LEGAL DOCUMENT

Privacy Policy

Kemuning Horology · Last Updated: 10 July 2025 · Effective: 10 July 2025

1. Introduction

Kemuning Horology ("we", "us", "our"), operating from 9 Jalan Sultan Idris Shah, 30000 Ipoh, Perak, Malaysia, is committed to handling personal data responsibly. This Privacy Policy explains what data we collect, why we collect it, how we use it, and what rights you have in relation to it. It applies to data collected through our website at kemunin.biz and through our workshop service intake process.

We process personal data in accordance with the Personal Data Protection Act 2010 (PDPA) of Malaysia. By using our website or submitting an enquiry, you acknowledge that you have read this policy.

2. Data We Collect

2.1 Information you provide directly

• Full name
• Email address
• Telephone number (where provided)
• Description of the watch piece submitted for service (make, condition notes)
• Any other information included in the message field of our enquiry form

2.2 Service records

When a watch is submitted for service at the workshop, we create a ledger entry associated with your contact details. This entry records the condition of the piece, the scope of work agreed, parts used, timing machine results, and completion notes. These records are held in a closed workshop system.

2.3 Website usage data

When you visit our website, standard technical data may be collected automatically including IP address, browser type, pages visited and visit duration. This data is used for site performance review and is not linked to personal identity unless you submit a form.

3. Legal Basis for Processing

• Contract performance: Processing your name, email and contact details to respond to service enquiries and deliver the requested service.
• Legitimate interests: Maintaining service records for quality assurance and future reference, and operating the website.
• Consent: Where you have opted into communications or cookie categories beyond essential functionality.

4. How We Use Your Data

• To respond to enquiries submitted through our website contact form
• To open and maintain the workshop service ledger entry for your piece
• To contact you when a service is complete or if there is a change in scope
• To retain a service history that can be referenced on future visits
• To review website performance and address technical issues

We do not send marketing communications without your explicit consent. We do not sell or share your personal data with third parties for their marketing purposes.

5. Data Sharing

We do not share your personal data with third parties except in the following limited circumstances:

• Service providers: Hosting and technical infrastructure providers who process data on our behalf under data processing agreements.
• Legal requirements: Where disclosure is required by Malaysian law or a competent authority.

We do not transfer your data outside Malaysia without appropriate safeguards in place.

6. Data Retention

• Enquiry form submissions: retained for 24 months from the date of submission, or for the duration of any active service relationship.
• Workshop service records: retained indefinitely as they form the baseline record for any future visit. You may request deletion of your personal contact details from old records at any time.
• Website usage logs: retained for up to 12 months.

7. Data Protection Measures

• Workshop service records are held in a closed paper and digital ledger system accessible only to workshop staff.
• Website data is hosted on servers with encryption in transit (TLS/HTTPS).
• Access to digital records is controlled by staff authentication.
• In the event of a data breach that risks harm to affected individuals, we will notify those individuals and the relevant authority within the timeframe required by the PDPA.

8. Cookies

Our website uses cookies for basic functionality and, with your consent, for analytics. For full details of the cookies we use and how to manage your preferences, please read our Cookie Policy.

9. Your Rights Under the PDPA (Malaysia)

Under the Personal Data Protection Act 2010, you have the following rights in respect of 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 or incomplete data.
• Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing before the withdrawal.
• Right to prevent processing: In certain circumstances, you may object to or limit our processing of your data.

To exercise any of these rights, please contact us at [email protected]. We will respond within 21 days.

10. Third-Party Links

Our website may contain links to third-party websites such as mapping services. We are not responsible for the privacy practices of those sites and recommend that you read their privacy policies independently.

11. Children

Our services are directed at individuals aged 18 and over. We do not knowingly collect personal data from persons under 18. If you believe we have inadvertently collected such data, please contact us and we will take steps to delete it.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The date at the top of the document will reflect the most recent revision. Where changes are material, we will make reasonable efforts to notify users who have submitted enquiries within the past 12 months. Continued use of the website after any change constitutes acceptance of the revised policy.

13. Contact for Data Enquiries

For any questions about this Privacy Policy or to exercise your rights:

• Email: [email protected]
• Address: Kemuning Horology, 9 Jalan Sultan Idris Shah, 30000 Ipoh, Perak, Malaysia
• Telephone: +60 5 241 8637