Cult.fit's privacy policy, last updated in September 2021, predates the Digital Personal Data Protection Act 2023 and consequently exhibits significant compliance gaps. While it transparently outlines the categories of personal and sensitive data collected (including biometric and health information) and provides a contact for data modification/deletion, its consent framework is bundled with service terms, failing to meet the 'freely given,' specific, and granular requirements of DPDP Section 6. Critical omissions include a lack of defined data retention periods, absence of explicit DPDP Data Principal rights (such as nomination), and no clear mechanism for grievance redressal through the Data Protection Board. Furthermore, its blanket cross-border data transfer clause requires substantial revision to align with DPDP's stringent conditions. The policy's reliance on the older IT Act 2011 framework for security, while a baseline, is insufficient for the more robust security and accountability mandates of the DPDP Act 2023, especially given the sensitive nature of the data Cult.fit processes.
⚠️ No explicit DPDP Act 2023 reference — still relies on IT Act 2000 framework
⚠️ Consent mechanism bundled with service terms — not 'freely given' or granular per Section 6
+5 more gaps detected