Privacy Policy

1. Data We Collect

We collect personal data in two ways: through the website enquiry form, and during the physical intake process at the workshop. The data collected includes:

• Contact information: name, email address, telephone number (optional on the web form, recorded at workshop intake).
• Service-related information: description of the timepiece, its make, model, and calibre reference if known; observed condition; service history if provided by the owner.
• Technical records: timegrapher readings, condition register notes, materials records, photographic documentation — created by the workshop during service.
• Website usage data: anonymised browsing data collected via analytics cookies, including pages visited and approximate location by country. This data is not personally identifying on its own.

We do not collect payment card data through the website. Payment for workshop services is handled in person or by bank transfer; card details are not stored by Horolume.

2. How We Use Your Data

Personal data collected from you is used only for the following purposes:

• Responding to workshop enquiries and providing service quotations.
• Carrying out the agreed scope of watchmaking work and documenting it in the condition register and service record.
• Communicating with clients about their piece during the bench period, including progress updates.
• Maintaining workshop records for the duration of any workmanship period (twelve months from return for movement service).
• Improving the website through aggregated analytics data — we review which pages are read most and how people find the site.

We do not use your personal data for marketing campaigns, third-party advertising, or data brokering. We do not sell personal data.

The legal basis for processing personal data is performance of a service agreement (PDPA consent is implicit through submission of an enquiry or presentation of a piece at intake), and legitimate interest in maintaining accurate workshop records during the workmanship period.

3. Data Retention

Enquiry records where no service follows are retained for twelve months and then deleted. Active client records — condition registers, service documents, correspondence — are retained for seven years from the date of service completion, in line with Malaysian statutory requirements for business records. Technical photographs forming part of an archive-grade service record are retained for the same period unless the owner requests a copy and consents to their earlier deletion from our systems.

4. Data Protection Measures

• Digital records are stored on encrypted drives with access restricted to workshop staff directly involved in the service concerned.
• Physical condition registers and service documents are stored in a locked cabinet at the workshop premises.
• The website is served over HTTPS. Enquiry form submissions are transmitted securely.
• We do not transfer personal data to servers outside Malaysia without informing the data subject.
• In the event of a data breach affecting personal data, we will notify affected individuals within a reasonable period and, where required by the PDPA or relevant guidance, the relevant authority.

5. Cookies

The website uses cookies for basic functionality (the cookie consent preference itself is stored in your browser's local storage) and, if you consent, for anonymised analytics. We do not use advertising cookies or third-party tracking cookies. Full details are in our Cookie Policy.

6. Third-Party Services

The website may link to external resources. We are not responsible for the privacy practices of linked sites. Analytics data, if enabled, is processed by a service provider under a data processing agreement. Personal client data is not shared with any third party except where required by Malaysian law.

7. Your Rights Under Malaysian PDPA

Under the Personal Data Protection Act 2010, you have the following rights in relation to personal data we hold about you:

• Right of access: You may request a copy of the personal data we hold about you.
• Right of correction: You may request correction of inaccurate personal data.
• Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time. Withdrawal does not affect lawfulness of processing prior to withdrawal.
• Right to prevent processing for direct marketing: We do not conduct direct marketing, but you may instruct us not to contact you about new workshop services.

To exercise any of these rights, write to [email protected] or post to Lot 12-3, Wisma Cendera, Jalan Ampang, 50450 Kuala Lumpur. We will respond within 21 days. Complaints may be directed to the Department of Personal Data Protection Malaysia (pdp.gov.my).

8. Children

The workshop's services are directed at adults. We do not knowingly collect personal data from anyone under the age of 18. If you believe a minor has submitted personal data through the website, contact [email protected] and we will delete it promptly.

9. Changes to This Policy

We may update this policy from time to time. Material changes will be noted on this page with a revised effective date. Continued use of the website or workshop services following a posted update constitutes acceptance of the revised policy. Where changes are significant, we will notify active clients by email.

10. Contact

Data controller: Horolume, Lot 12-3, Wisma Cendera, Jalan Ampang, 50450 Kuala Lumpur, Malaysia.

Privacy enquiries: [email protected]

Telephone: +60 3 2078 4613