Legal
Privacy Policy
Last Updated: 10 July 2025
Horolume ("we", "us", "our") is committed to handling personal information responsibly and with care. This policy explains what data we collect through this website and through our workshop services, how we use it, and what rights you have over it. We are based at 3A, Lebuh Farquhar, 10200 George Town, Penang, Malaysia and operate under Malaysian law, including the Personal Data Protection Act 2010 (PDPA).
1. Data We Collect
We collect personal information in the following circumstances:
- Contact form submissions: name, email address, and optionally phone number and a message about your watch.
- Workshop intake: when you bring a watch in person, we record your name and contact details alongside a description of the piece.
- Website analytics: if you accept analytics cookies, anonymised data about page visits and browser type is collected via third-party analytics tools.
- Cookies: technical and preference cookies are used as described in our Cookie Policy.
We do not collect sensitive personal data such as financial details, identification documents, or health information.
2. Legal Basis for Processing
Under the PDPA 2010, we process your data on the following grounds:
- Contract performance: to communicate with you about your watch service and fulfil the agreed work.
- Legitimate interest: to respond to enquiries, maintain our workshop intake records, and improve our website.
- Consent: for optional analytics and marketing cookies, which you can manage at any time.
3. How We Use Your Data
- To respond to enquiries sent via the contact form
- To arrange and communicate about your watch service
- To maintain workshop intake and condition records
- To send service-related communications (not marketing without consent)
- To improve our website based on anonymised usage data
We do not use your data for automated decision-making or profiling.
4. Data Sharing
We do not sell or share your personal data with third parties for commercial purposes. Limited sharing occurs in these circumstances:
- Service providers: website hosting and analytics providers operating under confidentiality agreements.
- Legal obligation: if required by Malaysian law or a valid court order.
Parts sourcing for restoration work may involve communication with specialist suppliers, but we share only what is necessary to identify the correct component — no personal client data is included in such correspondence.
5. Data Retention
- Workshop records: retained for 7 years to support follow-up service history.
- Contact enquiries: retained for 12 months after the last communication.
- Analytics data: anonymised aggregate data; identifiable session data retained for up to 26 months.
- Cookie preferences: stored locally on your device; cleared when you clear browser data.
6. Security
Our website is served over HTTPS. Access to client records is restricted to workshop staff. We do not store card or payment data. In the event of a personal data breach that poses a material risk, we will notify affected individuals and, where required, the relevant authority within a reasonable timeframe.
7. Cookies
We use essential, analytics, and preference cookies. A consent banner appears on first visit. You can manage your cookie choices at any time via our Cookie Policy page. Rejecting non-essential cookies does not affect your ability to use this website.
8. Your Rights
Under Malaysian PDPA 2010, you have the right to:
- Request access to personal data we hold about you
- Request correction of inaccurate or outdated data
- Withdraw consent for processing based on consent (this does not affect lawfulness of prior processing)
- Request that your data be deleted, subject to legal retention obligations
- Object to processing for direct marketing purposes
To exercise any of these rights, contact us at [email protected]. We will respond within 21 days. You may also raise a concern with the Department of Personal Data Protection Malaysia (PDPD).
9. Third-Party Links
This website may link to external pages. We are not responsible for the privacy practices of other websites and encourage you to review their policies independently.
10. Children's Privacy
Our services are intended for adults. We do not knowingly collect personal data from individuals under the age of 18. If you believe a minor has submitted data via our site, please contact us so we can remove it.
11. Policy Changes
We may update this policy from time to time. Changes will be reflected by the "Last Updated" date above. Continued use of our website after any update constitutes acceptance of the revised terms.
12. Contact
For any privacy-related questions or requests:
- [email protected]
- +60 4 261 7358
- Horolume, 3A Lebuh Farquhar, 10200 George Town, Penang, Malaysia