Privacy Policy

BCCL Program is intended for individuals 18+. If you are under 18, you may use the BCCL Program and Services offered by Serotonin only with the consent and supervision of a parent/guardian.

Personal Data: name, age/date of birth, gender, contact details (email, phone, address), account credentials, payment and billing details (tokenized—see Section 7), shipping details, and any other information you provide.

Usage Data: IP address, device/OS/browser type, pages viewed, timestamps, referral URLs, and cookies (see Section 10).

User Communications: messages, emails, support chats, in-app notifications, testimonials/feedback (posted only with consent).

SMS Consent Data: your phone number and opt-in status for receiving transactional/marketing SMS.

Anonymous/De-identified Data is information that cannot reasonably identify you (e.g., aggregated analytics). We may create and use Anonymous Data for research, analytics, and product improvement.

Directly from you when you create an account, complete forms, subscribe, chat with us, or submit feedback. Automatically via our apps/websites and hardware (telemetry, logs, cookies, analytics). From third parties you connect to us (e.g., authentication providers, wearable device providers) or as permitted by law.

We use your data to:

Provide and improve Services: create/manage accounts; authenticate logins; fix bugs; improve algorithms.

Process payments and subscriptions; handle invoices.

Communicate with you: service/transactional messages (policy/feature updates, security alerts); optional marketing with consent (you can opt out anytime).

Security & compliance: detect/prevent fraud, spam, abuse; enforce Terms; comply with legal obligations.

Research & analytics: de-identified/aggregated analysis to enhance efficacy of our program and Services.

We do not use your precise location for advertising and we do not sell your Personal Data.

We collect your phone number with explicit opt-in to send transactional updates and, where permitted, marketing. You can opt out at any time via provided instructions or by contacting care@humanedge.co.

With your permission, we may publish your testimonial (e.g., first name and city). You may withdraw consent by contacting us.

We use third-party payment gateways, including Razorpay (for India), to process payments securely. Your card/bank information is collected, encrypted, and processed directly by these gateways. We do not store raw card or banking details on our servers. For more information, please review at https://razorpay.com/privacy/

We share Personal Data only to operate the Services offered by Serotonin or as required by law:

Payment Providers: Paytm to process payments, prevent fraud.

Cloud/IT & Support Vendors: secure hosting, analytics, error/crash reporting, customer support/chat, email/SMS service providers.

Professional Advisors & Compliance: auditors, lawyers, accountants, regulators as legally required.

Affiliates/Corporate Transactions: with our affiliates or in connection with merger, acquisition, financing, or sale of assets (where the successor assumes privacy obligations).

Legal/Security: to comply with law, enforce Terms, or protect our rights/users' safety. We require service providers to safeguard Personal Data and to use it only for the services they perform for us.

We retain Personal Data as long as your account is active and as needed for the purposes above. Unless you request deletion sooner (see Section 12), we typically retain records for at least 10 years or longer where required for legal, accounting, tax, audit, or fraud-prevention purposes. De-identified/aggregated data may be retained indefinitely.

We use cookies and similar technologies to remember preferences, keep you signed in, and analyze usage. You can control cookies via your browser settings; disabling certain cookies may limit features. We use analytics services to understand product usage; these providers may process pseudonymous identifiers as described in their policies.

We use administrative, technical, and physical safeguards (encryption in transit, access controls, credential protection, least-privilege access). No method is 100% secure; we cannot guarantee absolute security.

Subject to applicable laws of India, you may:

Access/Update your profile information on the Platform or by messaging us via chat or by emailing care@humanedge.co

Delete/Close Account: email to care@humanedge.co for data-deletion or to initiate account closure. We will delete Personal Data except where we must retain limited records for legal, accounting, compliance, or dispute-resolution purposes.

Opt-out of marketing emails/SMS at any time (unsubscribe link or message instructions). Transactional/service communications will still be sent.

Disable cookies via your browser.

Withdraw consent for specific processing where consent is the legal basis.

We do not knowingly collect Personal Data from children under 18. If you believe a minor has provided Personal Data, contact us to delete it.

For any disputes / grievances, please contact:

Email: care@humanedge.co

Phone: +91 86579 66580

Address: Cortis Health Building, Dr. D. N. Road, Fort, Mumbai - 400 001

We may update this Policy from time to time. The "Last updated" date will change accordingly. Material changes will be notified via the Platform/email or on this page. Continued use of the Services after changes means you accept the updated Policy.

This Privacy Policy shall be governed by and construed in accordance with the applicable laws of India any disputes shall be subject to the exclusive jurisdiction of the courts in Mumbai, India.

By accessing HE Website ("Website") and its services (for example, when you visit our application or website and browse through various other portions of our websites or register via social media or via the registration form), you agree to provide consent to our collection, use, processing and sharing of your personal information as described in this Privacy Policy. In some cases, particularly if you reside in a country governed by a data protection regulation, we may ask you to provide explicit consent to access our services before proceeding for further operations.

'Personal Information' or 'PII' is defined as any information that identifies (whether directly or indirectly) to a particular individual or natural person, such as the individual's name, postal address, email address, mobile number and any other identifier indicating to that particular person. When anonymous information is directly or indirectly associated with personal information, the resulting information also is treated as personal information.

By submitting your details, requesting a callback, registering your interest, or otherwise proceeding through the microsite, you consent to HE collecting and processing your data for the purposes of enquiry handling, callback coordination, enrolment facilitation, sharing relevant details with Twin Health, and such other service-related purposes as are disclosed herein. Where required under applicable law, your consent shall also cover the use of relevant user-level data for providing, operating, and enhancing the services made available to you.

The Company respects the privacy of the users of the Services they use and is committed to reasonably protect it in all respects. The information about the user as collected by the Company are:

• Information supplied by users
• Information automatically tracked while navigation
• Inferred information through usage and log data
• Information collected from any other sources (like third party providers or social media platforms) name, mobile number, email address, city/location, and other contact/enquiry details submitted by you;
• records of your interest in or request for access to Twin Health services;
• communications and correspondence relating to such enquiry or onboarding;
• consent records and acknowledgements; and
• such user-level data, including n-1 data*, as may be collected by HE for facilitating, providing, administering, supporting, and enhancing the relevant services, subject to applicable law

*"n-1 data" for the purposes of this microsite means user-level data relating to an identifiable or reasonably identifiable individual user, other than anonymised or aggregated data, and may include service interaction data, enrolment-related data, communications data, and such other data as may be reasonably necessary for facilitating, operating, supporting, and improving the relevant services, subject to applicable law.

When you register on the website for the service, we ask that you provide basic personal information from you to continue to interact with you and to continue providing you the Services. Information that we collect includes –

• Name
• Phone Number
• Email Address
• Educational Information
• IP Address
• Photograph
• Occupation Details

HE may process Microsite Data for the following purposes:

• to receive and respond to user enquiries;
• to coordinate callbacks, appointments, or follow-ups;
• to facilitate your access to or enrolment with Twin Health;
• to share relevant enquiry and onboarding details with Twin Health;
• to operate, administer, support, troubleshoot, and improve the microsite and related facilitation workflows;
• to use relevant user-level data, including n-1 data, for providing and enhancing the services made available to you, where permitted and/or consented to under applicable law;
• to maintain records, comply with legal obligations, resolve disputes, and enforce applicable terms

We may collect additional information at other times, including but not limited to, when you provide feedback to HE or you change your content or email preferences, respond to a survey, or communicate with us. This includes information automatically collected while browsing/navigating through the website.

HE may share your relevant personal data, enquiry details, consent records, and such other information as may be necessary with Twin Health for callback, onboarding, enrolment facilitation, service administration, and related purposes. Once your information is shared with or collected directly by Twin Health for the underlying services, Twin Health shall process such data in accordance with its own applicable privacy notices, consents, and legal obligations.

Unless expressly stated otherwise at the point of collection, HE does not seek to collect or access detailed medical records, clinical notes, prescriptions, diagnostic reports, or consultation records through the microsite. To the extent any health-related or service-related user-level data is collected by HE for facilitating and improving services, such collection shall be limited to what is necessary, shall be subject to applicable law and consent requirements, and shall not extend beyond the stated purposes. Detailed health-service data collected and processed for the underlying program may be handled directly by Twin Health under its own applicable documentation.

Where processing of your data for the Twin Health microsite depends on your consent, you may withdraw such consent in accordance with applicable law. However, if you do not provide or withdraw consent for data processing or sharing that is necessary for callback coordination, onboarding, or service facilitation, HE may be unable to process your request or enable access to the relevant services.

To improve the responsiveness of the Website for our users, we may use cookies, or similar electronic tools to collect information to assign each visitor a unique, random number as a User Identification (User ID) to understand the user's individual interests using the identified computer. Unless you voluntarily identify yourself (through registration, for example), we will have no way of knowing who you are, even if we assign a cookie to your mobile/computer. The only personal information a cookie can contain is information you supply. A cookie cannot read data off your hard drive. Our advertisers may also assign their own cookies to your browser (if you click on their ads), a process that we do not control. We receive and store certain types of information whenever you interact with us via the application.

We may track certain information about you based upon your behaviour on using HE services. We use this information for conducting internal research on our users' demographics, devices, interests, and behaviour to better understand, protect and serve our users. We may also collect Your Information to track user behaviour and preferences for internal analytics and research. We may also use your information To evaluate your interest for various genres of content, services, offers; To perform analytics and conduct customer research, to determine your interest, for identifying content that generate sales and to analyse traffic patterns.

If you choose to post messages on social media accounts, message boards, or other message areas or leave feedback, we will collect that information you provide to us. We retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law. The above information may also be captured on our Website by our affiliates for the purposes mentioned above If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on our services, we may collect and store such information.

Information obtained from other sources: We may obtain updated contact information from third parties in order to correct our records and fulfil the Services or to communicate with you.

Demographic and purchase information: We may refer other sources of demographic and other information in order to provide you with more targeted communications and promotions. We use Google Analytics, among others, to track the user behaviour on our website. Google Analytics specifically has been able to support display advertising towards helping us gain understanding of our users' demographics and interests. The reports are anonymous and cannot be associated with any individual personally identifiable information that you may have shared with us.

Links to third party Application or websites: The website may include links to other websites or applications. Such websites or applications are governed by their respective privacy policies, which are beyond our control. Once you leave our servers (you can tell where you are by checking the URL in the location bar on your browser), use of any information you provide is governed by the respective privacy policy of the operator of the application, website you are visiting. That policy may differ from ours. If you can't find the privacy policy of any of these sites via a link from the application's/website homepage, you should contact the application/website owners directly for more information. We do not provide any personally identifiable information to third party websites/advertisers/ad-servers without your explicit consent.

We will only collect and process Personal Information about you where we have lawful basis. Lawful basis on which we would process your Personal Information includes obtaining explicit consent from you or processing for "legitimate interests" where processing is necessary by us to provide you with Services (For e.g. processing your information by our group companies/affiliates).

We use information to provide, analyse, administer, enhance and personalize our service and marketing efforts, to process your registration, to provide you services, and to communicate with you related to below mentioned points. For example, we use information to:

• To help advertisers understand our audience and confirm the value of advertising on our websites or applications (however it is usually in the form of aggregated statistics on traffic to various pages within our site) and to provide you relevant ads
• Communicate with you concerning our Services (for example by email, push notifications), so that we can send you news about HE, details about new features and content available on the HE Services, promotional announcements, and surveys, and to assist you with operational requests such as password reset requests.
• Notify you about changes in terms of service or privacy policy
• Allow you to participate in interactive features offered through our Services
• Sharing with our customer support team, unrelated third-party counsellors and career guidance experts to resolve your queries/concerns related to your rights or Services provided to you.

The Personal Information supplied by you enables us to improve our Services and provide you the most user-friendly experience(s). In some cases for e.g. provision of certain service(s) or utility(ies), we may require your contact information as well. All required information is service dependent and the Company may use the above said user Information to, maintain, protect, and improve the Services (including advertising) and for developing new services.

Any personally identifiable information provided by you will not be considered as sensitive if it is freely available and/or accessible in the public domain like any comments, messages, blogs, scribbles available on social platforms like Facebook, twitter etc. Any posted/uploaded/conveyed/communication by users on public sections of the Website becomes published content and is not considered personally identifiable information subject to this Privacy Policy. In case you choose to decline to submit personally identifiable information on the application/websites, we may not be able to provide certain Services on the application/websites to you. In any case, we will not be liable and or responsible for the denial of certain services to you for lack of you providing the necessary Personal Information.

When you register with our Services, we may contact you from time to time about updating your Personal Information to provide you features that we believe may benefit/interest you.

The Company shares your information with any third parties without obtaining the prior consent of User in the following limited circumstances:

• When it is requested or required by law or by any court or governmental agency or authority to disclose, for the purpose of verification of identity, or for the prevention, detection, investigation including cyber incidents, or for prosecution and punishment of offences. These disclosures are made in good faith and belief that such disclosure is reasonably necessary for enforcing these Terms or for complying with the applicable laws and regulations.

The Company proposes to share such information within its group companies and officers and employees of such group companies and such third-party entities for the purpose of processing Personal Information on its behalf. We also ensure that these recipients of such information agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.

• The Company may present information to its advertisers – to help them understand its audience and confirm the value of advertising on our websites or applications – however, it is usually in the form of aggregated statistics on traffic to various pages within our site.
• The Company may share your information regarding your activities on websites or applications with third party social websites to populate your social wall that is visible to other people however, you will have an option to set your privacy settings, where you can decide what you would like to share or not to share with others.

We will take reasonable steps to accurately record the Personal Information that you provide to us and any subsequent updates, subject to any requirement for such Personal Information or sensitive personal data or information to be retained by law or for legitimate business purposes.

We encourage you to review, update, and correct the Personal Information that we maintain about you, and you may request that we delete Personal Information about you that is inaccurate, incomplete, or irrelevant for legitimate purposes, or are being processed in a way which infringes any applicable legal requirement. If you would like to review, change or delete Personal Information we have collected from you, or permanently delete your account please contact the Grievance Officer:

• Email: care@humanedge.co
• Phone: +91 86579 66580
• Address: Cortis Health Building, Dr. D. N. Road, Fort, Mumbai - 400 001

We ask individual users to identify themselves and the Personal Information requested to be accessed, corrected or removed before processing such requests. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.

Your right to review, update, correct, and delete your Personal Information may be limited, subject to the law of your jurisdiction.

HE Website is not intentionally designed for or directed at persons less than 18 years of age. HE does not knowingly permit any person who is under 18 years of age to register with the Services or to provide any other personally identifying information. If HE becomes aware that any personally identifiable information of persons less than 18 years of age has been collected on HE Services without parental consent, then HE will take the appropriate steps to delete any such Personal Information and notify the parent, provided HE has their contact coordinates.

However, we consider that it the responsibility of the parents to monitor their children's use of our Services. Nevertheless, it is our policy not to collect and process any Personal Information from children below 18 years of age or offer to send any promotional materials to persons in that category. HE does not seek or intend to seek or receive any Personal Information from children. Should a parent or guardian have reasons to believe that a minor has provided HE with Personal Information without their prior consent, please contact our customer support team to ensure that the Personal Information is removed from the HE Services.

• If your requests are unreasonably excessive or repetitive,
• Where the rights or safety of another person or persons would be jeopardized, or

If the information or material you request relates to existing or anticipated legal proceedings between you and us, or providing access to you would prejudice negotiations between us or an investigation of possible unlawful activity. Your right to review, update, correct, and delete your Personal Information is subject to our records retention policies and applicable laws, including any statutory retention requirements.

We operate globally and may transfer your Personal Information to individual companies of the HE affiliated companies or third parties in locations around the world for the purposes described in this Privacy Policy. Wherever your Personal Information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your Personal Information. Additionally, when using or disclosing Personal Information transferred from the European Union, we use standard contractual clauses approved by the European Commission, adopt other means under European Union law for ensuring adequate safeguards.

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store Personal Information. All information gathered on the Website is securely stored within the HE controlled database. The database is stored on servers secured behind a firewall; access to the servers is password-protected and is strictly limited. However, as effective as our security measures are, no security system is impenetrable. If you know or have reason to believe that your HE account credentials have been lost, stolen, altered, or otherwise compromised or in case of any actual or suspected unauthorized use of your account, please contact us by contacting our customer support team.

The internet is an ever evolving medium. We may alter our Privacy Policy from time to time to incorporate necessary changes in technology, applicable laws or any other variant. In any case, we reserve the right to change (at any point of time) the terms of this Privacy Policy or the Terms of Use. Any changes we make will be effective immediately on notice, which we may give by posting the new policy on the Website. Your use of the Website or Services offered through the Website after such notice will be deemed acceptance of such changes. We may also make reasonable efforts to inform you via electronic mail. In any case, you are advised to review this Privacy Policy periodically on the Website to ensure that you are aware of the latest version. Because of the way we maintain certain Services, after you delete your information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.

If you require any information or clarification regarding the use of your Personal Information or this Privacy Policy or grievances with respect to use of your Personal Information, please contact:

• Email: care@humanedge.co
• Phone: +91 86579 66580
• Address: Cortis Health Building, Dr. D. N. Road, Fort, Mumbai - 400 001

The data controller for our services is Cortis with the business address of: Cortis Health Building, Dr. D. N. Road, Fort, Mumbai - 400 001

If you have any queries, complaints regarding the collecting, processing, transfer of personal data/Personal Information or regarding this Privacy Policy, please do contact our Data Protection Officer.

Any complaints, abuse or concerns with regards to the processing of information provided by you or breach of these terms shall be immediately informed to the designated Grievance Officer as mentioned below via in writing or through email signed with the electronic signature to or

• Email: care@humanedge.co
• Phone: +91 86579 66580
• Address: Cortis Health Building, Dr. D. N. Road, Fort, Mumbai - 400 001

We request you to please provide the following information in your complaint:-

• Identification of the information provided by you;
• Clear statement as to whether the information is personal information or sensitive personal information;
• A statement that you have a good-faith belief that the information has been processed incorrectly or disclosed without authorization, as the case may be;
• A statement, under penalty of perjury, that the information in the notice is accurate, and that the information being complained about belongs to you;
• You may also contact us in case you have any questions / suggestions about the Privacy Policy using the contact information mentioned above.

HE shall not be responsible for any communication, if addressed, to any non-designated person in this regard.