted advertising or tracking.
If you believe a child has provided personal data without appropriate consent, please contact our Grievance Officer immediately and we will take steps to delete such data promptly.
The Platform may use service providers whose servers are located outside India. Any transfer of personal data outside India is carried out in accordance with Section 16 of the DPDPA and the Government of India's notifications specifying permissible countries or territories for such transfer.
We ensure that any international data transfer is subject to appropriate contractual safeguards requiring the recipient to provide a level of data protection at least equivalent to that required under Indian law.
We do not transfer personal data to any jurisdiction that has been blacklisted or restricted by the Government of India under the DPDPA framework.
In accordance with Rule 12 of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, and Section 13 of the DPDPA, a Grievance Officer has been designated to address complaints and concerns regarding personal data processing.
If you are not satisfied with the resolution provided by our Grievance Officer, you may file a complaint with the Data Protection Board of India, once it becomes operational, in accordance with Section 27 of the DPDPA.
We may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or Platform features. Material changes will be communicated to you via email or a prominent notice on the Platform at least 30 days prior to taking effect, or earlier where required by law.
Continued use of the Platform after the effective date of any amendment constitutes your acceptance of the updated Policy. Where required by law, we will seek fresh consent for materially changed processing purposes.
The version history of this Policy, including previous versions, is available on request from our Grievance Officer.
For any questions, requests, or concerns related to this Privacy Policy or our data practices, please reach us at:
THIS POLICY IS GOVERNED BY THE LAWS OF INDIA. DISPUTES SHALL BE SUBJECT TO THE EXCLUSIVE JURISDICTION OF COURTS IN INDIA. · © 2026 THE KULTT. ALL RIGHTS RESERVED. OPERATED BY NOBLE PAUL.