Grade A Natural Jadeite · Jewellery · Bespoke Commissions

Effective Date: 1 July 2026 | Last Updated: 1 July 2026

🛡 Compliant with Singapore’s Personal Data Protection Act (PDPA) 2012
⚖️ Registered Dealer under the Precious Stones and Precious Metals (PSPM) Act 2019, Ministry of Law, Singapore

At The Masterpiece Collection, your privacy is treated with the same care and integrity as the
pieces we curate. This Privacy Policy explains how we collect, use, disclose, and safeguard
your personal data when you visit our website, make a purchase, or engage with us for bespoke
consultations. As a regulated dealer under the PSPM Act, certain data obligations are legally
mandated and are explained in full within this policy.

CONTENTS

01  Who We Are & Our Regulatory Status

02  Data We Collect

03  How We Collect Your Data

04  Legal Bases for Processing Your Data

05  How We Use Your Data

06  AML/CTF Compliance Obligations

07  Disclosure of Your Data

08  Cookies & Tracking Technologies

09  Data Retention

10  Data Security

11  Your Rights Under PDPA

12  Marketing Communications & Newsletter

13  Third-Party Links

14  Children’s Privacy

15  Changes to This Policy

16  Contact & Data Protection Officer

 

01  Who We Are & Our Regulatory Status

The Masterpiece Collection Pte. Ltd. (“The Masterpiece Collection”, “we”, “us”, or “our”) operates the website themasterpiececollection.com.sg, offering curated Grade A natural jadeite jewellery, beads, jadeite carvings, and bespoke commission services in Singapore.

For the purposes of the Personal Data Protection Act 2012 (No. 26 of 2012) (“PDPA”), The Masterpiece Collection Pte. Ltd. is the data controller responsible for your personal data collected through this website and our business operations.

 

IMPORTANT — REGULATED DEALER STATUS

The Masterpiece Collection Pte. Ltd. is an officially registered dealer under the Precious Stones and

Precious Metals (Prevention of Money Laundering and Terrorism Financing) Act 2019 (PSPM Act),

regulated by the Ministry of Law (MinLaw), Singapore.

 

As a regulated dealer, we are legally obligated to collect, verify, and retain certain customer

identification and due diligence data in connection with regulated transactions. This obligation

exists independently of and alongside our PDPA obligations, and customers cannot opt out of

data collection required for regulatory compliance purposes.

 

02  Data We Collect

We collect and process the following categories of personal data:

 

CATEGORY

EXAMPLES

Identity Data

Full name, NRIC/passport number or other government-issued ID (collected where required under the PSPM Act for transactions above the prescribed threshold)

Contact Data

Email address, phone number, mailing or delivery address

Transaction Data

Order history, items purchased, payment method type, billing details, transaction value

Account Data

Account login credentials, saved addresses, wishlist, purchase history

Bespoke & Consultation Data

Design preferences, jadeite specifications, and communication records related to bespoke commissions or professional consultations

AML/CTF Compliance Data

Customer due diligence information collected to comply with the Precious Stones and Precious Metals (PSPM) Act 2019, including identity documents and source of funds where applicable

NGI Certification Data

Details related to NGI (Natural Gemstone Institute) certification accompanying purchased pieces

Technical Data

IP address, browser type, device type, pages visited, session duration, referring URL

Marketing Data

Newsletter subscription status and preferences for receiving updates on new pieces and curated releases

Communications Data

Messages sent to us via email, contact forms, or during consultations

 

We do not collect or store financial account numbers, credit card details, or full payment card data. Payment transactions are processed by our secure third-party payment processor, which operates independently and under its own privacy and security obligations.

 

03  How We Collect Your Data

We collect your personal data through the following means:

  • Direct interactions: When you create an account, place an order, request a bespoke commission, book a professional consultation, subscribe to our newsletter, or contact us by email or in person.
  • In-person or appointment-based interactions: For professional consultations and bespoke commissions, additional data may be collected in person or via correspondence.
  • Regulatory interactions: For transactions that meet or exceed the prescribed threshold under the PSPM Act, we are legally required to conduct customer due diligence and collect identity verification documents.
  • Automated technologies: As you navigate our website, we automatically collect Technical Data via cookies, server logs, and similar tracking technologies.
  • Third parties: We may receive data from our payment processors, logistics providers, and analytics providers (e.g. Google Analytics) in connection with your orders and site interactions.

 

04  Legal Bases for Processing Your Data

We process your personal data on the following legal bases under the PDPA:

  • Consent: Where you have provided clear consent, such as subscribing to our newsletter or creating an account.
  • Contractual necessity: Where processing is necessary to fulfil your order, bespoke commission, or service agreement with us.
  • Legal obligation: Where we are required by law to collect and retain data, including obligations under the PSPM Act, the Income Tax Act, and other applicable Singapore legislation.
  • Legitimate interests: Where processing is necessary for our legitimate business interests, such as fraud prevention, site security, and improving our services, provided such interests are not overridden by your rights.

 

05  How We Use Your Data

We use your personal data only for lawful purposes, consistent with the PDPA’s purpose limitation principle. Specifically, we use your data to:

  • Process and fulfil your orders, including packaging, delivery, and enclosure of NGI certification documents
  • Create and manage your customer account
  • Communicate with you regarding your orders, returns, exchanges, and enquiries
  • Manage bespoke jadeite commissions and professional consultation appointments
  • Meet our legal obligations under the PSPM Act, including customer due diligence, record-keeping, and suspicious transaction reporting
  • Send marketing communications and curated updates where you have subscribed to our newsletter
  • Analyse and improve our website, product offerings, and customer experience
  • Comply with our legal, regulatory, and accounting obligations under Singapore law
  • Prevent fraud, unauthorised access, and illegal activities on our platform

 

06  AML/CTF Compliance Obligations

This section explains data collection that is required by law and is not subject to customer

consent or opt-out under the PDPA’s ‘required by law’ exception (Section 17, PDPA 2012).

 

As a regulated dealer under the Precious Stones and Precious Metals (Prevention of Money Laundering and Terrorism Financing) Act 2019 (PSPM Act), The Masterpiece Collection is subject to the following mandatory obligations:

Customer Due Diligence (CDD)

For cash transactions at or above SGD 20,000 (or its equivalent in foreign currency), or for non-cash transactions where required by our internal risk framework, we are obligated to collect and verify:

  • Full legal name
  • NRIC number, passport number, or other government-issued identification
  • Date of birth and nationality
  • Residential address
  • Source of funds, where required by our risk assessment

These requirements apply regardless of your preferences and cannot be waived. Failure to provide the required information may result in us being unable to complete your transaction.

Record-Keeping Obligations

Under the PSPM Act, we are required to retain customer due diligence records and transaction records for a minimum of 5 years from the date of the transaction or the end of the business relationship, whichever is later.

This retention obligation exists independently of and in addition to our general data retention practices under the PDPA. CDD records cannot be erased on request during the mandatory retention period.

Suspicious Transaction Reporting

Where required by law, we may be obligated to report suspicious transactions or activities to the relevant Singapore authorities, including the Suspicious Transaction Reporting Office (STRO). Such reporting may involve the disclosure of personal data without prior notification to the individual concerned, as permitted under the PDPA’s law enforcement exception.

Sanctions Screening

We may conduct sanctions screening of customers and transactions against applicable Singapore and international sanctions lists. This may involve processing your identity data through approved screening tools or services.

 

07  Disclosure of Your Data

We do not sell, rent, or trade your personal data. We may share your data with the following categories of recipients where necessary:

  • Logistics & delivery providers — to fulfil domestic and international shipping of your purchases
  • Payment processors — to securely process transactions on our behalf
  • IT & platform service providers — for WooCommerce, website hosting, CRM, and customer support infrastructure
  • Analytics providers — for aggregated, anonymised website performance insights (e.g. Google Analytics)
  • NGI and gemological certification bodies — where relevant to piece authentication and certification
  • MinLaw and other Singapore regulatory authorities — as required by the PSPM Act and applicable law
  • Law enforcement and government agencies — including STRO, for suspicious transaction reporting and other mandatory disclosures
  • Legal advisors or auditors — where necessary for legal proceedings, compliance, or internal audit

 

All third-party service providers engaged for operational purposes are required to handle your data consistently with the PDPA and to use it only for the purposes we specify.

 

08  Cookies & Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience and analyse site performance. Cookies are small text files stored on your device.

Types of Cookies We Use

  • Essential cookies: Required for core website functions including the shopping cart and account sessions. These cannot be disabled.
  • Analytics cookies: Help us understand visitor behaviour and optimise our website (e.g. Google Analytics). Data is anonymised and aggregated.
  • Marketing cookies: Used to measure the effectiveness of our campaigns and deliver relevant content.
  • Preference cookies: Remember your settings and browsing preferences for a better experience.

Managing Cookies

You may control or disable non-essential cookies through your browser settings. Disabling essential cookies may affect your ability to use features such as the shopping cart and account login. For further guidance, visit aboutcookies.org.

 

09  Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes described in this policy, subject to the following:

  • Order and transaction records: Minimum 5 years, for accounting, tax, and legal compliance purposes.
  • AML/CTF compliance data (CDD records and transaction records): Minimum 5 years from the date of the transaction or end of the business relationship, as required by the PSPM Act. This data cannot be erased on request during this mandatory period.
  • Account data: Retained for the duration of your active account and for a reasonable period after closure.
  • Bespoke commission and consultation records: Retained for the duration of the commission or service and for a minimum of 5 years thereafter, given the one-of-a-kind nature of our pieces.
  • Marketing / newsletter data: Retained until you unsubscribe or withdraw consent.
  • Technical and log data: Typically up to 12 months.

 

Data that is no longer required and not subject to mandatory retention will be securely deleted or anonymised.

 

10  Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These include:

  • SSL/TLS encryption for all data transmitted between your browser and our website
  • Secure, access-controlled hosting infrastructure for our WooCommerce platform
  • Physical and logical access controls for CDD and compliance records
  • Regular security assessments, software updates, and patch management
  • Access to personal data limited strictly to authorised personnel on a need-to-know basis

 

In the event of a personal data breach that is likely to result in significant harm to affected individuals, we will notify those individuals and the Personal Data Protection Commission (PDPC) in accordance with Singapore’s mandatory breach notification requirements under the PDPA.

 

11  Your Rights Under PDPA

Under Singapore’s Personal Data Protection Act 2012, you have the following rights in relation to your personal data:

 

Access

Request a copy of the personal data we hold about you.

Correction

Request correction of any inaccurate or incomplete personal data we hold.

Withdrawal of Consent

Withdraw consent to collection, use, or disclosure of your data at any time, subject to legal and contractual restrictions.

Data Portability

Request that we transmit your data to another organisation where technically feasible (PDPA Part VIA).

Erasure

Request deletion of your personal data where we no longer have a legitimate basis to retain it. Note: certain data must be retained to comply with MinLaw regulatory obligations and cannot be erased on request.

Complaints

Lodge a complaint with the Personal Data Protection Commission (PDPC) at pdpc.gov.sg.

 

To exercise any of your rights, please contact our Data Protection Officer at the details provided in Section 16. We will respond within 30 days. Identity verification may be required before we process your request.

Please note: certain data collected under our PSPM Act obligations cannot be erased or withheld, as its collection and retention is mandated by Singapore law. We will clearly explain any such limitation when responding to your request.

 

12  Marketing Communications & Newsletter

With your consent, we may send you occasional newsletter updates featuring new jadeite pieces, curated releases, editorial content, and events.

You can opt out at any time by:

  • Clicking the “unsubscribe” link in any newsletter email
  • Contacting us directly at sales@themasterpiececollection.com.sg

 

Withdrawing marketing consent will not affect your ability to receive transactional communications regarding your orders or bespoke commissions. We comply with Singapore’s Do Not Call (DNC) Registry provisions under the PDPA for any SMS or voice marketing communications.

 

13  Third-Party Links

Our website may link to third-party platforms including Instagram (@themasterpiececollectionsg) and other social media or partner sites. These operate under their own privacy policies and data practices. We are not responsible for the privacy or security practices of any third-party websites linked from our site.

 

14  Children’s Privacy

Our website and services are not directed at persons under 18 years of age. We do not knowingly collect personal data from minors. If you believe a child has submitted personal data to us without appropriate parental consent, please contact us immediately and we will take steps to delete it promptly.

 

15  Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our business practices, technology, or applicable laws. When material changes are made, we will update the “Last Updated” date at the top of this page and, where appropriate, notify you by email.

Your continued use of our website or engagement with our services after changes are posted constitutes acceptance of the updated policy.

 

16  Contact & Data Protection Officer

For all privacy-related queries, data access or correction requests, or to exercise your rights under the PDPA, please contact our Data Protection Officer:

 

Data Protection Officer

The Masterpiece Collection Pte. Ltd.

Singapore

Email: sales@themasterpiececollection.com.sg

Professional Consultation Hours: 11am – 6pm

Website: themasterpiececollection.com.sg/contact

We aim to respond to all data protection queries within 30 days.

Unresolved complaints may be escalated to the Personal Data Protection Commission (PDPC) at pdpc.gov.sg.

 

© 2026 The Masterpiece Collection Pte. Ltd. All rights reserved.     |     Grade A Natural Jadeite · Authenticated. Curated. Enduring.