Last Updated: 2nd December 2025 

Program Humanedge Essentials (“Program”) available at Project Serotonin (“Platform”) is offered by Bennett, Coleman and Co. Limited (“BCCL”) in partnership with Serotonin Sales India Private Limited (“Serotonin”) which operates websites sr.tn, join.sr.tn, app.sr.tn and the Project Serotonin mobile applications (collectively, the “Services”).  

By adhering and accepting this privacy policy you agree to provide your personal information  for collecting, storage to BCCL and for processing, storage and using it for the purposes of the said Services to Serotonin. Any references to (our, us, we) in this privacy policy refers to BCCL. 

You agree that BCCL has partnered with Serotonin and is only facilitating  you to access the  Platform and to connect to Project Serotonin/Services and therefore, we would only be collecting, storing personal information for the purpose of sharing the personal information to Serotonin, so that Serotonin could provide the Services. All Services shall be provided by Serotonin and therefore, BCCL shall not be liable for any reports or Services so availed from the said Project Serotonin. Any grievances if any can be directly reached out to the contact details provided by Serotonin which is available at email address: support@sr.tn and phone number at +91 89718 83752 

Therefore, by agreeing to the terms of this Privacy Policy you agree to also abide by the Privacy Policy of Serotonin which is available at https://www.sr.tn/privacy-policy. However, for avoidance of doubt, it is clarified that Serotonin shall be liable for your personal information which has been shared for providing the Services by Serotonin. Therefore, our liability is limed to collection  storage of personal information so that you can generate your user ID to log in to Serotonin webpages/application. 

BCCL for the purpose of offering the Program would only be providing its Platform to connect to Project Serotonin and therefore, it would only collect, store the Personal Information limited for sharing it to Serotonin, so that Serotonin could provide the Services. The processing, storage, usage of your personal information shall be done by Serotonin. 

 
You agree that on availing the Services, Serotonin shall provide a personalized micronutrition program that may include consultations, digital recommendations, and shipment of third-party manufactured supplements. By using Serotonin Services, you agree to the terms of the Privacy Policy available at https://www.sr.tn/privacy-policy (Serotonin Privacy Policy). and consent to the collection, use, processing, and disclosure of your information as described in Serotonin Privacy Policy. 
 
1) Eligibility & Age Limit 
‍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. 
 
2) Types of Data We Collect  
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. 
 
3) How We Collect Data 
‍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. 
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4) How We Use Data 
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. 
 
5) SMS/WhatsApp & Phone 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 humanedge@timesofindia.com.

6) Testimonials 
‍With your permission, we may publish your testimonial (e.g., first name and city). You may withdraw consent by contacting us. 
 
7) Payments 
We use third-party payment gateways, including Paytm (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 Patym’s Privacy Policy at https://paytm.com/company/terms-and-conditions?company=one97&tab=privacy   
 
8) Sharing & Disclosures 
‍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). 
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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. 
 
9) Data Retention 
‍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. 
 
10) Cookies & Analytics 
‍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. 
 
11) Security 
‍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. 
 
12) Your Rights & Choices 
‍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 humanedge@timesofindia.com  ‍Delete/Close Account: email to humanedge@timesofindia.com  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. 
 
13) Children’s Privacy 
‍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. 
 
14) Contact 
For any disputes / grievances, please contact: 
Email:  humanedge@timesofindia.com   
Phone: + 91 86579 66580 
Address:  The Times of India Building, Dr. D. N. Road, Fort, Mumbai - 400 001 
 
15) Changes to this Policy 
‍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. 
 
16) Governing Law 
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.