1. Introduction
This Privacy Policy explains how ACCORGMINDS PRIVATE LIMITED (“Company”, “we”, “us”, “our”) collects, uses, stores, discloses, and protects information when you (“User”, “Client”, “you”) access or use ApnaTheka — Smart Wine Shop ERP and the website accorgwines.com (collectively, the “Services”). By using the Services or making a payment to us, you consent to the practices described in this Policy.
This Policy is published in compliance with the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and the Digital Personal Data Protection Act, 2023.
2. Definitions
- “Company” / “we” / “us” / “our” means ACCORGMINDS PRIVATE LIMITED, a company registered under the Companies Act, 2013 (CIN: U62099RJ2025PTC108933).
- “Services” means the cloud-based Software-as-a-Service product ApnaTheka — Smart Wine Shop ERP, including billing, inventory, accounting, compliance, and reporting modules built for licensed liquor retailers (theka shops) and allied businesses in Rajasthan and other Indian states.
- “User” / “Client” means any individual, proprietorship, firm, or company that registers, subscribes to, or otherwise uses the Services.
- “Personal Data” means any information that relates to an identified or identifiable natural person.
- “Payment Information” means any data shared during a payment transaction, including UPI ID, masked card details, bank account details, and transaction reference numbers.
3. Company Details
Legal Name: ACCORGMINDS PRIVATE LIMITED
CIN: U62099RJ2025PTC108933
Registered Office: 2nd Floor, AMJ Royal Tower, Opp. Police Line, Bikaner – 334001, Rajasthan, India
Email: accorgminds@gmail.com
Phone: +91 8619700971
Website: https://accorgwines.com
Grievance Officer: Mr. Subhash Saran · accorgminds@gmail.com · +91 8619700971
4. Information We Collect
4.1 Account & Identity Information
- Full name, email address, mobile number, WhatsApp number
- Login credentials (passwords are stored only as salted hashes)
- Profile photo (optional)
4.2 Business Information
- Shop / firm name, address, city, state, PIN code
- GSTIN, PAN, Excise / Liquor Licence number, FL/RL/CL category
- Bank account details (only when shared by you for invoicing or reconciliation)
4.3 Operational Data
- Sales, purchase, stock, day-close, parcha, and accounting transactions you record in the ERP
- Customer / distributor master data you create within your tenant
- Reports, exports, and dashboards generated through the Services
4.4 Payment Information
We use third-party payment aggregators including (but not limited to) PhonePe Payment Gateway and other Reserve Bank of India (RBI) authorised aggregators to process subscription payments. We do NOT store your full card number, CVV, UPI PIN, or net-banking credentials on our servers. Our payment partners are PCI-DSS compliant and handle these data points directly. We retain only:
- Transaction ID / order reference
- Amount, currency, status (success / failure / refund)
- Masked instrument details (e.g., last 4 digits of card, UPI handle)
- Invoice and GST records as required under Indian tax law
4.5 Technical & Usage Data
- IP address, browser type, device information, operating system, time-zone
- Login activity, action logs, and audit trails within the application
- Cookies and similar tracking technologies (see Section 11)
4.6 Communications
- Emails, support tickets, and chat messages you send to us
- WhatsApp messages exchanged through our Business API (with your consent)
5. Purpose of Processing
We process your data strictly for the following purposes:
- Creating and maintaining your tenant account and providing the Services
- Processing subscription payments, generating tax invoices, and reconciling transactions
- Sending transactional alerts (OTP, daily parcha summary, billing reminders, payment receipts) over Email / WhatsApp / SMS
- Providing customer support and resolving issues you report
- Detecting fraud, preventing abuse, securing our infrastructure, and maintaining audit trails
- Complying with applicable laws — GST, Excise, Income Tax, Companies Act, IT Act, DPDP Act
- Improving the Services through aggregated, anonymised analytics
6. Legal Basis for Processing
- Your express consent at the time of sign-up and payment
- Performance of the subscription contract you have entered into with us
- Compliance with our legal obligations
- Our legitimate interests in operating, securing, and improving the Services
7. How We Share Information
We do not sell, rent, or trade your Personal Data. We share data only in the following circumstances:
- Payment Aggregators: PhonePe Payment Gateway and other RBI-authorised aggregators receive the minimum data needed to process your payment (name, email, mobile, amount, order ID).
- Cloud & Infrastructure Providers: Reputable hosting, database, email-delivery, and WhatsApp Business API providers under written confidentiality and data-processing terms.
- Authorised Personnel: Our employees and contractors on a strict need-to-know basis, bound by confidentiality.
- Legal & Regulatory Requests: When required by a valid court order, summons, GST / Excise notice, or other lawful demand under Indian law.
- Business Transfers: In the event of a merger, acquisition, or asset sale, subject to equivalent privacy obligations.
8. Data Security
We implement reasonable security practices that meet or exceed Rule 8 of the SPDI Rules, 2011, including:
- TLS / HTTPS encryption for all data in transit
- Encrypted database storage and salted password hashes
- Role-based access control and per-tenant data isolation
- Periodic backups, monitoring, and audit logging
- Restricted physical and logical access to production systems
No system can be guaranteed 100% secure. You are responsible for maintaining the secrecy of your login credentials.
9. Data Retention
- Active accounts: data is retained for the duration of your subscription
- Tax & accounting records: retained for at least 8 years to comply with GST, Income Tax, and Companies Act requirements
- Payment records: retained for at least 8 years for audit and reconciliation
- On account closure: operational data is deleted or anonymised within 90 days, except where retention is required by law
10. Your Rights
Subject to applicable law, you may:
- Access the Personal Data we hold about you
- Request correction of inaccurate or outdated data
- Request deletion of your data (subject to retention obligations)
- Withdraw consent for non-essential communications at any time
- Lodge a grievance with our Grievance Officer
Send requests to
accorgminds@gmail.com with the subject line “Data Access / Deletion Request”. We will respond within 30 days.
11. Cookies & Tracking
We use cookies and similar technologies to:
- Maintain login sessions
- Remember preferences (language, theme)
- Measure usage to improve the product (aggregated only)
You can disable cookies in your browser; some features may stop working.
12. WhatsApp & Email Communications
We send the following message types via WhatsApp Business API and Email, only after you opt in by sharing your number/email at sign-up:
- OTP and login verification
- Daily parcha summary, parcha-pending alerts, distributor / staff daily reports
- Subscription renewal reminders, payment receipts, invoices
- Service notifications and incident updates
We do not send marketing messages without separate opt-in. You can opt out anytime by replying STOP or writing to us.
13. Children
The Services are intended for licensed adult businesses. We do not knowingly collect data from anyone under 18 years of age.
14. Cross-Border Data Transfer
Your data is primarily stored on servers located in India. Where we use third-party providers that may process data outside India, we ensure equivalent protection through contractual safeguards, in line with the DPDP Act, 2023.
15. Changes to this Policy
We may update this Policy from time to time. The “Effective Date” at the top will reflect the latest version. Material changes will be notified by email or in-app notice. Continued use of the Services after the change constitutes acceptance.
16. Governing Law & Jurisdiction
This Policy is governed by the laws of India. Any dispute arising out of or in relation to this Policy shall be subject to the exclusive jurisdiction of the courts at Bikaner, Rajasthan.
17. Contact Us
For any questions, complaints, or grievances regarding this Privacy Policy or your data, please contact:
ACCORGMINDS PRIVATE LIMITED
2nd Floor, AMJ Royal Tower, Opp. Police Line, Bikaner – 334001, Rajasthan, India
Email: accorgminds@gmail.com
Phone: +91 8619700971