Privacy Policy
Last updated: 10 June 2025
This policy describes how Cairnvale (operating from 81 Jalan Kuchai Lama, 58200 Kuala Lumpur, Malaysia) collects, uses, and protects personal data in connection with its clerical and archival services. It applies to data provided through this website and through direct contact with Cairnvale.
Cairnvale's services involve handling physical documents belonging to client families. The handling of those documents is governed by separate written handling agreements. This policy covers the personal data associated with enquiries, appointments, and ongoing service delivery.
1. Data we collect
We collect only what is necessary to provide the services requested. This includes:
- Contact data: name, email address, telephone number — collected when you submit an enquiry or complete an intake form.
- Project data: names of household members, document descriptions, notes from records sessions — collected only when a service engagement begins, under a signed handling agreement.
- Communication records: emails and notes from telephone calls relating to an active project.
- Website data: cookies and basic analytics if you have consented. See our Cookie Policy for details.
We do not collect financial account details, asset valuations, or government identity numbers except where these appear on the face of a document being indexed, in which case they are recorded only in the index description.
Legal basis for processing
Processing is carried out on the basis of: (a) performance of a contract, where you have engaged a Cairnvale service; (b) consent, where you have provided contact information to receive a response to an enquiry; and (c) legitimate interest, where we retain minimal records of completed engagements for quality and dispute-resolution purposes.
Retention
Enquiry data: retained for 12 months from last contact, then deleted. Project data: retained for 36 months from project completion, then deleted. Encrypted client document files: deleted immediately after confirmed handover to the family.
2. How we use personal data
- To respond to enquiries submitted through this website or by telephone
- To manage and carry out the clerical and archival services you have engaged
- To produce written outputs (next-steps sheets, indexes, annual reports) for the relevant family members
- To maintain a record of the handling agreement and project scope
- To comply with applicable Malaysian law, including the Personal Data Protection Act 2010
We do not use personal data for marketing communications without consent. We do not sell, rent, or trade personal data to any third party.
Third-party processors
We use a small number of third-party services for basic website operation: web hosting and basic analytics (if consented). Client document data is not stored on any third-party platform. All scanning and indexing is performed on local, encrypted hardware held at our office premises.
3. Data protection measures
- Client document files are stored in encrypted form on local hardware only during the active project period
- No cloud storage is used for client documents
- Physical access to document collections held at our office is restricted to project staff
- Digital files are deleted from Cairnvale's systems immediately after confirmed handover
- Staff handling personal data are bound by confidentiality obligations
In the event of a data breach affecting personal data, affected individuals will be notified without undue delay in accordance with the requirements of the Malaysian Personal Data Protection Act 2010 and any applicable regulations.
4. Cookies
This website uses cookies for basic functionality. Optional analytics and preference cookies are set only with your consent. You can manage your preferences at any time. See our Cookie Policy for the full list of cookies used and how to control them.
5. Your rights under the PDPA (Malaysia)
Under the Personal Data Protection Act 2010 (Malaysia), you have the following rights in respect of personal data we hold about you:
- Right of access: to request a copy of personal data we hold about you
- Right of correction: to request correction of inaccurate or incomplete data
- Right to withdraw consent: where processing is based on consent, you may withdraw it at any time. This does not affect data processed before withdrawal.
- Right to limit processing: to request that we stop using data for a specific purpose
- Right to complain: you may lodge a complaint with the Personal Data Protection Commissioner of Malaysia if you believe your data has been handled improperly
To exercise any of these rights, contact us at [email protected]. We will respond within 21 days.
6. Third-party links
This website may contain links to external websites, including the referral directory provided with records session outputs. Cairnvale is not responsible for the privacy practices of any external site. Visiting an external link is subject to that site's own policies.
7. Children's privacy
Cairnvale's services are intended for adults aged 18 and over who are managing matters on behalf of a family. We do not knowingly collect personal data from individuals under 18. If we become aware that we hold data from a minor, we will delete it promptly.
8. Policy updates
This policy may be updated to reflect changes in our services or applicable law. The date at the top of this page indicates when it was last revised. Continued use of this website following an update constitutes acceptance of the revised policy.
9. Contact for data matters
For questions about this policy or to exercise your data rights: