Privacy Policy

1. Introduction

Luxury Watch Works Pvt. Ltd. ("Luxury Watch Works", "we", "our", or "us") is committed to protecting the privacy and personal data of our customers, website visitors, business partners, and other individuals who interact with us.

This Privacy Policy explains how we collect, use, store, share, retain, and protect personal data when you use our website, contact us, enquire about our services, register for our events or educational programmes, engage with us through digital communication channels, or otherwise interact with Luxury Watch Works.

We recognise that personal data is entrusted to us with confidence. We are committed to processing such information responsibly, transparently, and in accordance with the Digital Personal Data Protection Act, 2023 ("DPDP Act"), the applicable rules made thereunder, and other applicable laws of India.

This Privacy Policy is intended to help you understand:

  • what personal data we collect;

  • why we collect and process your personal data;

  • how we use and protect your information;

  • when we may share your personal data with authorised service providers or other parties;

  • how long we retain your information;

  • the rights available to you under applicable law; and

  • how you may contact us regarding any privacy-related questions, requests, or grievances.

By interacting with Luxury Watch Works or using our website, you acknowledge that you have read this Privacy Policy. Where your consent is required under applicable law, we will seek your consent through appropriate notices and consent mechanisms before processing your personal data.

We periodically review this Privacy Policy to ensure that it remains accurate and reflects changes in our business operations, legal obligations, and technological practices. The latest version of this Privacy Policy will always be made available on our website.

2. Scope of this Privacy Policy

This Privacy Policy applies to the collection, processing, storage, use, disclosure, retention, and protection of personal data by Luxury Watch Works Pvt. Ltd. in connection with its business operations and services.

‍This Privacy Policy applies to individuals who interact with Luxury Watch Works through any of the following channels:

  • ‍ ‍Our official website (www.luxurywatchworks.com);

  • Online enquiry and contact forms;

  • Service booking and repair requests;

  • Watch servicing, restoration, authentication, valuation, inspection, and related after-sales services;

  • WhatsApp Business and other authorised messaging platforms;

  • Telephone calls, emails, and other customer support communications;

  • In-person visits to our service centre or office;

  • Educational programmes, workshops, seminars, masterclasses, and events organised or hosted by Luxury Watch Works;

  • Marketing communications, newsletters, service reminders, and promotional updates where you have provided consent or where otherwise permitted under applicable law; and

  • Any other lawful interaction where you voluntarily provide your personal data to Luxury Watch Works.

This Privacy Policy applies to the personal data of:

  • Customers and prospective customers;

  • Website visitors;

  • Event participants and registrants;

  • Business partners and vendors who interact with us in an individual capacity;

  • Individuals making enquiries regarding our products or services; and

  • Any other individual whose personal data is processed by Luxury Watch Works in the course of its legitimate business activities.

This Privacy Policy does not apply to:

  • Personal data processed exclusively for personal or domestic purposes by individuals;

  • Third-party websites, platforms, or services that are not owned or controlled by Luxury Watch Works, even where links to such websites are provided on our website. We encourage you to review the privacy policies of those third parties before providing your personal data.

Where any service, campaign, event, or platform operated by Luxury Watch Works requires additional privacy disclosures or specific consent, such notices shall supplement this Privacy Policy and shall prevail to the extent of any inconsistency for that particular activity.

This Privacy Policy shall be read together with any additional privacy notices, consent statements, website notices, or terms and conditions provided by Luxury Watch Works in relation to specific products, services, events, or digital platforms.‍

3. Definitions

For this Privacy Policy, the following terms shall have the meanings assigned below unless the context otherwise requires:

3.1 "Applicable Law"
Means the Digital Personal Data Protection Act, 2023 ("DPDP Act"), the rules framed thereunder, and any other applicable laws, regulations, or governmental directions governing the processing of personal data in India.

‍3.2 "Company", "Luxury Watch Works", "we", "our" or "us"
‍Means Luxury Watch Works Pvt. Ltd., having its registered office at Unit No. 39/A, 1st Floor, Kala Bhavan, Shrimad Rajchandraji Marg, Behind Royal Theatre, Opera House, Mumbai – 400004, Maharashtra, India.‍ ‍

3.3 "Consent"
Means a free, specific, informed, unconditional, and unambiguous indication of the Data Principal's agreement to the processing of their personal data for a specified purpose, provided through a clear affirmative action, in accordance with the DPDP Act.‍ ‍

3.4 "Data Fiduciary"
Means the person or entity which alone or in conjunction with others determines the purpose and means of processing personal data. For the purposes of this Privacy Policy, Luxury Watch Works Pvt. Ltd. acts as the Data Fiduciary‍ ‍

3.5 "Data Principal"
‍Means the individual to whom the personal data relates, as defined under the DPDP Act.

3.6 "Personal Data"
‍Means any data about an individual who is identifiable by or in relation to such data, as defined under the DPDP Act.‍ ‍

3.7 "Personal Data Breach"
‍Means any unauthorised processing of personal data or accidental disclosure, acquisition, sharing, use, alteration, destruction, loss of access, or compromise of personal data that may affect its confidentiality, integrity, or availability.‍ ‍

3.8 "Processing"
‍Means a wholly or partly automated operation or set of operations performed on personal data, including collection, recording, organisation, storage, adaptation, retrieval, use, sharing, disclosure, transmission, alignment, restriction, erasure, or destruction.

‍3.9 "Service Providers"
‍Means third-party organisations or individuals engaged by Luxury Watch Works to provide services on its behalf, including website hosting, information technology services, communication platforms, payment processing, analytics, logistics, customer relationship management, marketing support, and other operational services that may involve the processing of personal data under appropriate contractual and legal safeguards.

‍3.10 "Services"
‍Means the products and services offered by Luxury Watch Works, including luxury watch servicing, repairs, restoration, maintenance, polishing, authentication, inspection, valuation, consultations, educational programmes, events, and related after-sales support.‍ ‍

3.11 "Website"‍ ‍
Means the official Luxury Watch Works website located at www.luxurywatchworks.com, together with any webpages, forms, digital applications, or online services operated under the control of Luxury Watch Works.‍ ‍

3.12 "You" or "Your"
Means any individual who visits our Website, contacts Luxury Watch Works, submits an enquiry, requests our services, participates in our events, or otherwise provides personal data to Luxury Watch Works.

4. About Luxury Watch Works

Luxury Watch Works Pvt. Ltd. ("Luxury Watch Works", "we", "our", or "us") is an independent luxury watch service centre headquartered in Mumbai, India. We specialise in the servicing, maintenance, restoration, authentication, inspection, and preservation of luxury timepieces, delivering technical expertise and after-sales support to watch owners, collectors, authorised partners, and other customers.

‍Our services are designed to support the long-term care and preservation of luxury watches through professional servicing, preventive maintenance, technical consultations, authentication, valuation support, educational initiatives, and related customer services.

For the purposes of the Digital Personal Data Protection Act, 2023 ("DPDP Act"), Luxury Watch Works acts as a Data Fiduciary in relation to the personal data that we collect and process in connection with our business operations.

As a Data Fiduciary, we determine the purposes for which personal data is collected and the manner in which such personal data is processed. We are committed to ensuring that all processing of personal data is carried out lawfully, fairly, transparently, and in accordance with the requirements of the DPDP Act, applicable rules made thereunder, and other applicable laws.

We recognise that the trust placed in us extends beyond the care of luxury timepieces and includes the responsible handling of our customers' personal data. Accordingly, we have implemented policies, procedures, and reasonable technical and organisational safeguards to protect personal data throughout its lifecycle—from collection and use to storage, sharing, retention, and secure disposal.‍ ‍

Where we engage third-party service providers to support our operations, we require such providers to process personal data only for authorised purposes and in accordance with applicable contractual obligations and legal requirements. Luxury Watch Works remains responsible for ensuring that personal data entrusted to us is handled with appropriate care and accountability.‍ ‍

Privacy and data protection form an integral part of our commitment to customer service, ethical business practices, and responsible corporate governance. We continuously review and improve our privacy practices to ensure they remain aligned with applicable legal requirements, evolving technology, and the expectations of our customers.

Company Details

Legal Name: Luxury Watch Works Pvt. Ltd.

Registered Office: Unit No. 39/A, 1st Floor, Kala Bhavan, Shrimad Rajchandraji Marg, Behind Royal Theatre, Opera House, Mumbai – 400004, Maharashtra, India.

‍Website:www.luxurywatchworks.com‍ ‍Email:contact@luxurywatchworks.com

‍The contact details for privacy-related requests, grievances and the exercise of rights under the DPDP Act are provided in the Grievance Redressal and Contact Information section of this Privacy Policy.‍

5. Personal Data We Collect

Luxury Watch Works collects only such personal data as is necessary for providing our services, responding to enquiries, fulfilling our contractual and legal obligations, improving our customer experience, and conducting our legitimate business operations.

The categories of personal data that we may collect include, but are not limited to, the following:

5.1 Identity Information

We may collect information that identifies you, including:

  • Full name

  • Title (where applicable)

  • Date of birth (only where voluntarily provided or required for a specific purpose)

  • Signature (where applicable)

5.2 Contact Information

We may collect:

  • Mobile telephone number

  • Landline number (where applicable)

  • Email address

  • Postal or correspondence address

  • City, State and Country

This information enables us to communicate with you regarding enquiries, appointments, quotations, service updates, collections, deliveries, invoices, customer support, and other requested services.

5.3 Watch and Service Information

As part of our luxury watch servicing and related services, we may collect information relating to your watch, including:

  • Watch brand

  • Model

  • Reference number

  • Serial number

  • Year of purchase (where available)

  • Service history

  • Condition assessment

  • Technical inspection findings

  • Repair requirements

  • Authentication or valuation details

  • Photographs of the watch

  • Service estimates

  • Service reports

  • Warranty-related information

  • Collection and delivery details (where applicable)

While this information generally relates to your watch rather than directly to you, certain records may become associated with your personal data for the purpose of providing our services.

5.4 Communication Information

We may maintain records of communications exchanged with you, including:

  • Website enquiries

  • Contact forms

  • Emails

  • WhatsApp messages

  • Telephone conversations (where documented)

  • Customer support interactions

  • Appointment requests

  • Feedback and reviews

  • Complaints and grievance communications

5.5 Transaction Information

Where applicable, we may collect information relating to commercial transactions, including:

  • Quotations

  • Invoices

  • Payment status

  • Order or service reference numbers

  • Billing information

  • Tax-related information where required under applicable law

Luxury Watch Works does not intentionally collect or store complete payment card details. Electronic payments are processed through authorised payment service providers in accordance with their respective privacy and security practices.

5.6 Event and Educational Programme Information

Where you register for workshops, seminars, masterclasses, or other events organised by Luxury Watch Works, we may collect:

  • Registration information

  • Professional or organisational affiliation (where voluntarily provided)

  • Attendance records

  • Communication preferences

  • Feedback submitted following participation

5.7 Website Usage Information

When you visit our Website, certain technical information may be collected automatically, including:

  • Internet Protocol (IP) address

  • Browser type and version

  • Device information

  • Operating system

  • Website pages visited

  • Date and time of access

  • Referral source

  • Website interaction data

  • Cookie identifiers and similar technologies where applicable

Such information helps us administer our Website, improve its performance, understand visitor behaviour, and enhance user experience.

5.8 Marketing and Communication Preferences

Where you choose to receive marketing or promotional communications, we may collect information relating to your communication preferences, including:

  • Subscription status

  • Preferred communication channel

  • Marketing consent status

  • Records of consent or withdrawal of consent

  • Communication history

5.9 Information You Voluntarily Provide

You may voluntarily provide additional personal information while interacting with Luxury Watch Works, including through enquiries, consultations, surveys, customer feedback, event participation, or correspondence. We process such information only for the purpose for which it is provided or as otherwise permitted under applicable law.

5.10 Identity Verification Information

In limited and exceptional circumstances, Luxury Watch Works may request a government-issued identification document (such as an Aadhaar Card, Passport, Driving Licence or Voter ID or any other officially recognised identity document) solely for the purpose of verifying the identity of an individual.

This may be necessary, for example, where a customer is unable to produce the original service receipt or collection acknowledgement at the time of collecting a watch or where identity verification is reasonably required to protect the customer, prevent unauthorised release of a timepiece, investigate suspected fraud, or comply with applicable legal obligations.

Luxury Watch Works collects only the minimum identity information reasonably necessary for such verification and processes it solely for the specific purpose for which it was requested. Such information is retained only for as long as necessary in accordance with our Data Retention Policy and applicable legal requirements and is protected using appropriate security safeguards.

6. How We Collect Personal Data

Luxury Watch Works collects personal data through lawful, fair, and transparent means in connection with the provision of our services, operation of our business, and our interactions with customers, prospective customers, website visitors, business partners, and other individuals.

We collect personal data through the following sources:

6.1 Information You Provide Directly

We collect personal data that you voluntarily provide when you:

  • Submit an enquiry through our Website;

  • Contact us by telephone, email, WhatsApp, or other authorised communication channels;

  • Request a quotation or consultation;

  • Book a watch servicing, repair, restoration, authentication, valuation, inspection, polishing, or related service;

  • Visit our service centre or office;

  • Register for a workshop, seminar, masterclass, or other event organised by Luxury Watch Works;

  • Subscribe to newsletters or marketing communications (where offered);

  • Complete customer feedback forms or surveys;

  • Submit complaints, compliments, or other correspondence; or

  • Otherwise communicate with us in relation to our products or services.

The personal data collected depends on the nature of your interaction with us and the services you request.

6.2 Information Collected During the Provision of Services

During the course of providing our services, we may generate or collect additional information relating to your engagement with Luxury Watch Works, including:

  • Service records;

  • Inspection reports;

  • Technical assessments;

  • Repair history;

  • Authentication and valuation records;

  • Warranty-related information;

  • Photographs of watches submitted for inspection or servicing;

  • Customer communication records; and

  • Service completion and delivery records.

Such information enables us to provide, manage, improve, and support our services throughout the customer relationship.

6.3 Information Collected Through Our Website

When you visit our Website, certain information may be collected automatically through cookies and similar technologies, including technical and usage information such as:

  • Internet Protocol (IP) address;

  • Browser type;

  • Device information;

  • Operating system;

  • Website usage data;

  • Referring website;

  • Date and time of access; and

  • Website interaction information.

Such information assists us in operating, maintaining, securing, and improving our Website and understanding how visitors use our online services.

Further information regarding our use of cookies and similar technologies is provided in the relevant section of this Privacy Policy.

6.4 Information Collected Through Communications

We may collect information when you communicate with us through authorised channels, including:

  • Email correspondence;

  • WhatsApp Business communications;

  • Telephone calls;

  • Customer support enquiries;

  • Appointment scheduling;

  • Service updates; and

  • Follow-up communications.

These records help us respond to enquiries, provide customer support, maintain service records, and improve the quality of our services.

6.5 Information from Business Partners and Authorised Representatives

Where appropriate and lawful, we may receive personal data from:

  • Authorised representatives acting on your behalf;

  • Corporate customers;

  • Business partners;

  • Logistics providers;

  • Insurance providers (where applicable);

  • Payment service providers; or

  • Other organisations involved in providing services requested by you.

We process such information only for the purpose for which it is provided and in accordance with applicable law.

6.6 Information from Publicly Available Sources

In limited circumstances, we may obtain publicly available business contact information from publicly accessible sources, including professional directories, corporate websites, publicly available business listings, or other lawful sources, where relevant to our legitimate business activities and permitted under applicable law.

6.7 Accuracy of Information

We rely upon the accuracy of the personal data provided to us. You are requested to ensure that the information you provide is complete, accurate, and kept up to date, and to notify us promptly of any changes so that we may maintain accurate records and continue to provide our services effectively.

Luxury Watch Works does not knowingly collect personal data through unlawful, deceptive, or unauthorised means. We collect personal data only where it is reasonably necessary for our business operations, the provision of requested services, compliance with applicable legal obligations, or for other purposes permitted under the Digital Personal Data Protection Act, 2023 and other applicable laws.

7. Purpose of Processing

Luxury Watch Works processes personal data only for specified, lawful, and legitimate purposes that are connected with our business operations, the services requested by you, compliance with applicable legal obligations, or other purposes permitted under the Digital Personal Data Protection Act, 2023 ("DPDP Act") and other applicable laws.

Depending on the nature of your interaction with us, we may process your personal data for one or more of the following purposes:

7.1 To Respond to Enquiries

We process personal data to:

  • Respond to enquiries submitted through our Website, email, telephone, WhatsApp, or other authorised communication channels;

  • Provide information regarding our services;

  • Arrange consultations, appointments, or inspections; and

  • Communicate with prospective customers regarding their requests.

7.2 To Provide Our Services

We process personal data to:

  • Receive and manage service requests;

  • Inspect, diagnose, service, repair, restore, authenticate, value, or maintain luxury watches;

  • Prepare quotations and service estimates;

  • Schedule appointments and service activities;

  • Maintain service records;

  • Coordinate collection and delivery services where applicable; and

  • Provide warranty, post-service support, and customer assistance.

7.3 To Communicate with You

We process personal data to communicate with you regarding:

  • Service updates;

  • Appointment confirmations;

  • Quotations;

  • Invoices;

  • Collection and delivery arrangements;

  • Technical findings;

  • Customer support;

  • Responses to your requests; and

  • Other communications relating to the services you have requested.

7.4 To Process Transactions

Where applicable, we process personal data for purposes relating to:

  • Preparing quotations;

  • Issuing invoices;

  • Processing payments;

  • Maintaining financial records;

  • Complying with taxation and accounting obligations; and

  • Managing contractual relationships with customers.

7.5 To Improve Our Services

We may process personal data to:

  • Analyse customer feedback;

  • Evaluate service quality;

  • Improve customer experience;

  • Enhance operational efficiency;

  • Develop new services; and

  • Maintain quality assurance standards.

Where reasonably possible, such analysis may be carried out using aggregated or de-identified information.

7.6 To Operate and Improve Our Website

We process technical and website usage information to:

  • Operate and maintain our Website;

  • Monitor website performance;

  • Improve functionality and user experience;

  • Diagnose technical issues;

  • Analyse website traffic; and

  • Protect the security and integrity of our digital platforms.

7.7 Marketing and Customer Engagement

Where you have provided your consent or where otherwise permitted under applicable law, we may process your personal data to:

  • Send newsletters;

  • Provide service reminders;

  • Share maintenance recommendations;

  • Inform you about educational content;

  • Invite you to workshops, seminars, masterclasses, and events;

  • Communicate information about new services or promotional campaigns; and

  • Conduct customer engagement activities.

You may withdraw your consent for marketing communications at any time in accordance with this Privacy Policy.

7.8 Compliance with Legal and Regulatory Obligations

We may process personal data where necessary to:

  • Comply with applicable laws, regulations, legal processes, or lawful requests from competent authorities;

  • Maintain statutory records;

  • Prevent fraud or unlawful activities;

  • Exercise or defend legal claims;

  • Protect our legal rights, property, customers, employees, and business operations; and

  • Meet our obligations under applicable law.

7.9 Security and Fraud Prevention

We process personal data where reasonably necessary to:

  • Protect our Website, systems, and infrastructure;

  • Detect, investigate, prevent, or respond to security incidents;

  • Prevent fraud, misuse, unauthorised access, or other unlawful activities;

  • Maintain the confidentiality, integrity, and availability of our information systems; and

  • Protect the safety of our customers, employees, and business operations.

7.10 Other Lawful Purposes

We may process personal data for any other purpose:

  • For which you have provided your consent;

  • Which is directly related to the purpose for which the personal data was originally collected;

  • Which is required or authorised under applicable law; or

  • Which is otherwise permitted under the Digital Personal Data Protection Act, 2023.

Luxury Watch Works will not process personal data for purposes that are incompatible with the purposes described in this Privacy Policy unless required or permitted by applicable law or unless we provide an appropriate notice and obtain consent where required.

8. Legal Grounds for Processing Personal Data under the Digital Personal Data Protection Act, 2023

Luxury Watch Works processes personal data only in accordance with the Digital Personal Data Protection Act, 2023 ("DPDP Act") and other applicable laws.
Under the DPDP Act, personal data may be processed where the Data Principal has provided valid consent or where processing is otherwise permitted under the Act. The legal grounds on which Luxury Watch Works processes personal data are set out below.

8.1 Processing Based on Consent

Where required under the DPDP Act, Luxury Watch Works processes personal data only after obtaining the free, specific, informed, unconditional and unambiguous consent of the Data Principal through a clear affirmative action.

Consent may be obtained when you:

  • Submit an enquiry through our Website;

  • Request information regarding our products or services;

  • Register for workshops, seminars, educational programmes, or events;

  • Subscribe to newsletters or promotional communications;

  • Choose to receive marketing communications;

  • Participate in surveys or feedback initiatives; or

  • Otherwise provide your personal data for a specified purpose.

Where processing is based on your consent, you may withdraw such consent at any time in accordance with applicable law and this Privacy Policy. Withdrawal of consent shall not affect the lawfulness of any processing carried out before such withdrawal.

8.2 Processing for Certain Legitimate Uses

In certain circumstances, the DPDP Act permits the processing of personal data without obtaining separate consent.

Accordingly, Luxury Watch Works may process personal data where such processing is permitted under applicable law, including where it is reasonably necessary:

  • To provide or facilitate a service or transaction that you have voluntarily requested;

  • To comply with applicable legal or regulatory obligations;

  • To respond to lawful requests from competent governmental or regulatory authorities;

  • To protect the rights, safety, or security of individuals or property where permitted by law;

  • To establish, exercise, or defend legal claims; or

  • For any other purpose expressly permitted under the DPDP Act or other applicable laws.

Luxury Watch Works will rely on such grounds only where they are applicable and permitted by law.

8.3 Purpose Limitation

Luxury Watch Works processes personal data only for the specific purpose for which it was collected, for purposes that are compatible with that original purpose where permitted by applicable law, or for any other lawful purpose authorised under the DPDP Act.

We do not use personal data for unrelated or incompatible purposes without providing an appropriate notice and obtaining consent where required.

8.4 Data Minimisation

Luxury Watch Works seeks to collect and process only such personal data as is reasonably necessary for the relevant purpose.

We regularly review our data collection practices to ensure that unnecessary personal data is not collected, retained, or processed.

8.5 Accuracy of Personal Data

Where appropriate having regard to the purpose for which personal data is processed, Luxury Watch Works takes reasonable steps to ensure that personal data is accurate, complete, and up to date.

We encourage individuals to notify us promptly if their personal information changes or requires correction.

8.6 Accountability

Luxury Watch Works remains responsible for ensuring that personal data entrusted to us is processed in accordance with the DPDP Act, applicable rules, and this Privacy Policy, including where processing activities are carried out by authorised service providers acting on our behalf.

Our internal policies and procedures are designed to support responsible data governance, appropriate security safeguards, and compliance with applicable legal requirements.

9. Sharing of Personal Data

Luxury Watch Works respects the confidentiality of your personal data and does not sell, rent, trade, or otherwise disclose your personal data to third parties for their independent marketing purposes.
We may share personal data only where it is necessary for the purposes described in this Privacy Policy, where required by applicable law, or where you have provided your consent.
Depending on the nature of our business operations and the services requested by you, your personal data may be shared with the following categories of recipients.

9.1 Authorised Service Providers (Data Processors)

Luxury Watch Works may engage carefully selected third-party service providers to perform services on our behalf. Such service providers process personal data only in accordance with our documented instructions and for the purposes authorised by Luxury Watch Works.

These service providers may include organisations providing:

  • Website hosting and maintenance;

  • Cloud infrastructure and data storage;

  • Information technology support;

  • Customer relationship management systems;

  • Email and communication platforms;

  • WhatsApp Business messaging services;

  • Website analytics and performance monitoring;

  • Digital marketing support;

  • Payment processing services;

  • Logistics and courier services;

  • Document management and secure storage; and

  • Other operational services reasonably necessary for our business.

Luxury Watch Works remains responsible for ensuring that personal data processed on its behalf is handled in accordance with applicable law.

9.2 Professional Advisers

Where reasonably necessary, we may share personal data with our professional advisers, including:

  • Legal advisers;

  • Chartered accountants;

  • Auditors;

  • Compliance consultants; and

  • Other professional advisers engaged to support our business operations.

Such disclosures are made only where necessary for professional services and subject to appropriate obligations of confidentiality.

9.3 Regulatory Authorities and Government Agencies

We may disclose personal data where required or authorised by applicable law, including where disclosure is necessary:

  • To comply with legal obligations;

  • To respond to lawful requests issued by courts, regulators, or competent governmental authorities;

  • To comply with judicial proceedings;

  • To protect our legal rights;

  • To investigate suspected unlawful activities; or

  • To fulfil statutory or regulatory reporting requirements.

9.4 Business Transactions

In the event of a proposed or completed merger, acquisition, restructuring, reorganisation, transfer of assets, investment, or other corporate transaction involving Luxury Watch Works, personal data may be transferred to the relevant parties, subject to appropriate confidentiality obligations and compliance with applicable law.

9.5 With Your Direction or Consent

We may share your personal data with other individuals or organisations where:

  • You have expressly requested or authorised us to do so;

  • You have provided your consent; or

  • Such sharing is necessary to fulfil a service specifically requested by you.

9.6 International Processing

Where our authorised service providers process personal data outside India, such processing shall be undertaken only where permitted under applicable law and subject to appropriate contractual, technical, and organisational safeguards designed to protect your personal data.

9.7 Protection of Personal Data During Sharing

Before sharing personal data with authorised recipients, Luxury Watch Works takes reasonable steps to ensure that:

  • The sharing is necessary for a lawful and specified purpose;

  • Appropriate contractual or legal obligations apply where required;

  • Reasonable security measures are maintained to protect personal data;

  • Access to personal data is limited to authorised persons with a legitimate need to know; and

  • Personal data is not used for purposes inconsistent with this Privacy Policy or applicable law.

9.8 No Sale of Personal Data

Luxury Watch Works does not sell or commercially exploit personal data.

We do not disclose personal data to third parties for their own advertising or independent marketing purposes.

Any sharing of personal data is undertaken solely for legitimate business purposes, compliance with applicable legal obligations, the provision of requested services, or other purposes permitted under the Digital Personal Data Protection Act, 2023.

10. Website Forms and Service Enquiries

Luxury Watch Works provides various online forms and communication channels to enable individuals to enquire about our services, request quotations, schedule consultations, arrange watch servicing, register for events, or otherwise communicate with us.

When you voluntarily submit information through any of our Website forms or authorised communication channels, we collect and process your personal data only for the purposes described in this Privacy Policy and in accordance with applicable law.

10.1 Information Collected Through Website Forms

Depending on the nature of your enquiry or request, we may collect information including:

  • Full name;

  • Email address;

  • Mobile or telephone number;

  • City and State;

  • Details relating to your watch, including the brand, model, or service requirements;

  • The nature of your enquiry or message;

  • Any supporting documents, photographs, or information voluntarily submitted by you; and

  • Any other information reasonably necessary to respond to your request.

We request that you provide only such personal data as is reasonably necessary for the purpose of your enquiry.

10.2 Purpose of Collection

Information submitted through our Website forms may be used to:

  • Respond to your enquiry;

  • Provide quotations or service estimates;

  • Arrange consultations or appointments;

  • Process requests for servicing, restoration, authentication, inspection, valuation, or related services;

  • Communicate regarding your requested services;

  • Provide customer support;

  • Maintain records relating to your enquiry or service request; and

  • Comply with applicable legal and regulatory obligations.

Luxury Watch Works does not use information submitted through Website enquiry forms for purposes that are incompatible with those described in this Privacy Policy unless permitted by applicable law or where we have obtained your consent where required.

10.3 Accuracy of Information

You are responsible for ensuring that the personal data provided by you is accurate, complete, and up to date.

Where your contact details or other relevant information change, we encourage you to notify us so that we may maintain accurate records and continue to provide our services effectively.

10.4 Service Enquiries

Where you request watch servicing, restoration, authentication, valuation, inspection, polishing, maintenance, or related services, Luxury Watch Works may collect additional information reasonably necessary to:

  • Identify your service requirements;

  • Assess your watch;

  • Prepare quotations;

  • Communicate technical observations;

  • Maintain service records;

  • Coordinate collections and deliveries where applicable;

  • Issue invoices; and

  • Provide post-service support.

Such information is processed only to the extent reasonably necessary for providing the requested services and fulfilling our contractual, operational, and legal obligations.

10.5 Consent and Privacy Notice

Where required under applicable law, Luxury Watch Works will provide an appropriate privacy notice and obtain your consent before processing personal data submitted through our Website forms.

Our Website forms are designed to inform individuals of:

  • the purpose for which personal data is being collected;

  • the categories of personal data requested;

  • how the information will be used;

  • where additional information can be found in this Privacy Policy; and

  • how individuals may contact us regarding privacy-related requests or grievances.

Where processing is based on consent, you may withdraw your consent in accordance with applicable law and the provisions of this Privacy Policy.

10.6 Marketing Communications

Submitting a Website enquiry or requesting our services does not, by itself, constitute consent to receive marketing or promotional communications.

Where Luxury Watch Works offers newsletters, promotional updates, educational content, event invitations, or other marketing communications, such communications will be sent only where permitted under applicable law and, where required, based on your separate consent.

You may opt out of marketing communications at any time by following the unsubscribe instructions provided in the communication or by contacting Luxury Watch Works using the contact details provided in this Privacy Policy.

10.7 Protection of Information Submitted Through Website Forms

Luxury Watch Works implements reasonable technical and organisational measures to safeguard personal data submitted through our Website forms against unauthorised access, disclosure, alteration, misuse, or loss.

Information submitted through our Website forms is accessible only to authorised personnel and authorised service providers who require such access for legitimate business purposes and who are subject to appropriate confidentiality and security obligations.

11. WhatsApp Business Communications

Luxury Watch Works recognises that WhatsApp is an important communication channel for providing customer support, service updates, appointment coordination, and other business communications. We are committed to processing personal data exchanged through WhatsApp Business in accordance with the Digital Personal Data Protection Act, 2023 ("DPDP Act"), applicable rules, and this Privacy Policy.

11.1 Purpose of WhatsApp Communications

Where you choose to communicate with us through WhatsApp Business, we may process your personal data for purposes including:

  • Responding to your enquiries;

  • Scheduling appointments and consultations;

  • Providing quotations and service estimates;

  • Coordinating watch collections and deliveries;

  • Providing service progress updates;

  • Sharing inspection findings and service reports;

  • Responding to customer support requests;

  • Providing warranty-related assistance;

  • Sending invoices, receipts, and other transaction-related communications; and

  • Any other communication reasonably necessary to provide the services requested by you.

11.2 Information We May Process

Depending on the nature of your communication, we may process:

  • Your mobile telephone number;

  • Your name;

  • WhatsApp profile information voluntarily made available by you;

  • Messages exchanged between you and Luxury Watch Works;

  • Photographs, videos, documents, or other files voluntarily shared by you;

  • Information relating to your watch and requested services; and

  • Records of customer support interactions.

We request that you do not share personal data that is not reasonably necessary for your enquiry or service request.

11.3 Service Communications

Luxury Watch Works may communicate with you through WhatsApp Business regarding:

  • Appointment confirmations;

  • Service reminders;

  • Collection and delivery arrangements;

  • Service status updates;

  • Technical observations;

  • Requests for additional information;

  • Warranty support;

  • Customer support responses; and

  • Other communications directly related to the services requested by you.

Such communications are intended to facilitate the efficient delivery of our services.

11.4 Marketing Communications

Where Luxury Watch Works offers marketing communications through WhatsApp, including promotional updates, educational content, maintenance recommendations, event invitations, newsletters, or information regarding new services, such communications shall be sent only where permitted under applicable law and, where required, based on your consent.

You may withdraw your consent to receive marketing communications at any time by replying with an unsubscribe request, using any opt-out mechanism provided, or by contacting Luxury Watch Works using the contact details provided in this Privacy Policy.

Withdrawal of marketing consent will not affect our ability to send communications that are necessary to provide the services requested by you.

11.5 Use of WhatsApp Business Service Providers

Luxury Watch Works may use authorised WhatsApp Business Solution Providers or communication service providers to facilitate customer communications.

Where such providers process personal data on our behalf, they do so only for authorised business purposes and in accordance with applicable contractual obligations, appropriate security measures, and applicable law.

11.6 Customer Responsibilities

When communicating with Luxury Watch Works through WhatsApp, you are requested to:

  • Provide accurate information;

  • Avoid sharing unnecessary personal information;

  • Avoid sharing passwords, banking credentials, or other confidential information that is not required for the requested services; and

  • Inform us promptly if your contact details change.

11.7 Security of WhatsApp Communications

Luxury Watch Works implements reasonable administrative, technical, and organisational measures to protect personal data processed through WhatsApp Business.

While WhatsApp Business incorporates security features, no method of electronic communication or transmission over the internet can be guaranteed to be completely secure. We encourage customers to exercise appropriate caution when transmitting personal information electronically.

11.8 Record Retention

WhatsApp communications may be retained for as long as reasonably necessary to:

  • Maintain customer service records;

  • Respond to enquiries;

  • Resolve disputes or complaints;

  • Comply with legal or regulatory obligations; or

  • Support the administration of our business.

Such records will be managed in accordance with our data retention practices and applicable law.

12. Email Communications

Luxury Watch Works uses email as an official communication channel to provide customer support, respond to enquiries, deliver service-related information, administer business operations, and, where permitted under applicable law, communicate marketing and educational content.

We process personal data contained in email communications in accordance with the Digital Personal Data Protection Act, 2023 ("DPDP Act"), applicable rules, and this Privacy Policy.

12.1 Purpose of Email Communications

We may communicate with you by email for purposes including:

  • Responding to enquiries and requests for information;

  • Providing quotations and service estimates;

  • Confirming appointments and service bookings;

  • Sending service progress updates;

  • Delivering inspection reports and technical assessments;

  • Issuing invoices, receipts, and payment confirmations;

  • Providing warranty information and post-service support;

  • Responding to customer support requests;

  • Resolving complaints or grievances; and

  • Complying with applicable legal or regulatory obligations.

12.2 Information Processed Through Email

Depending on the nature of the communication, we may process:

  • Your name;

  • Email address;

  • Mobile or telephone number (where included);

  • Organisation or company name (where applicable);

  • Details relating to your enquiry or requested services;

  • Watch-related information;

  • Attachments voluntarily provided by you, including photographs or documents;

  • Email correspondence and communication history; and

  • Other information reasonably necessary to respond to your request.

We request that you provide only such personal data as is reasonably necessary for your enquiry or the services requested.

12.3 Service-Related Communications

Luxury Watch Works may send service-related emails that are necessary for the administration and delivery of the services requested by you.

Such communications may include:

  • Acknowledgement of enquiries;

  • Appointment confirmations;

  • Quotations and estimates;

  • Service status updates;

  • Technical observations;

  • Collection and delivery coordination;

  • Invoice and payment notifications;

  • Warranty information;

  • Service completion notifications; and

  • Responses to customer support requests.

These communications are considered operational in nature and are intended solely to facilitate the services requested by you.

12.4 Marketing and Promotional Communications

Where Luxury Watch Works sends newsletters, educational content, luxury watch care insights, maintenance recommendations, event invitations, promotional campaigns, or information regarding new products or services, such communications will be sent only where permitted under applicable law and, where required, based on your consent.

Marketing communications are separate from operational service communications.

Where applicable, every marketing email will include an appropriate mechanism enabling you to unsubscribe or withdraw your consent to receive future promotional communications.

Withdrawal of your consent to receive marketing communications will not affect our ability to send emails that are necessary to administer the services requested by you or to comply with our legal obligations.

12.5 Email Service Providers

Luxury Watch Works may use authorised email service providers and communication platforms to facilitate business and marketing communications.

Such service providers process personal data only on our behalf, in accordance with our documented instructions, applicable contractual obligations, and appropriate technical and organisational safeguards.

12.6 Security of Email Communications

Luxury Watch Works implements reasonable administrative, technical, and organisational measures to safeguard personal data transmitted and stored through email communications.

However, electronic communications transmitted over the internet cannot be guaranteed to be completely secure. While we take reasonable precautions to protect personal data, we encourage individuals to exercise appropriate care when sending confidential or sensitive information by email.

12.7 Retention of Email Communications

Email correspondence may be retained for as long as reasonably necessary to:

  • Maintain customer service records;

  • Provide ongoing customer support;

  • Administer our services;

  • Resolve disputes or complaints;

  • Establish, exercise, or defend legal claims;

  • Comply with applicable legal, regulatory, taxation, or accounting obligations; or

  • Meet our legitimate business record-keeping requirements.

Email records are retained and securely managed in accordance with our internal data retention policies and applicable law.

13. Horology 101 and Event Registrations

Luxury Watch Works organises and participates in educational programmes, workshops, seminars, masterclasses, networking events, exhibitions, and other initiatives to promote horological knowledge, luxury watch ownership, and customer engagement.

Where you register for or participate in any such programme or event, Luxury Watch Works may collect and process your personal data in accordance with the Digital Personal Data Protection Act, 2023 ("DPDP Act"), applicable rules, and this Privacy Policy.

13.1 Purpose of Collection

We collect personal data relating to event registrations for purposes including:

  • Registering your participation;

  • Confirming attendance;

  • Managing event logistics;

  • Communicating event schedules and updates;

  • Verifying participant information where necessary;

  • Providing event-related materials;

  • Issuing attendance confirmations or certificates, where applicable;

  • Responding to participant enquiries;

  • Improving future educational programmes and events; and

  • Complying with applicable legal, regulatory, or administrative requirements.

13.2 Information We May Collect

Depending on the nature of the programme or event, we may collect:

  • Full name;

  • Email address;

  • Mobile telephone number;

  • Organisation or company name (where applicable);

  • Job title or professional designation (where voluntarily provided);

  • City and State;

  • Registration preferences;

  • Attendance records;

  • Dietary or accessibility requirements (where voluntarily provided and relevant to the event);

  • Feedback submitted after the event; and

  • Any additional information voluntarily provided during registration or participation.

We request that participants provide only such information as is reasonably necessary for the administration of the event.

13.3 Event Communications

Luxury Watch Works may use your contact details to communicate with you regarding:

  • Registration confirmations;

  • Event reminders;

  • Changes to the programme or schedule;

  • Venue information;

  • Speaker updates;

  • Educational materials;

  • Certificates of participation (where applicable);

  • Feedback requests; and

  • Other communications directly related to the event for which you have registered.

These communications are operational in nature and are intended solely to facilitate your participation in the relevant programme or event.

13.4 Photographs, Audio and Video Recordings

Certain events organised by Luxury Watch Works may be photographed, audio recorded, or video recorded for documentation, educational, promotional, or archival purposes.

Where your identifiable image, voice, or other personal data is intended to be used for promotional or marketing purposes beyond reasonable event documentation, Luxury Watch Works will provide appropriate notice and, where required under applicable law, obtain your consent.

If you do not wish to appear in promotional photographs or recordings, you may notify the event organiser before or during the event, and we will make reasonable efforts to accommodate your request where practicable.

13.5 Marketing Communications

Registering for a Horology 101 programme, workshop, seminar, or other event does not automatically constitute consent to receive future marketing or promotional communications.

Where Luxury Watch Works wishes to send newsletters, educational updates, event invitations, promotional content, or information about future programmes, such communications will be sent only where permitted under applicable law and, where required, based on your consent.

You may withdraw your consent to receive marketing communications at any time by using the unsubscribe mechanism provided or by contacting Luxury Watch Works.

13.6 Sharing of Event Information

Luxury Watch Works may share limited personal data with authorised service providers engaged for the administration of an event, including providers of event management, registration platforms, venue management, communication services, audiovisual support, or related operational services.

Such service providers process personal data only on behalf of Luxury Watch Works and in accordance with appropriate contractual obligations, confidentiality requirements, and applicable law.

Luxury Watch Works does not sell participant information or disclose it to third parties for their independent marketing purposes.

13.7 Retention of Event Records

Personal data relating to event registrations may be retained for as long as reasonably necessary to:

  • Maintain attendance records;

  • Respond to participant enquiries;

  • Administer future communications where consent has been provided;

  • Evaluate and improve future programmes;

  • Resolve complaints or disputes;

  • Comply with applicable legal or regulatory obligations; or

  • Maintain legitimate business records.

At the end of the applicable retention period, personal data will be securely deleted, anonymised, or otherwise disposed of in accordance with our internal data retention policies and applicable law.

14. Watch Servicing, Repairs and Authentication Records

Watch servicing, repairs, restoration, authentication, inspection, valuation, polishing, preventive maintenance, and related after-sales services form the core business activities of Luxury Watch Works.

To provide these specialised services, Luxury Watch Works collects and maintains records relating to customers, their timepieces, requested services, technical assessments, and associated business transactions.

Such information is processed only to the extent reasonably necessary for providing our services, maintaining service history, complying with applicable legal obligations, protecting customer interests, and supporting the long-term ownership and preservation of luxury timepieces.

14.1 Purpose of Processing

Luxury Watch Works may process personal data and service-related information for purposes including:

  • Registering service requests;

  • Identifying customers and their watches;

  • Conducting inspections and technical diagnostics;

  • Preparing service estimates and quotations;

  • Performing servicing, repairs, restoration, authentication, valuation, polishing, and related services;

  • Procuring genuine components and spare parts where required;

  • Maintaining complete service histories;

  • Providing warranty support and after-sales assistance;

  • Coordinating collection and delivery services;

  • Responding to customer enquiries;

  • Maintaining quality assurance records;

  • Resolving disputes or complaints; and

  • Complying with applicable legal, taxation, accounting, and regulatory obligations.

14.2 Information We May Collect

Depending upon the services requested, we may process information including:

Customer Information

  • Full name;

  • Contact number;

  • Email address;

  • Postal or correspondence address;

  • Billing information;

  • Customer identification or service reference number.

Watch Information

  • Brand;

  • Model;

  • Reference number;

  • Serial number;

  • Movement details (where applicable);

  • Year of manufacture or purchase (where available);

  • Service history;

  • Warranty status;

  • Ownership information voluntarily provided by the customer;

  • Condition at the time of receipt.

Service Information

  • Customer-reported observations;

  • Technical inspection findings;

  • Diagnostic reports;

  • Service recommendations;

  • Parts replaced;

  • Repair records;

  • Authentication findings;

  • Valuation details (where requested);

  • Water resistance test results;

  • Timekeeping test results;

  • Final quality control reports;

  • Collection and delivery records.

Supporting Documentation

Where relevant, we may also process:

  • Photographs of the watch before, during, and after servicing;

  • Customer correspondence;

  • Service authorisations;

  • Quotations;

  • Invoices;

  • Warranty documentation;

  • Proof of collection or delivery; and

  • Other documentation reasonably necessary for administering the requested services.

14.3 Service History

Luxury Watch Works may maintain historical service records relating to watches serviced by us.

These records assist us in:

  • Providing consistent after-sales support;

  • Maintaining accurate servicing history;

  • Supporting future diagnostics;

  • Verifying previous repairs;

  • Processing warranty-related matters; and

  • Improving the quality and continuity of our services.

Historical service records are retained only for as long as reasonably necessary for these purposes and in accordance with applicable law.

14.4 Authentication and Valuation Services

Where a customer requests authentication, inspection, condition reporting, or valuation services, Luxury Watch Works may collect and process additional information reasonably necessary to perform those services.

Authentication and valuation reports are prepared based on the information and physical condition of the watch at the time of inspection. Such reports are maintained as part of our service records and may be retained for quality assurance, customer support, legal compliance, and record-keeping purposes.

14.5 Confidentiality of Service Records

Luxury Watch Works treats all customer service records and watch-related information as confidential.

Access to such records is restricted to authorised personnel and authorised service providers who require access for legitimate business purposes and who are subject to appropriate confidentiality obligations.

We do not disclose customer service records to third parties except:

  • With your consent;

  • Where necessary to provide the requested services;

  • Where required by applicable law;

  • To authorised service providers acting on our behalf; or

  • Where otherwise permitted under the Digital Personal Data Protection Act, 2023.

14.6 Retention of Service Records

Service records, technical reports, inspection findings, photographs, invoices, quotations, and related documentation may be retained for as long as reasonably necessary to:

  • Maintain service history;

  • Provide warranty and post-service support;

  • Respond to customer enquiries;

  • Establish, exercise, or defend legal claims;

  • Comply with statutory, taxation, accounting, or regulatory obligations; and

  • Support legitimate business record-keeping requirements.

At the end of the applicable retention period, such records will be securely deleted, anonymised, or otherwise disposed of in accordance with our internal data retention policies and applicable law.

14.7 Security of Service Records

Luxury Watch Works implements appropriate administrative, technical, and organisational safeguards to protect customer information and watch service records against unauthorised access, disclosure, alteration, misuse, loss, or destruction.

Access to service records is limited to authorised personnel whose responsibilities require such access. We periodically review our internal processes and security measures to support the confidentiality, integrity, and availability of customer information throughout the service lifecycle.

15. Cookies and Website Technologies

Luxury Watch Works uses cookies and similar technologies on its Website to support website functionality, improve user experience, understand how visitors interact with our Website, enhance website security, and measure the effectiveness of our digital services and marketing activities.

This section explains how these technologies operate and how you may manage your preferences.

15.1 What Are Cookies?

Cookies are small text files that are stored on your computer, mobile device, or other internet-enabled device when you visit a website.

Cookies enable a website to recognise your device, remember certain preferences, improve website performance, analyse visitor behaviour, and support the delivery of online services.

In addition to cookies, our Website may use similar technologies such as pixels, tags, scripts, software development kits (SDKs), local storage, or other technologies that perform comparable functions.

15.2 Types of Cookies We Use

Depending on the features available on our Website, Luxury Watch Works may use the following categories of cookies and similar technologies.

(a) Strictly Necessary Cookies

These cookies are essential for the operation of the Website and enable core functionality, including:

  • Website navigation;

  • Security features;

  • Session management;

  • Form submissions; and

  • Basic website functionality.

Without these cookies, certain parts of the Website may not function correctly.

(b) Functional Cookies

These cookies help remember your preferences and improve your browsing experience by enabling features such as:

  • Language preferences;

  • User settings;

  • Form convenience features; and

  • Other functionality designed to improve website usability.

(c) Analytics and Performance Cookies

We may use analytics technologies to understand how visitors interact with our Website, including information relating to:

  • Pages visited;

  • Website navigation;

  • Device type;

  • Browser information;

  • Approximate geographic location;

  • Referral sources;

  • Session duration;

  • User interactions; and

  • Overall Website performance.

Such information helps us improve our Website, identify technical issues, evaluate content performance, and enhance the overall user experience.

Where reasonably possible, analytics information is used in an aggregated or de-identified form.

(d) Advertising and Marketing Technologies

Where enabled, our Website may use advertising and marketing technologies to:

  • Measure the effectiveness of advertising campaigns;

  • Understand customer engagement;

  • Improve marketing performance;

  • Deliver more relevant advertising content; and

  • Support audience measurement and campaign analytics.

Where required under applicable law, such technologies will be used only after obtaining your consent.

15.3 Third-Party Technologies

Luxury Watch Works may use third-party technologies and services to support Website functionality, analytics, advertising, security, communication, and performance monitoring.

These providers may place or access cookies or similar technologies in accordance with their respective privacy practices and applicable law.

Examples of such services may include:

  • Website hosting platforms;

  • Website analytics providers;

  • Tag management services;

  • Advertising platforms;

  • Embedded content providers; and

  • Security or performance monitoring services.

Luxury Watch Works encourages users to review the privacy policies of such third-party providers where appropriate.

15.4 Managing Cookie Preferences

You may manage or disable cookies through your browser settings.

Most web browsers allow you to:

  • View stored cookies;

  • Delete existing cookies;

  • Block future cookies;

  • Receive notifications before cookies are placed; and

  • Configure cookie preferences.

Please note that disabling certain cookies may affect the functionality, performance, or availability of certain features of our Website.

Where our Website provides a cookie consent or preference management mechanism, you may update your preferences at any time through that mechanism.

15.5 Information Collected Through Cookies

Depending on the technologies used, cookies and similar technologies may collect information including:

  • Internet Protocol (IP) address;

  • Browser type and version;

  • Device identifiers;

  • Operating system;

  • Date and time of visit;

  • Website pages viewed;

  • Session information;

  • Referral URLs;

  • Clickstream information;

  • Website interactions; and

  • Other technical information reasonably necessary for Website operation, analytics, and security.

Such information is processed in accordance with this Privacy Policy and applicable law.

15.6 Cookie Retention

Different cookies remain on your device for different periods depending upon their purpose.

Some cookies are deleted automatically when your browsing session ends, while persistent cookies remain on your device until they expire or are deleted by you through your browser settings.

Luxury Watch Works periodically reviews the cookies and similar technologies used on its Website to ensure they remain appropriate for our business operations and legal obligations.

15.7 Updates to Cookie Practices

As our Website, technology, and business operations evolve, Luxury Watch Works may introduce, modify, or discontinue the use of cookies or similar technologies.

Where such changes materially affect the processing of personal data, we will update this Privacy Policy and, where required under applicable law, provide appropriate notice or obtain consent before implementing such changes.


16. Google Analytics and Website Performance

Luxury Watch Works uses website analytics and performance monitoring tools to better understand how visitors interact with our Website, improve user experience, enhance website performance, measure the effectiveness of our digital initiatives, and support informed business decisions.

These technologies help us evaluate how our Website is used while supporting the security, reliability, and continuous improvement of our online services.

16.1 Purpose of Website Analytics

Website analytics are used to:

  • Measure Website traffic and visitor engagement;

  • Understand how visitors navigate our Website;

  • Identify the most frequently viewed pages and content;

  • Monitor Website performance and availability;

  • Improve Website usability and accessibility;

  • Detect and resolve technical issues;

  • Evaluate the effectiveness of marketing campaigns;

  • Measure conversions and customer enquiries;

  • Improve search engine visibility and Website performance; and

  • Support data-driven business and marketing decisions.

16.2 Analytics Information We May Process

Depending on your browser settings, cookie preferences, and the technologies used on our Website, analytics tools may process information including:

  • Internet Protocol (IP) address;

  • Browser type and version;

  • Device type and operating system;

  • Screen resolution and browser language;

  • Approximate geographic location;

  • Pages visited;

  • Time spent on pages;

  • Navigation paths;

  • Website interactions;

  • Referral source;

  • Search queries leading to our Website (where available);

  • Date and time of visits;

  • Session information; and

  • Other technical information necessary for Website analytics and performance monitoring.

Where reasonably practicable, such information is analysed in aggregated or de-identified form.

16.3 Analytics and Performance Technologies

Luxury Watch Works may use analytics, tag management, and website performance technologies provided by authorised third-party service providers to support the operation and continuous improvement of our Website.

These technologies may assist in:

  • Measuring Website usage;

  • Monitoring Website performance;

  • Managing analytics tags;

  • Understanding user behaviour;

  • Measuring advertising effectiveness;

  • Monitoring search performance; and

  • Supporting search engine optimisation (SEO) and Website optimisation initiatives.

Such service providers process information in accordance with their applicable privacy practices and contractual obligations.

16.4 Search Performance and Website Optimisation

Luxury Watch Works may use website performance and search analytics tools to understand how our Website appears in search engines and how visitors discover our online services.

This information may include:

  • Search queries;

  • Click-through rates;

  • Search impressions;

  • Website indexing information;

  • Page performance metrics;

  • Technical Website diagnostics; and

  • Other search performance information.

Such information assists us in improving Website quality, discoverability, accessibility, and user experience.

16.5 Advertising Measurement

Where applicable, website analytics may also be used to:

  • Measure the effectiveness of online advertising campaigns;

  • Understand visitor engagement following advertising campaigns;

  • Evaluate conversion performance;

  • Improve audience measurement; and

  • Optimise marketing initiatives.

Where required under applicable law, advertising-related analytics will be used only after obtaining the appropriate consent.

16.6 Data Security

Luxury Watch Works takes reasonable steps to ensure that information collected through analytics and Website performance technologies is protected using appropriate administrative, technical, and organisational safeguards.

Access to analytics information is restricted to authorised personnel and authorised service providers who require such access for legitimate business purposes.

16.7 Your Choices

Where our Website provides a cookie or consent management mechanism, you may manage your analytics and advertising preferences through that mechanism.

You may also manage certain analytics-related settings through your browser configuration or other available privacy controls provided by your device or the relevant service provider.

Disabling analytics technologies may affect our ability to improve Website performance and user experience but will not prevent you from accessing the core functionality of our Website where technically feasible.

16.8 Continuous Review

Luxury Watch Works periodically reviews its use of website analytics and performance technologies to ensure that they remain appropriate, proportionate, and aligned with our legitimate business requirements, our privacy commitments, and applicable law.

Where we introduce new analytics technologies that materially affect the processing of personal data, we will update this Privacy Policy and, where required, provide an appropriate notice or obtain consent before implementing such changes.

17. Third-Party Service Providers (Data Processors)

Luxury Watch Works engages carefully selected third-party service providers ("Data Processors") to support the operation of our business, the delivery of our services, the administration of our Website, customer communications, technology infrastructure, payment processing, marketing activities, and other legitimate business functions.

Where such service providers process personal data on behalf of Luxury Watch Works, they do so only in accordance with our documented instructions, applicable contractual obligations, the Digital Personal Data Protection Act, 2023 ("DPDP Act"), and other applicable laws.

Luxury Watch Works remains responsible for ensuring that personal data processed on its behalf is handled with appropriate care and in accordance with applicable legal requirements.

17.1 Categories of Data Processors

Depending on the services requested by you and the nature of our business operations, we may engage Data Processors providing services including:

  • Website hosting and infrastructure;

  • Cloud computing and secure data storage;

  • Information technology support;

  • Customer relationship management (CRM) systems;

  • Email communication platforms;

  • WhatsApp Business communication platforms;

  • Marketing automation and campaign management services;

  • Website analytics and performance monitoring;

  • Search engine optimisation and digital marketing support;

  • Payment processing services;

  • Accounting and financial administration;

  • Logistics, courier, and delivery services;

  • Document management;

  • Security monitoring; and

  • Other operational services reasonably necessary for our business.

These Data Processors receive access only to the personal data reasonably necessary for the specific services they perform.

17.2 Processing Instructions

Data Processors engaged by Luxury Watch Works are authorised to process personal data only:

  • For the purposes specified by Luxury Watch Works;

  • In accordance with applicable contractual obligations;

  • In compliance with applicable law;

  • Subject to appropriate confidentiality obligations; and

  • Using appropriate technical and organisational safeguards.

They are not authorised to use personal data for their own independent purposes unless they have an independent legal basis to do so.

17.3 Selection of Service Providers

Before engaging a Data Processor, Luxury Watch Works seeks to assess whether the service provider is capable of implementing appropriate measures to protect personal data.

Such assessments may include consideration of:

  • Information security practices;

  • Privacy controls;

  • Technical capabilities;

  • Confidentiality obligations;

  • Regulatory compliance;

  • Operational reliability; and

  • The nature of the services to be provided.

Luxury Watch Works periodically reviews its relationships with Data Processors as part of its ongoing privacy governance programme.

17.4 Security Measures

Luxury Watch Works requires its authorised Data Processors, where appropriate, to implement reasonable administrative, technical, physical, and organisational safeguards designed to protect personal data against:

  • Unauthorised access;

  • Unauthorised disclosure;

  • Alteration;

  • Misuse;

  • Accidental loss;

  • Destruction; and

  • Other unlawful or unauthorised processing activities.

17.5 Confidentiality

Authorised Data Processors are expected to maintain the confidentiality of personal data processed on behalf of Luxury Watch Works and to restrict access to authorised personnel who require such access for legitimate business purposes.

17.6 International Processing

Certain authorised Data Processors may process personal data outside India where such processing is necessary for the provision of their services.

Where personal data is processed outside India, Luxury Watch Works will take reasonable steps to ensure that such processing is undertaken in accordance with the DPDP Act, applicable rules, and any restrictions or requirements that may be notified by the Government of India regarding cross-border transfers of personal data.

17.7 Monitoring and Oversight

Luxury Watch Works periodically reviews its Data Processors to ensure that they continue to support appropriate standards of privacy, security, confidentiality, and regulatory compliance.

Where appropriate, we may update our internal records, contractual arrangements, or operational practices to reflect changes in applicable law, business requirements, or the services provided by our Data Processors.

17.8 Changes to Service Providers

As our business evolves, Luxury Watch Works may appoint, replace, or discontinue Data Processors from time to time.

Such operational changes will not affect the manner in which we protect personal data. Where any change materially affects the processing of personal data, we will update this Privacy Policy and provide any notice required under applicable law.

18. Sharing of Personal Data

Luxury Watch Works respects the confidentiality of the personal data entrusted to us. We do not sell, rent, lease, or otherwise disclose personal data to third parties for their independent marketing purposes.

We share personal data only where such sharing is necessary to provide our services, fulfil contractual or legal obligations, support our legitimate business operations, or where you have provided your consent or where such processing is otherwise permitted under the Digital Personal Data Protection Act, 2023 ("DPDP Act") and other applicable laws.

18.1 Categories of Recipients

Depending on the nature of your interaction with Luxury Watch Works, your personal data may be shared with one or more of the following categories of recipients:

  • Authorised employees of Luxury Watch Works;

  • Authorised Data Processors acting on our behalf;

  • Information technology and cloud service providers;

  • Customer relationship management and communication platforms;

  • Website hosting and analytics providers;

  • Payment processing service providers;

  • Logistics and courier partners;

  • Professional advisers, including legal advisers, auditors, accountants, and consultants;

  • Insurance providers, where relevant to a requested service;

  • Government authorities, regulators, courts, or law enforcement agencies where disclosure is required or authorised by law; and

  • Other parties where disclosure is necessary to provide the services requested by you.

18.2 Purpose of Sharing

Where personal data is shared, it is shared only to the extent reasonably necessary for purposes including:

  • Providing requested services;

  • Processing enquiries and service requests;

  • Managing customer communications;

  • Operating and maintaining our Website and technology infrastructure;

  • Processing payments and financial transactions;

  • Delivering watches and related documentation;

  • Providing customer support;

  • Performing analytics and service improvements;

  • Protecting our legal rights and business interests;

  • Preventing fraud and maintaining security; and

  • Complying with applicable legal and regulatory obligations.

18.3 Confidentiality and Access Controls

Luxury Watch Works restricts access to personal data to individuals and organisations that require such access for authorised business purposes.

Persons receiving personal data on our behalf are expected to maintain appropriate standards of confidentiality and implement reasonable security measures designed to protect personal data from unauthorised access, disclosure, alteration, misuse, or loss.

18.4 No Sale or Commercial Exploitation of Personal Data

Luxury Watch Works does not:

  • Sell personal data;

  • Rent personal data;

  • Trade personal data;

  • License personal data for independent commercial exploitation; or

  • Permit third parties to use personal data for their own marketing purposes without an appropriate legal basis.

18.5 Legal and Regulatory Disclosures

We may disclose personal data where necessary to:

  • Comply with applicable laws or regulations;

  • Respond to lawful requests from courts, regulators, or government authorities;

  • Protect the rights, property, or safety of Luxury Watch Works, our customers, employees, or other individuals;

  • Investigate suspected fraud, unlawful activities, or security incidents; or

  • Establish, exercise, or defend legal claims.

18.6 Corporate Transactions

Where Luxury Watch Works undergoes a merger, acquisition, investment, restructuring, business transfer, or similar corporate transaction, personal data may be transferred as part of that transaction, subject to appropriate confidentiality obligations and compliance with applicable law.

18.7 Cross-Border Sharing

Where personal data is processed or accessed outside India by authorised Data Processors or service providers, Luxury Watch Works will take reasonable steps to ensure that such processing is carried out in accordance with the DPDP Act, applicable rules, and any restrictions or requirements that may be notified by the Government of India regarding cross-border transfers of personal data.

18.8 Our Commitment

Luxury Watch Works shares personal data only where it is reasonably necessary, proportionate, and lawful.

We remain accountable for the protection of personal data processed on our behalf and continuously review our data sharing practices to ensure they remain aligned with our legal obligations, our business operations, and our commitment to protecting the privacy of our customers and stakeholders.

20. Data Retention

Luxury Watch Works retains personal data only for as long as it is reasonably necessary to fulfil the purposes for which it was collected and processed, to provide our services, comply with applicable legal and regulatory obligations, resolve disputes, establish or defend legal claims, maintain business records, and support the legitimate operation of our business.

When personal data is no longer required for these purposes, and where its retention is not required under applicable law, Luxury Watch Works will take reasonable steps to securely erase, anonymise, or otherwise dispose of such personal data in accordance with the Digital Personal Data Protection Act, 2023 ("DPDP Act"), applicable rules, and our internal data retention policies.

20.1 Retention Principles

Luxury Watch Works determines the appropriate retention period for personal data by considering factors including:

  • The purpose for which the personal data was collected;

  • The nature of the services provided;

  • The sensitivity of the personal data;

  • Applicable statutory, taxation, accounting, contractual, or regulatory requirements;

  • Warranty obligations;

  • Customer support requirements;

  • Potential legal claims or disputes;

  • Business continuity requirements; and

  • Other legitimate business needs permitted under applicable law.

20.2 Categories of Records

Depending on the nature of our relationship with you, we may retain records including:

  • Customer account and contact information;

  • Website enquiry records;

  • Service requests and correspondence;

  • Watch servicing and repair history;

  • Authentication, inspection, and valuation records;

  • Quotations and service estimates;

  • Invoices, payment records, and financial documentation;

  • Warranty records;

  • Email and WhatsApp communications;

  • Event registration records;

  • Customer feedback and complaint records;

  • Website security and system logs;

  • Analytics records (where applicable); and

  • Other records reasonably necessary for the operation of our business.

Each category of information is retained only for the period reasonably necessary for its intended purpose or as required by applicable law.

20.3 Secure Disposal

Where personal data is no longer required, Luxury Watch Works will take reasonable steps to ensure that such information is:

  • Securely deleted from active systems where appropriate;

  • Anonymised so that individuals can no longer be identified;

  • Securely destroyed where maintained in physical form; or

  • Otherwise disposed of using methods appropriate to the nature of the information and applicable legal requirements.

20.4 Suspension of Deletion

Luxury Watch Works may retain personal data beyond the ordinary retention period where reasonably necessary:

  • To comply with applicable legal or regulatory obligations;

  • To respond to lawful requests from competent authorities;

  • To establish, exercise, or defend legal claims;

  • To investigate fraud, security incidents, or unlawful activities;

  • To comply with court orders or legal proceedings; or

  • Where retention is otherwise required or permitted under applicable law.

Once the relevant legal or operational requirement no longer applies, the personal data will be securely erased, anonymised, or otherwise disposed of in accordance with our internal data retention procedures.

20.5 Periodic Review

Luxury Watch Works periodically reviews the personal data that it holds to ensure that information which is no longer reasonably necessary for the purposes for which it was collected is identified and appropriately managed.

As part of our privacy governance programme, we regularly review:

  • Categories of personal data retained;

  • Applicable retention periods;

  • Legal and regulatory requirements;

  • Business operational needs;

  • Secure deletion procedures; and

  • The effectiveness of our data lifecycle management practices.

20.6 Our Commitment

Luxury Watch Works is committed to responsible information lifecycle management.

We seek to ensure that personal data is retained only for legitimate and lawful purposes and is securely erased, anonymised, or otherwise disposed of when it is no longer required, while continuing to meet our obligations under the Digital Personal Data Protection Act, 2023 and other applicable laws.

21. Security Safeguards

Luxury Watch Works is committed to protecting the confidentiality, integrity, and availability of the personal data entrusted to us.

In accordance with the Digital Personal Data Protection Act, 2023 ("DPDP Act"), applicable rules, and recognised information security practices, we implement reasonable technical, organisational, administrative, and physical safeguards designed to protect personal data against unauthorised access, disclosure, alteration, misuse, accidental loss, destruction, or other unauthorised processing.

While no system of transmission or storage can be guaranteed to be completely secure, Luxury Watch Works continuously reviews and enhances its security practices to reduce risks and protect personal data throughout its lifecycle.

21.1 Information Security Programme

Luxury Watch Works maintains an information security programme designed to support the protection of personal data processed in connection with our business operations.

Our security programme includes measures appropriate to the nature, volume, sensitivity, and purpose of the personal data processed by us.

21.2 Administrative Safeguards (People & Process)

What it means

This section is about how employees handle customer information.

Every LWW employee should understand:

Customer Information

  • Collect only the information required to provide the service.

  • Never ask for unnecessary personal information.

  • Do not write customer information on loose papers unless absolutely necessary.

  • Keep service forms and customer records secure.

Access

  • Only access customer information if your job requires it.

  • Never browse customer records out of curiosity.

  • Do not share customer details with colleagues who are not involved in the service.

Confidentiality

Never discuss:

  • Customer names

  • Phone numbers

  • Watch values

  • Authentication reports

  • VIP/HNI customers

  • Celebrity clients

outside legitimate business purposes.

21.3 Technical Safeguards (Technology)

What it means

Employees should protect company systems and devices.

Rules

  • Use strong passwords.

  • Do not share passwords.

  • Enable Multi-Factor Authentication (MFA) wherever available.

  • Lock your computer when away from your desk.

  • Do not install unauthorised software.

  • Keep browsers and applications updated.

  • Report suspicious emails or links immediately.

  • Do not store customer data on personal devices unless specifically authorised.

21.4 Physical Safeguards (Office & Workshop)

What it means

Protect both physical documents and physical watches.

Employees should:

  • Keep customer forms in secure storage.

  • Do not leave customer files unattended.

  • Lock filing cabinets after use.

  • Do not allow visitors into restricted work areas without permission.

  • Secure laptops when leaving the office.

  • Shred documents before disposal where appropriate.

  • Return all documents to secure storage after use.

For Luxury Watch Works, physical security also includes:

  • Watches awaiting service

  • Authentication reports

  • Valuation reports

  • Collection receipts

  • Government ID copies (when collected)

These should not be left on desks or in publicly accessible areas.

21.5 Access Controls

Access to personal data is granted only to authorised employees, contractors, and authorised Data Processors who require such access for legitimate business purposes and in accordance with their assigned roles and responsibilities.

Luxury Watch Works follows the Principle of Least Privilege, ensuring that access is limited to the personal data reasonably necessary to perform authorised duties.

Access rights are periodically reviewed and are modified, suspended, or revoked whenever they are no longer required due to changes in responsibilities, employment status, or business requirements.

Employees are required to comply with Luxury Watch Works' internal access control and information security policies, including maintaining the confidentiality of authentication credentials, using only authorised accounts, protecting company systems from unauthorised access, and promptly reporting any actual or suspected security incidents.

Failure to comply with these access control requirements may result in appropriate disciplinary action in accordance with Company policies and applicable law.

 

21.6 Vendor Security

Where authorised Data Processors or third-party service providers process personal data on behalf of Luxury Watch Works, we seek to ensure that such providers implement appropriate security measures consistent with their services and applicable contractual obligations.

We periodically review our relationships with key service providers as part of our privacy and information security governance programme.

21.7 Monitoring and Incident Management

Luxury Watch Works maintains procedures for monitoring the security of our information systems and responding to actual or suspected security incidents.

Where appropriate, we investigate security events, take corrective actions, document significant incidents, and implement measures designed to reduce the likelihood of recurrence.

Where a personal data breach occurs, Luxury Watch Works will respond in accordance with applicable law, including any notification requirements prescribed under the DPDP Act or applicable rules.

21.8 Employee Responsibilities

Employee Responsibilities

This is the most important section because it defines every employee's obligations.

Every employee should understand that they must:

Protect Customer Information

Examples:

  • Don't share customer phone numbers.

  • Don't disclose customer email addresses.

  • Don't share service estimates without authorisation.

  • Don't reveal watch valuations.

  • Don't discuss HNI or celebrity customers outside work.

Follow Company Procedures

Employees should:

  • Follow the Privacy Policy.

  • Follow internal SOPs.

  • Use approved systems.

  • Follow collection and verification procedures.

  • Verify identity before releasing a watch.

Report Problems Immediately

Examples:

  • Lost laptop.

  • Lost customer documents.

  • Wrong email sent.

  • Wrong WhatsApp message.

  • Missing watch collection receipt.

  • Suspicious login.

  • Phishing email.

  • Customer data accidentally shared.

These incidents should be reported immediately to management so appropriate action can be taken.

Respect Customer Rights

If a customer asks to:

  • Access their data

  • Correct their data

  • Delete their data (where applicable)

  • Withdraw consent

  • Stop marketing communications

employees should not ignore the request. Instead, they should forward it to the designated person responsible for privacy matters.

21.9 Continuous Improvement

Information security is an ongoing process.

Luxury Watch Works reviews periodically and updates its security controls, operational procedures, technology infrastructure, and governance practices to address evolving business requirements, technological developments, regulatory expectations, and emerging cybersecurity risks.

21.10 Our Commitment

Luxury Watch Works recognises that protecting personal data is a continuous responsibility.

We remain committed to maintaining appropriate safeguards, promoting a culture of privacy and information security, and continually improving our practices to support compliance with the Digital Personal Data Protection Act, 2023 and other applicable laws.