Privacy Policy

1. Introduction

Cengalhor Studio ("the Studio", "we", "us") operates from 47 Lebuh Acheh, 10300 George Town, Pulau Pinang, Malaysia. This Privacy Policy describes how the Studio collects, uses, and protects personal data provided through this website and through the service enquiry process.

This policy applies to all individuals who contact the Studio, submit enquiries through this website, or bring pieces to the Studio for service. By using this website or engaging the Studio's services, you acknowledge that your personal data will be handled as described below.

The Studio complies with Malaysia's Personal Data Protection Act 2010 (PDPA 2010) in all data handling practices.

2. Data We Collect

2.1 Information You Provide Directly

• Your name and contact details (email address, telephone number)
• A description of the watch or piece you are enquiring about
• Any additional details you choose to share about the piece's history or your service requirements

2.2 Information Collected Automatically

• Browser type and version, operating system, device type
• Pages visited on this website, time and date of visits
• IP address (stored in anonymised or pseudonymised form where possible)
• Cookie preferences and consent status (stored locally on your device)

2.3 Legal Basis for Processing

Personal data submitted through the enquiry form is processed on the basis of your consent and the legitimate interest of the Studio in responding to service enquiries. Data necessary to fulfil a service agreement is processed on the basis of that contractual relationship. Analytics data, where collected, relies on your consent as expressed through the cookie preference tool.

3. How We Use Your Data

• To respond to your enquiry and discuss the appropriate service programme
• To manage the service relationship — including scheduling, notifications, and collection
• To issue reference numbers, document scope agreements, and produce service records
• To understand website usage and improve the information we provide (analytics, where consented)
• To comply with applicable legal requirements

The Studio does not use your personal data for unsolicited marketing. If we wish to contact you about new programmes or information, we will ask for your agreement beforehand.

4. Data Sharing

The Studio does not sell, rent, or share your personal data with third parties for their own marketing purposes. Data may be disclosed in the following limited circumstances:

• To service providers engaged by the Studio to assist with website hosting, analytics, or email delivery — only to the extent necessary and under contractual data protection obligations
• Where required by applicable law, court order, or regulatory requirement

Where third-party analytics or advertising tools are active, their data processing is governed by their own privacy policies. You can control these through the cookie preference tool on this website.

5. Data Retention

Enquiry records and service documentation are retained for seven years from the date of the service, in accordance with standard business record-keeping practice under Malaysian law. Cookie consent records are retained for twelve months. Where no service results from an enquiry, contact information is deleted within 90 days of the last communication.

6. Data Protection Measures

The Studio takes reasonable technical and organisational steps to protect personal data, including:

• Website traffic encrypted via HTTPS
• Access to service records restricted to Studio staff on a need-to-know basis
• Physical service records stored securely at the Studio's premises
• Regular review of data handling practices

In the event of a data breach that poses a risk to individuals, the Studio will notify affected individuals and the relevant authority as required under applicable law.

7. Cookies

This website uses cookies for essential functionality and, with your consent, for analytics purposes. Essential cookies are necessary for the website to function and cannot be disabled. Optional cookies (analytics, preferences, marketing) are only placed with your consent.

You can manage your cookie preferences at any time through our Cookie Policy page.

8. Your Rights Under PDPA 2010

Under Malaysia's Personal Data Protection Act 2010, you have the following rights with respect to your personal data:

• The right to request access to personal data held about you
• The right to request correction of inaccurate or incomplete data
• The right to withdraw consent for processing where processing is based on consent
• The right to request that processing be limited in certain circumstances

To exercise any of these rights, please contact the Studio by email at [email protected]. The Studio will respond within 21 days. In some circumstances, a processing fee may apply as permitted under the PDPA.

If you have a concern about how your data has been handled, you may contact the Department of Personal Data Protection Malaysia (JPDP) at www.pdp.gov.my.

9. Third-Party Links

This website may contain links to external websites or services. The Studio is not responsible for the privacy practices or content of those sites. We recommend reviewing the privacy policy of any external site you visit.

10. Children's Privacy

The Studio's services are intended for individuals aged 18 and over. We do not knowingly collect personal data from persons under the age of 18. If you believe a minor has submitted personal data to the Studio, please contact us and we will delete that data promptly.

11. Changes to This Policy

The Studio may update this Privacy Policy from time to time. Material changes will be noted on this page with a revised "Last Updated" date. Continued use of the website after changes are posted constitutes acceptance of the updated policy. For significant changes, we will take reasonable steps to notify individuals who have provided contact information.

12. Contact

For questions about this Privacy Policy or the Studio's data handling practices:

• Email: [email protected]
• Post: Cengalhor Studio, 47 Lebuh Acheh, 10300 George Town, Pulau Pinang, Malaysia