Privacy Policy

Introduction

This Privacy Policy describes how the 50 Above 50 competition and its website (the "50 Above 50") collect, use, disclose, and protect personal information. The 50 Above 50 competition ("Competition") is organized by Khyaal (Taisho Ventures Private Limited) (referred to as "Organiser", "we", "us", or "our"). This Policy applies to all users, including general visitors of our Site and individuals participating in the Competition. By visiting our Site or registering for the Competition, you agree to the practices described in this Privacy Policy. We are committed to handling your personal information in accordance with applicable Indian laws, including the Information Technology Act, 2000 and relevant data protection rules and guidelines.

Information Collected

We collect information to provide and improve our services, to administer the Competition, and for other purposes described in this Policy. The information we collect falls into two categories: Personal Information and Non-Personal Information.

Personal Information: When you interact with us, for example by registering for the Competition (either by self-nomination or nominating someone else) or contacting us, we may collect personal data such as:

Identity Details: Full name, date of birth (age).
Contact Information: Phone number, email address, mailing address, city and state of residence.
Demographic Information: Age (to ensure eligibility above 50 years), nationality or citizenship status (for eligibility as Indian/OCI/PIO), and, if applicable, gender or other profile information you choose to provide.
Competition Participation Data: Information related to your participation, such as talent category chosen, any biographical information or profile you provide, photographs, audio/video recordings of auditions or performances submitted, and any other information you share during registration or auditions.
Verification Documents: Copies of identification or age proof (e.g. PAN card, Aadhaar, passport, driver's license or other ID) may be requested to verify your age and identity for eligibility. These documents may contain sensitive personal data (such as identification numbers or date of birth); we collect and use them only for verification purposes.
Payment Information: If a registration fee is processed online, we (or our payment service provider) collect payment details. Note: We typically use secure third-party payment gateways to handle financial information (such as credit/debit card numbers or UPI details), and do not store your full financial information on our servers beyond what is necessary for transaction records (e.g., payment confirmation and transaction IDs).

Non-Personal Information: When you visit our Site (even if you do not register), we collect certain technical and usage data automatically:

Usage Data: Your IP address, browser type, device type, operating system, referring website, pages viewed, links clicked, and the dates/times of access. This information does not directly identify you but provides insights into how our Site is used.
Cookies and Similar Technologies: We use cookies and similar tracking technologies (described in more detail in the Cookies and Tracking section below) to collect information about your interactions with the Site, such as your preferences or log-in session information. This helps us improve user experience and site functionality.
Aggregated Data: We may also derive aggregated data from your personal information and usage data. For example, we might track the number of visitors to our Site or compile statistics on how participants heard about the Competition. This aggregated information does not identify individuals and may be used by us for analytical or marketing purposes.

We collect personal information directly from you when you provide it (such as through registration forms, nomination forms, or contacting us), and in some cases from third parties: for example, if someone nominates you for the Competition, the nominator provides your name and contact details. We assume that anyone nominating a third party has obtained appropriate permission to share that third party's information with us. Nominees will be contacted and given the opportunity to consent to this Privacy Policy and complete their registration.

Use of Information

We use the collected information for a variety of purposes related to the Competition and the operation of our Site. All use of personal information is done in accordance with applicable law and based on your consent or another valid legal basis. The purposes for which we use your information include:

Competition Administration: To process registrations and nominations for the 50 Above 50 competition, verify participants' eligibility (e.g., age and identity), and manage your involvement in the Competition. This includes scheduling auditions (online or offline), facilitating your participation in different rounds, and overall administration of the event.
Communication: To contact you regarding Competition matters. We will use your contact details to send important updates and information such as registration confirmations, audition details, results of various rounds, selection of finalists, and other announcements. We may also respond to your inquiries, provide customer support, and address any requests or issues you raise.
Provision of Services and Benefits: Participants of 50 Above 50 are entitled to certain benefits (for example, all registered participants receive a complimentary Khyaal Club membership on the Khyaal app if they are not already members). We will use personal information to facilitate these benefits - for instance, creating or activating your membership in our affiliated programs or apps, and delivering any associated services or products.
Publicity and Promotion: If you are selected as a finalist or winner, we may use your name, likeness (such as your photograph or video of your performance), city, and talent category for promotional purposes. This could include displaying winner or finalist details on our Site, social media channels, press releases, or other marketing materials related to the Competition. We will not excessively use personal details beyond what is necessary for these legitimate promotion interests of the Competition. By participating, you understand and consent that limited personal information may be made public in connection with Competition results and related promotions.
Marketing and Future Communications: With your consent, we may use your contact information to inform you about news, events, upcoming competitions (including future editions of 50 Above 50), products, services or initiatives that we believe may be of interest to you (especially those focused on senior citizens, as that is our core community). For example, we might send updates about our app, senior community events, or invitations to participate in subsequent chapters of the Competition. You will have the opportunity to opt-out of or unsubscribe from such marketing communications at any time if you do not wish to receive them.
Site Operation and Improvements: We use non-personal and aggregated information to operate and improve our website, ensure its functionality, and enhance user experience. For instance, analyzing how users navigate the Site helps us optimize design and content. We may also use cookies to remember your preferences and provide a more seamless experience (see Cookies and Tracking below).
Security and Fraud Prevention: To maintain the integrity of the Competition and the security of our platforms, we may use personal data to monitor for and prevent fraudulent activity, impersonation, misuse of our Site, or violations of Competition rules and our Terms & Conditions. If any participant is found to be providing false information or engaging in prohibited behavior, we will use the information we have to investigate and take appropriate actions (including disqualification or legal measures, if necessary).
Legal Compliance: To comply with our legal and regulatory obligations under Indian law. For example, we may use or disclose personal information as needed to fulfill reporting obligations, respond to lawful requests by public authorities, or exercise legal rights. We also retain certain financial transaction records for accounting and tax compliance.
Other Purposes with Consent: If we intend to use your personal information for any purpose not listed above, we will do so only with your explicit consent. You have the choice to grant or withhold such consent and, if given, you can withdraw it at any time as described in the Consent section below.

We ensure that personal data is used only for the purposes for which it was collected (or closely related purposes). If we need to use your data for a new purpose, we will seek your consent or provide you with notice as required by law.

Data Sharing and Disclosure

We value your privacy and handle your personal information with care. We do not sell or rent your personal information to third parties. However, in certain circumstances, we may share or disclose information to third parties, as outlined below, and always in compliance with this Policy and applicable laws:

Within Our Organization and Affiliates: Personal information will be accessible to a limited number of authorized personnel within the Organiser's company (Taisho Ventures Pvt. Ltd./Khyaal) who need to know such information for their duties. This includes teams responsible for managing the Competition (e.g., event management staff, judges/panel members, customer support, marketing, and technical/IT staff). All such persons are bound by confidentiality obligations. We may also share relevant data with our affiliated entities (such as the Khyaal app/platform team) to facilitate services like membership benefits or to improve our offerings for seniors, but always under strict privacy and security controls consistent with this Policy.
Service Providers and Vendors: We employ trusted third-party companies and service providers to perform certain functions on our behalf. This may include:

IT and Hosting Services: Providers of website hosting, cloud data storage, video streaming or content delivery networks, who enable our Site and online audition submissions to function reliably.
Payment Processors: Secure payment gateway services to handle any registration fees or transactions (they receive your payment details to process payments, under strict confidentiality and security).
SMS/Email Communication Services: Vendors that assist in sending out OTPs (one-time passwords for verification), bulk emails, SMS or WhatsApp notifications for Competition updates.
Marketing and Analytics Partners: Firms that help us with analytics (like Google Analytics) or email marketing (like newsletter distribution platforms), to improve our outreach and understand usage of our Site.
Event Partners: If we partner with event management companies, talent coordinators, or venue organizers for offline auditions or the finale event, we may share necessary details with them to coordinate those events (e.g., providing a list of registered participants for a region's audition event).

These third-party service providers are given access only to the information necessary for them to perform their specific services. They are contractually obligated to use the data solely for our purposes and to implement adequate security measures to protect your information. We require that they do not disclose or use personal data for any other purpose.
Judges, Mentors, and Competition Partners: During the Competition phases, audition materials (such as your performance video or profile) and relevant personal details (e.g., your name, age, and talent category) will be shared with members of our judging panel and any mentors or experts involved in evaluating entries. This is solely for the purpose of fairly judging the Competition. Judges and associated personnel are bound by confidentiality and are not permitted to use participant information outside the scope of the Competition. If we have celebrity judges or partners, they will only receive limited information necessary for judging or mentoring. Additionally, if the Competition has sponsors who provide prizes or special offers, we may share winners' or finalists' contact information with those sponsors strictly for prize fulfillment (for example, for delivering a prize or coordinating a winners' event), and not for general marketing unless you separately consent to such marketing by the sponsor.
Business Partners and Sponsors: The 50 Above 50 Competition may have corporate partners or sponsors (for example, organizations providing support, rewards, or co-hosting events). We will not share your personal details with these partners for their independent use without your consent. We may, however, share aggregated or anonymized data (e.g., total number of participants from each region or generic age group statistics) with sponsors for reporting the success of the event. If a sponsor or partner is to be given access to any identifiable personal information for collaborative purposes, we will ensure you are informed and consent is obtained as required. In no case will your sensitive personal information (like ID proofs or financial info) be shared with sponsors.
Legal Requirements and Protection of Rights: We may disclose personal information if required to do so by law or legal process, or if we in good faith believe that such action is necessary to: (a) comply with a legal obligation, government request, or court order; (b) enforce our Terms & Conditions or other agreements; (c) investigate and defend ourselves against any third-party claims or allegations; (d) detect, prevent, or otherwise address fraud, security, or technical issues; or (e) protect the rights, property, or safety of the Organiser, our users, participants, or the public. This includes exchanging information with law enforcement or other authorities when legally mandated.
Change of Business Ownership: In the event that our business (Taisho Ventures Pvt. Ltd. or the 50 Above 50 project) undergoes a merger, acquisition, restructuring, or sale of assets, or in the unlikely event of bankruptcy, personal data related to the Competition and Site may be transferred to the successor or acquiring entity. Any new entity will continue to be bound by the commitments in this Privacy Policy with respect to your personal information (unless you are notified of changes and given an opportunity to exercise applicable rights). We will inform you of any such transfer as required by law and endeavor to ensure the new owner maintains the same level of privacy protection for your data.
With Your Consent: Besides the situations outlined above, we will share your personal information with third parties only with your explicit consent. For instance, if you specifically agree to let us share your contact details with a media outlet for an interview, or you opt-in to receive communications from a sponsor or partner, we will honor that consent. You have the right to refuse or withdraw such consent at any time (see the Consent section below).

We strive to limit the personal information we share and to ensure that any third parties who receive it uphold privacy and security standards equivalent to our own. Whenever your information is shared, it is done in a secure manner and only to the extent necessary for the fulfillment of the above purposes.

Consent

By providing us with your personal information (through using our Site or registering for the Competition), you consent to the collection, use, and disclosure of that information in accordance with this Privacy Policy. We obtain consent in various ways and respect your choices regarding your data:

Obtaining Consent: In most cases, we will ask for your affirmative consent at the point of data collection. For example, when you fill out the online registration or nomination form for 50 Above 50, you will be required to agree to the Privacy Policy (and Terms & Conditions) by checking a box or clicking "I Agree". This consent covers our handling of your information as described herein. If you refuse to provide consent or required information, we may not be able to register you or the nominee for the Competition. In situations where consent is implied by your actions (such as when you voluntarily send us information via email or phone), we will use that information solely for the purposes relevant to that communication.
Consent for Nominations: If you are nominating someone else for the Competition, you must ensure you have the nominee's permission to share their personal details with us. We will reach out to the nominated person using the contact information provided to inform them of the nomination and direct them to this Privacy Policy and our Terms. The nominee's continued participation (such as submitting an audition or completing their registration) will serve as their consent to our collection and use of their data. If a nominee does not wish to participate or consent, we will delete their information collected from the nominator upon their request.
Withdrawal of Consent: You have the right to withdraw your consent at any time. For example, if you initially agree to receive promotional emails or to be contacted for future competitions, you can later opt-out. Every promotional email from us will contain an "unsubscribe" link to allow you to stop receiving that type of communication. Additionally, you can contact us at any time (see the Contact Information section) to withdraw consent to any further use of your personal information. Please note that withdrawal of consent will not affect the legality of any processing we conducted prior to your withdrawal. However, if you withdraw consent for us to use essential information (like your contact details or age verification) during an ongoing Competition, it may hinder our ability to include you in the Competition and could result in your disqualification or withdrawal from participation. We will inform you if such consequences arise so you can make an informed decision.
Choice and Opt-Out: Where applicable, we give you choices about the collection and use of your data. For instance, you may have the option to decline non-essential cookies via your browser settings or our cookie banner (see Cookies and Tracking below). You may also choose not to fill out certain optional fields in forms. However, please understand that failure to provide certain information may limit your ability to participate (for example, not providing proof of age means we cannot verify eligibility, so participation isn't possible).
Continued Use After Changes: If we update this Privacy Policy (as explained in Changes to the Policy), continued use of the Site or continued participation in the Competition after those changes take effect will constitute your consent to the revised terms, to the extent permitted by law. We will notify you of major changes to ensure you can review the updated policy and renew consent if required.

In summary, we seek to ensure that you are fully informed and have control over your personal data. We will not make unwarranted use of your information and will honor your rights to consent or object. If at any point you have concerns about how we handle your privacy preferences, please contact us so we can assist (see Contact Information for how to reach us).

Data Retention

We retain personal information for only as long as necessary to fulfill the purposes outlined in this Policy, or as required or permitted by law. The duration for which we keep different categories of data may vary based on the context of its collection and use. Our data retention practices are as follows:

Competition Data: If you register as a participant (or are nominated and then register) for 50 Above 50, we will retain your personal information for the duration of the Competition and a reasonable period thereafter. This allows us to administer the Competition (from auditions through finals) and handle any post-competition activities such as prize distribution or responding to queries/appeals. After the Competition concludes, we may retain your data for a certain period to address any follow-up matters (e.g., confirming winners, handling tax obligations for prizes, or resolving any disputes) and to contact you about future editions of the Competition if you have not opted out. Typically, personal data of participants may be kept for a few years after the Competition to facilitate the planning of future events (for example, to invite past participants or showcase alumni stories) - but we will only do so in line with the uses you have consented to and you may request deletion as described below.
General Inquiries: If you contact us through the Site or via email/phone for support or inquiries (without necessarily being a registered participant), we will retain the correspondence and your contact details for as long as needed to address your inquiry and any subsequent issues. Customer service communications may be kept for a short period for quality assurance and to have a history of your interactions in case you contact us again.
Usage Data: Non-personal data (like site logs and analytics data) may be retained for our internal analysis and security purposes. This data is generally aggregated or anonymized over time. Raw logs that contain IP addresses or device identifiers are typically retained for a limited period (for example, a few weeks or months) unless we need to keep them longer to investigate security incidents or abuse. Aggregated analytics reports may be kept longer but do not identify individuals.
Legal and Regulatory Obligations: We may need to retain certain information for longer periods if required by law. For instance:

Financial Records: Records of payments, invoices, or receipts (including registration fee transactions) are maintained as needed for accounting and tax compliance (often for a minimum of 7 years or as per tax law requirements).
Compliance and Disputes: If we are involved in a legal dispute or receive a legal request (such as from law enforcement or courts), we will preserve relevant information until the matter is resolved and no further appeal or action is expected. Also, if we have reason to believe that a participant has violated our rules or engaged in unlawful behavior, we may retain their data as necessary to cooperate with investigations or to pursue/defend legal claims.

Data Deletion: Once the retention period expires or the purpose of collecting your data is fulfilled, we will securely delete, dispose of, or anonymize your personal information. For example, if you decide not to participate in the Competition after registering, upon your request we can remove your personal details from our active databases (though we might keep minimal information like your name or email in a suppression list to ensure we honor no-contact requests). Similarly, copies of your identity proof used for age verification will not be kept longer than needed for verification. If stored electronically, they will be deleted; if physical, they will be securely destroyed, unless required for audit purposes. Audition videos or materials submitted may be deleted from our systems after the Competition unless you are among finalists whose content may be archived for historical record or promotional highlights (and even in such cases, you can request removal if you have concerns, subject to any overriding legitimate interest we might demonstrate).
Account Data: If any user accounts are created on our Site or related platforms for the Competition (for example, a login to check competition status or the Khyaal Club membership account created for participants), those account details will be retained as long as the account is active. If you choose to delete an account or if an account remains inactive for an extended period, we may remove or anonymize the personal data associated with it in accordance with our standard procedures and any applicable legal requirements.

Please note that even after you request deletion of your personal data, we may retain certain information in backup systems or as required to comply with law. However, such information will continue to be protected in accordance with this Policy and applicable laws. When we no longer need personal information, we ensure it is either securely destroyed or irreversibly anonymized so that you can no longer be identified from it.

Security Measures

We take the security of your personal information very seriously. In order to protect your data from unauthorized access, misuse, alteration, or destruction, we implement a range of technical, administrative, and physical security measures that are consistent with industry standards and as required under Indian law (including Section 43A of the Information Technology Act, 2000 and associated data security regulations). Key security practices in place include:

Encryption: Sensitive personal data and important transactions on our Site are protected via encryption. For example, our website is accessible only over HTTPS, meaning data transmitted between your browser and our servers is encrypted with SSL/TLS. If you submit personal information through online forms, or make payments, that data is transmitted securely. We also employ encryption or hashing for storing certain types of information (such as passwords, if any, are stored in hashed form).
Access Controls: We limit access to personal information strictly to authorized personnel and third parties who need that information for the purposes described in this Policy. Within our organization, access to participant data is granted only to employees or contractors on a need-to-know basis (for instance, the Competition management team, support team, etc.), and these individuals are bound by confidentiality obligations. Our databases and systems require authentication and adhere to the principle of least privilege (each user has the minimum access rights necessary for their role).
Secure Storage: Personal data collected by us is stored on secure servers. We use reputable cloud service providers and data center partners that employ high standards of security. We also ensure reasonable security practices and procedures as prescribed by the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011. This may include compliance with recognized standards or codes of best practices (for example, maintaining ISO 27001 certification or similar, if applicable, for our IT infrastructure) - in general, we strive to maintain security at or above the level considered reasonable under applicable law.
Firewalls and Monitoring: Our systems are protected by network security measures such as firewalls, intrusion detection systems, and monitoring tools that alert us to suspicious activities. We continuously update and patch our software, and maintain up-to-date antivirus and anti-malware protections to guard against emerging threats.
Employee Training and Policies: We train our staff about the importance of protecting personal information and require all team members to adhere to our internal privacy and security policies. Regular training and awareness programs ensure that employees handle data in compliance with this Privacy Policy and legal requirements.
Third-Party Safeguards: When we share information with third-party service providers (as described in the Data Sharing section), we ensure through contracts that they also implement appropriate security measures. We perform due diligence on our vendors' security practices and require them to report any data breaches immediately to us.
Payment Security: Any online payment processing is conducted via PCI-DSS compliant gateways, which use robust security controls. We do not store your payment card details on our systems beyond possibly the last few digits for reference; the sensitive data is handled by the payment processor.
Audit and Testing: We periodically review our data collection, storage, and processing practices, including physical security measures, to guard against unauthorized access. Security audits, vulnerability assessments, and penetration testing may be conducted to evaluate the strength of our safeguards and to make improvements where necessary.

While we employ strong measures to protect your data, it's important to note that no method of transmission over the internet or method of electronic storage is 100% secure. Thus, although we strive to protect your personal information, we cannot guarantee absolute security. In the unlikely event of a data breach or any incident affecting the security of your personal data, we will notify affected individuals and relevant authorities as required by law, and we will take all necessary steps to contain and remedy the breach.

It is also important for you as a user to take precautions. Please maintain the confidentiality of any credentials (e.g., a password or OTP) you use to access our services. If you suspect any unauthorized access or encounter any security issues on our Site, notify us immediately so we can assist and take appropriate measures.

User Rights

We respect your rights regarding your personal data. Under Indian law and our internal policies, individuals have certain rights and choices as to how their information is used. Below is a summary of your rights and how you can exercise them:

Right to Access: You have the right to request access to the personal information we hold about you. This includes details on what data we have, how we are using it, and who it may have been disclosed to. We will provide you with a copy of your personal data maintained by us, usually within a reasonable time. In certain cases, there may be a minimal administrative fee if the request is extensive, but we will inform you of any charges in advance and as permitted by law.
Right to Correction (Rectification): We strive to keep your personal information accurate and up-to-date. If you discover that any data we have about you is incorrect or incomplete (for example, an outdated contact number or a misspelled name), you have the right to request that we correct or update it. Upon verification, we will promptly correct any inaccuracies or augment incomplete information.
Right to Withdraw Consent: As noted in the Consent section, if our processing of your personal data is based on your consent, you have the right to withdraw that consent at any time. This includes opting out of marketing emails or any other voluntary data processing activity. To withdraw consent, you can use the specific opt-out mechanisms provided (such as unsubscribe links), or contact us directly with your request. Note that withdrawal of consent will not affect processing that has already occurred but will apply going forward.
Right to Object or Opt-Out: Even where processing is based on legitimate interests or another lawful basis, you may have the right to object to certain types of processing. For example, you can request that we stop using your information for direct marketing purposes at any time, and we will comply. If we ever engage in any automated decision-making or profiling that significantly affects you, you would have the right to object to that as well (however, at present, decisions in the Competition, such as judging outcomes, are made by human judges and voting, not solely by automated means).
Right to Deletion (Erasure): In some circumstances, you may request that we delete the personal information we hold about you. For instance, if you no longer want us to have your data and the data is no longer necessary for the purpose it was collected, you can ask that it be removed. We will honor such requests where feasible and where we have no lawful reason to retain the data. Do note, if you request deletion of data essential to running the Competition (like your identity/contact info) while the Competition is ongoing, we may have to treat it as a withdrawal from the Competition, as we cannot practically continue without that information. After the Competition, you can request deletion and, aside from information we must keep for legal reasons, we will erase your personal data from our active systems. Some residual information may remain in backups for a brief period but will be purged according to our retention policy.
Right to Data Portability: This right (more commonly provided under newer data protection laws such as the forthcoming Digital Personal Data Protection Act, 2023) allows you to request a copy of your personal data in a commonly used electronic format so you can transfer it to another service provider if needed. While Indian law does not yet explicitly mandate data portability at the time of this Policy, we will do our best to accommodate reasonable requests for export of your data in a usable format, should you require it.
Right to Grievance Redressal: If you have any grievances or complaints about how we are handling your personal data, you have the right to lodge a complaint with us and/or with the appropriate data protection authority. We have appointed a Grievance Officer (see Contact Information below) to address user grievances related to personal data. We encourage you to contact our Grievance Officer first, and we commit to attempt to resolve your concerns expeditiously (within the timeframe prescribed by law, which is ordinarily one month). If you are not satisfied with our response, you can seek further recourse through legal channels available under Indian law.
Right to Not be Subject to Unlawful Profiling: We do not engage in any profiling of users that would be considered discriminatory, sensitive, or otherwise unlawful. Participants are judged in the Competition based on talent and rules adherence by our judging panel and public voting for finalists, not by automated profiling. If you ever feel that decisions about you have been made unfairly or inaccurately, you have the right to query and contest such decisions.

To exercise any of your rights, please reach out to us via the contact details provided in the Contact Information section. For security purposes, we may need to verify your identity (for example, by confirming details we already have on file or asking for identification) before fulfilling certain requests, especially for access or deletion, to ensure that we do not disclose data to an unauthorized person. We will respond to your request within a reasonable timeframe and in accordance with applicable law. In some cases, certain legal exceptions may apply - for instance, we might not be able to provide certain information if it includes personal data about another individual, or we may refuse a deletion request if retaining the information is required by law - but we will explain any such limitations in our response.

We are committed to honoring your rights and ensuring you have control over your personal information. Your trust is important to us, and we will always strive to accommodate requests and maintain transparent communication regarding your data.

Cookies and Tracking

Our Site uses cookies and similar tracking technologies to distinguish you from other users and to enhance your experience. This section explains what these technologies are and how we use them.

What Are Cookies: Cookies are small text files that are placed on your device (computer, smartphone, etc.) when you visit a website. They allow the website to recognize your device and store certain information about your preferences or past actions. Cookies can be "session cookies" (which last only until you close your browser) or "persistent cookies" (which remain on your device for a set period or until you delete them).
Types of Cookies We Use:

Essential Cookies: These are necessary for the operation of our Site. For example, if our Site has login functionality or multi-step forms, essential cookies would enable you to stay logged in or remember your progress. Without these, certain services you request may not be provided.
Analytics Cookies: We use these to collect information about how visitors use our Site (e.g., which pages are visited most often, how users navigate between pages, any error messages encountered). This helps us improve the way our site works. We may use third-party analytics tools like Google Analytics. The information collected is generally aggregated and anonymous. It does not identify you personally, but it does help us understand user behavior in general. Google Analytics, for instance, may set its own cookies to perform these services; however, it provides information to us in a way that does not reveal your personal identity.
Preference Cookies: These cookies allow our Site to remember choices you make (such as your preferred language or region, or if you've seen a particular announcement so we don't show it again). This personalization makes your experience better.
Advertising or Social Media Cookies: Note: At present, the 50 Above 50 Site does not display third-party ads, so we do not actively use advertising cookies. We also do not embed social media plugins that track you (aside from simple links to our social pages). Should this change in the future, we will update this Policy. If any sponsor or partner content includes their own cookies, we will alert you or obtain consent as needed. Currently, our focus is on running the Competition, and our cookies are primarily for functionality and analytics.

Web Beacons and Similar Technologies: In addition to cookies, we might use small graphic images or other code (often called web beacons or pixel tags) on our Site or in our emails. These are tiny, invisible images embedded in a webpage or email that communicate to us whether a page was visited or an email was opened. For example, if we send a newsletter or competition update via email, we might include a beacon to count how many recipients opened the message. This helps us gauge the effectiveness of our communications. These technologies often work in conjunction with cookies.
Your Choices (Cookie Controls): When you first visit our Site, you may see a cookie notice or banner that alerts you to the use of cookies. In some cases, we might provide an option for you to manage your cookie preferences (accepting or rejecting certain categories of cookies). Regardless, you have the ability to control cookies through your browser settings. Most web browsers allow you to:

Block Cookies: You can typically configure your browser to refuse some or all cookies, or to prompt you before accepting a cookie from websites you visit.
Delete Cookies: You can delete cookies that have already been set. This can usually be done through a menu option like "Clear browsing data" or "Clear cookies".

Please note, if you disable or refuse cookies, some parts of our Site may become inaccessible or not function properly. For instance, if a cookie is used to remember your progress in a registration form, blocking cookies might mean you have to start over each visit.
Third-Party Tracking: Our Site does not knowingly permit third parties (other than the services mentioned, like analytics providers) to track your online activities across unrelated websites. We do not currently honor Do Not Track (DNT) signals due to the lack of an industry standard, but we only use tracking in the limited ways described. If we integrate any additional third-party features in the future that could collect your data (such as an embedded video player, social media widget, or sponsor's tool that can set cookies), we will inform you and handle those interactions in line with privacy best practices (obtaining consent if required).
Cookies in Advertising Emails: We do not have third-party advertisements on the Site, but if we ever run promotional campaigns or retargeting, cookies might be involved. For example, if in the future we advertise the Competition across the internet, we might use cookies or pixels to measure the effectiveness of those ads (like seeing if someone who clicked an ad ended up registering on our Site). If so, those would typically involve third-party advertising networks or social media (like Facebook Pixel or Google Ads cookies). As of the current policy date, our usage of such methods is minimal to none; any introduction of these would be reflected in an updated Privacy Policy and cookie notice.

We encourage you to review our Cookie use periodically. By using our Site without disabling cookies via your browser or via any provided opt-out mechanism, you consent to our use of cookies and similar technologies as described here. For more detailed information on cookies and how you can manage them, you may refer to guides on your specific browser's support site or visit informational resources such as aboutcookies.org. Remember, cookies help us make your experience with 50 Above 50 smoother, but you are in control of how they are used.

Third-Party Links

The 50 Above 50 website and communications may contain links to third-party websites or services that are not owned or controlled by us. Examples include:

Links to sponsors' or partners' websites (for example, a sponsor's logo on our Site might hyperlink to the sponsor's own website).
Social media links or handles (like links to our pages on Facebook, Instagram, or other platforms).
References or resources for additional information (such as news articles, blog posts, or an external FAQ related to the Competition or our parent company).

Please be aware that this Privacy Policy does not apply to third-party websites or services that we do not operate. We are not responsible for the content, privacy practices, or handling of information by any external sites. If you click on a third-party link, any data you provide or actions you take on the third-party site are governed by that third party's terms and privacy policy, not ours.

We strongly encourage you to review the privacy policies of every external site you visit after leaving our Site. This is especially important if you choose to share personal information or perform transactions on those sites. Third parties may have their own cookies, data collection tools, or solicit personal information from you.

For example, if our Site directs you to a media article on a news website, that news site may collect data about your visit or if you engage (like leaving a comment on that article). Or if you follow us on social media and interact with us there, the information you provide is also subject to the social media platform's policy.

We do our best to only associate with reputable third parties, and we might provide links for your convenience or to enrich your experience. However, once you leave our domain (50above50.com or khyaal.com), we have no control over how your data is handled. Therefore, we cannot be held responsible for any incidents that arise from your visit to third-party sites accessed through our Site.

If you find any third-party links on our Site that you believe are problematic (for example, the link is broken or you suspect it is unsafe), please notify us so that we can review it. Your safety and privacy are important to us even beyond our own Site, and we welcome feedback on ensuring a trustworthy environment.

In summary, exercise caution and due diligence when following external links. This Privacy Policy applies only to 50 Above 50 and Khyaal's own platforms and services.

Legal Basis and Compliance

We are dedicated to complying with all applicable Indian laws and regulations concerning data protection and privacy. Our data handling practices are designed to meet the requirements of the Information Technology Act, 2000 (IT Act) and the rules issued under it, as well as any other relevant statutes or guidelines in India. Key legal and regulatory frameworks we adhere to include:

Information Technology Act, 2000:We recognize and abide by the provisions of the IT Act that relate to data protection. In particular, Section 43A of the IT Act (and associated rules) mandates that companies implementing reasonable security practices to safeguard sensitive personal data, and provides for compensation in case of negligence leading to wrongful loss or gain. We affirm that we have instituted such reasonable security practices as described in the Security Measures section of this Policy.
Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (SPDI Rules): These rules, issued under the IT Act, define what constitutes "Sensitive Personal Data or Information" (SPDI) and lay down obligations for how organizations in India should collect, process, transfer, secure, and disclose such information. We comply with these rules by:

Clearly outlining our privacy practices in this Policy and making it available on our Site, thereby providing notice to users.
Obtaining consent for the collection and use of sensitive data (for example, if we collect ID proofs or health information, which are considered sensitive, we do so with your explicit consent and only for necessary purposes like verifying age eligibility).
Allowing you to review and correct information and providing contact details for grievance redressal (as described in User Rights and Contact Information).
Implementing reasonable security practices to safeguard SPDI, which may include following codes of best practices or international standards.
Only transferring personal data including SPDI to third parties or outside India in accordance with the law - i.e., ensuring the same level of data protection from the recipient and obtaining consent where necessary.

Data Protection Guidelines by Indian Authorities: We stay updated with guidelines and advisories issued by bodies such as the Ministry of Electronics and Information Technology (MeitY) and industry regulators concerning data privacy. For example, if any new advisory prescribes additional user rights or breach notification procedures, we will integrate those into our practices. We also monitor decisions by Indian courts or the Data Protection Authority (once established under new laws) to ensure our compliance remains current.
Digital Personal Data Protection Act, 2023 (DPDP Act): India has enacted a new comprehensive data protection law in 2023. While the implementation timelines and detailed rules of the DPDP Act are being rolled out, we are proactively aligning our practices with its principles. This Privacy Policy and our data handling ethos already incorporate many core concepts of the DPDP Act, such as purpose limitation, data minimization, storage limitation, and lawful basis for processing (consent or legitimate uses). As the DPDP Act comes into full effect and if any additional compliance requirements are mandated, we will update our policies and procedures accordingly to ensure full compliance with the law.
Jurisdiction and Cross-Border Data Transfer Our operations are primarily based in India, and we process and store data on servers located in India or in jurisdictions deemed to have adequate data protection. In the event we transfer personal data outside of India (for example, using a cloud service or email service whose servers are in another country), we shall do so in compliance with applicable Indian law. This means we will ensure the recipient of the data offers an equivalent level of data protection as provided under Indian law, or we will seek your consent for such transfer if required. By using our Site or providing your information, you consent to the processing of your information in India and to any such cross-border transfer and processing, in accordance with this Policy.
Lawful Bases of Processing: We process personal data only on lawful grounds. In most cases, the lawful basis is your consent (for example, you consent to our use of your data by agreeing to this Policy when you register). In other cases, processing may be necessary for the performance of a contract (e.g., the contract being the Competition's terms you agree to, where using your data is needed to fulfill our obligations to you as a participant). Sometimes we may process data to pursue our legitimate interests (such as ensuring the security of our platform or sending updates about our services to our members) - when we do so, we ensure this does not override your fundamental rights and freedoms. And of course, some processing is done to comply with legal obligations (for instance, retaining financial records for tax law compliance, or providing information to authorities under lawful orders).
Accountability: We understand that merely stating compliance is not enough; we actively maintain records and evidence of our data protection practices. This includes documenting consents obtained, training employees on privacy, keeping data inventories, and having internal checks (like audits or assessments) to verify that privacy controls are effective. If required by law or regulators, we will cooperate fully and provide whatever information is necessary to demonstrate our compliance.

By adhering to Indian privacy laws and continually updating our privacy program, we aim to protect your rights and build trust. In case of any conflict between this Privacy Policy and applicable Indian laws, the law will prevail, and we will adjust our practices accordingly. Our commitment is to maintain the highest standards of privacy and transparency with our users.

Children's Privacy

Protecting the privacy of minors is extremely important to us. Our Competition and website are not intended for children under the age of 18. We do not knowingly solicit or collect personal information from individuals under 18 years of age. Participation in the 50 Above 50 Competition is strictly limited to adults (individuals above 50 years of age as per the eligibility criteria). Similarly, our services and content are directed towards adult users (for example, senior citizens and those who nominate them, who are expected to be adults).

No Participation by Minors: If you are under 18, please do not attempt to register for the Competition, use our Site to submit any personal information, or engage with our services. In the registration and nomination process, we ask for date of birth to ensure participants are above the required age. Any minor who attempts to participate would be deemed ineligible, and we would not intentionally retain their personal data.
No Intentional Data Collection: We do not knowingly collect personal data from anyone under 18. For example, our forms and processes are designed for adults. If a minor (under 18) has provided us with personal information (such as by someone misrepresenting their age or a child using an adult's device), that was done without our knowledge or intent.
Steps Upon Awareness: If we become aware that we have inadvertently collected personal information from a person under 18, we will take immediate steps to delete such information from our records. For instance, if an underage individual somehow manages to register or if a parent/guardian informs us that their minor child provided data, we will promptly remove the data and cancel any associated registration or account. We may also take further steps as necessary to ensure that no further contact or processing occurs in relation to that data.
Parental Guidance: We encourage parents and guardians to be aware of their children's online activities. If a parent or guardian believes that their child (under 18) has submitted personal information to us, please contact us right away (see the Contact Information section below). We will work with you to investigate and, if applicable, erase any such information.
Limited Interaction with Minors: While our platform is not aimed at children, we recognize that minors might indirectly interact with our content (for example, a grandchild might see the Site when helping a grandparent to sign up). We advise adults to not share any unnecessary personal information about minors on our platform. Any testimonials, stories or content on our site that feature individuals may include minors only with appropriate consent and in compliance with all laws (e.g., if we showcase a senior's family including grandchildren in a story, we would do so only with the family's consent and in a child-friendly manner). However, such scenarios are rare and carefully managed.

In summary, we do not seek or wish to handle data of children under 18. The Competition is exclusively for an adult audience. By using our Site or services, you affirm that you are at least 18 years old (or using the Site under the supervision of an adult guardian who agrees to this Policy). If you are a minor, please exit our Site and do not attempt to use our services. We are committed to complying with all applicable child data protection regulations, and ensuring a safe experience for all users.

Changes to the Policy

We may update or revise this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. We encourage you to review this Policy periodically to stay informed about how we are protecting your information. Key points regarding changes to the policy include:

Notification of Changes: If we make any material (significant) changes to this Privacy Policy, we will notify users in an appropriate manner. This may include:

Posting a prominent notice on our website (for example, a banner or pop-up notification on the homepage or the Privacy Policy page indicating that the Policy has been updated).
Updating the "Last Updated" date at the top or bottom of this Privacy Policy page to reflect when the latest changes were made.
For registered participants or users for whom we have contact information, we may also choose to send an email or message informing you of the update, especially if the changes could affect your rights or obligations.

Scope of Changes: Changes to the Policy could be minor (such as clarifications or language tweaks) or major (such as adding new sections or changing how data is processed). Minor changes may be made without advance notice, but they will be reflected in the updated Policy text. Major changes, especially those that affect how your personal data may be used or shared, will either be communicated to you beforehand or at least clearly brought to your attention at the time of implementation.
Consent to Changes: If you continue to use our Site or services after a revised Privacy Policy has been posted, such continued use will be interpreted as acceptance of the updated terms, to the extent permitted by law. However, if the law requires that we obtain your explicit consent for any changes (for example, if a new use of your data requires fresh consent), we will do so. We will not enforce material changes retroactively on personal data we collected in the past without your consent, unless required by law.
Review Availability: The latest version of the Privacy Policy will always be available on our Site (likely accessible via a "Privacy Policy" link in the footer or menu). You can determine if there have been changes since your last review by checking the effective date or last updated date. We may also archive prior versions of this Privacy Policy and make them available for your review upon request, so you can see what changes have been made over time.
Reason for Updates: Possible reasons we might update this Policy include (but are not limited to): launching new features or services (which might involve new data uses), changes in our business structure, changes in the law (like the coming into force of new data protection regulations), or feedback from users/authorities that prompts a revision of our privacy practices.

We are committed to transparency. If you have questions about any changes or need clarification on any aspect of the Privacy Policy, please reach out to us (see Contact Information below). We will be happy to explain any updates and how they may impact you.

Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please do not hesitate to contact us. We value your feedback and are here to address any issues you may have. You can reach us through the following contact points:

Email: You can email us at support@50above50.com for any privacy-related inquiries or requests. (If you prefer, you may also reach out to our general support at care@khyaal.com, and your query will be routed to the appropriate team.) We aim to respond to emails promptly, typically within 2 business days. For requests to exercise your data rights (access, correction, deletion, etc.), please use email so that we have a clear written record of your request.
Postal Address: You may send written correspondence or requests to our office address below. Please include attention to "Privacy Team - 50 Above 50" or "Grievance Officer" so we can direct it properly:

Khyaal (Taisho Ventures Private Limited)
703, Star Hub, Building No. 1,
Behind ITC Grand Maratha Hotel,
International Airport Road, Sahar, Andheri (E),
Mumbai - 400059, Maharashtra, India.

If you send us a physical letter, kindly provide a clear return address or contact information so we can get back to you. Note that postal inquiries might take longer to receive and respond to due to mail delivery times.
Phone: For urgent matters, you may contact our office at +91-9820988336 or 022-49394949. These phone lines are attended during regular business hours (IST). Keep in mind that for certain requests (like detailed data access requests or formal complaints), we may still ask you to follow up in writing (via email or letter) so we can properly document and address your concerns.
Grievance Officer: In accordance with the SPDI Rules and Indian law, we have designated a Grievance Officer to address any grievances or concerns you have regarding your personal data. Our Grievance Officer is responsible for overseeing compliance with this Privacy Policy and resolving user complaints. You may contact the Grievance Officer at support@50above50.com (or by mail at the address above, Attn: Grievance Officer). Please include all relevant details in your complaint. The Grievance Officer will acknowledge your complaint within 36 hours (15 days is common in some policies, but SPDI requires expeditious resolution within 1 month) and endeavor to provide a resolution or response to your issue within one month from the date of receipt of your grievance, as mandated by law. We are committed to resolving all such matters fairly and efficiently.
Additional Contacts: If you have general queries about the Competition that are not privacy-related, you can also reach out via support@50above50.com or refer to our FAQ page on the Site. But for anything to do with your personal data or this Privacy Policy, the contacts above are the best way to reach our privacy team.

We appreciate the trust you place in us by sharing your personal information and we are here to uphold that trust. If you feel that we have not lived up to our commitments in this Privacy Policy or have any suggestions for improvement, we genuinely welcome your input. Your communications with us are treated with confidentiality and importance.

Thank you for reading our Privacy Policy. Your privacy is of utmost importance to us, and we will continue to protect it diligently.

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