Privacy Policy

1. Who we are

This website is operated by New Art Diamonds (Singapore) Pte Ltd (UEN 202006172M), trading as Ginza Diamond Shiraishi (“we”, “us”, “our”). Our registered address is 39 Keppel Road, #05-05 Tanjong Pagar Distripark, Singapore 089065.

We are a registered dealer in precious stones and precious metals, registration number PS20200001954.

We are committed to handling your personal data responsibly and in accordance with the Personal Data Protection Act 2012 of Singapore (the “PDPA”). This policy explains what personal data we collect, why we collect it, who we share it with, how long we keep it, and what rights you have.

This policy applies to our website at diamond-shiraishi.sg, to our appointment booking pages, and to personal data we collect at our boutiques in Singapore.

2. What personal data we collect

3. Why we collect and use your personal data

• To arrange, confirm, reschedule and remind you about appointments at our boutiques.
• To contact you by telephone or email to confirm that you are attending a booked appointment and to verify the details of your booking.
• To respond to enquiries you send us.
• To answer messages, comments and enquiries you send us through our social media accounts and through messaging applications.
• To complete your purchase, and to provide after sales service, repairs, resizing and warranty service, including our lifetime Craftman Support warranty.
• To serve you across a bridal purchase that commonly happens in two stages, an engagement ring and later a set of wedding rings, so that when you return to us we already hold the context of what you chose, which boutique you visited and who assisted you, and you do not have to begin again.
• To understand how our website is used, so that we can improve it.
• To measure how well our advertising works, and to show our advertising to people who have visited our website.
• To send you marketing about our products, services and events, where you have agreed to receive it.
• To verify your identity and keep records of that verification, where a transaction requires it by law.
• To meet our legal, accounting, tax and regulatory obligations, including our obligations as a registered dealer in precious stones and precious metals.

4. Our basis for collecting and using your personal data

Where you give us your personal data voluntarily, for example by booking an appointment or completing our enquiry form, and it is reasonable that you would do so for that purpose, we rely on your consent, including deemed consent under the PDPA.

Where we verify your identity for a transaction that reaches or exceeds SGD 20,000 in cash, we do not rely on your consent. We are a registered dealer under the Precious Stones and Precious Metals (Prevention of Money Laundering, Terrorism Financing and Proliferation Financing) Act 2019, registration number PS20200001954, and that Act requires us to carry out customer due diligence and to keep a record of it. The PDPA permits us to collect, use and disclose personal data without consent where another written law requires it. If you prefer not to provide identification, we will not be able to complete a transaction of that size.

Where we use website analytics and advertising technologies, we rely on deemed consent by notification, on the basis of the notice given in this policy, or on the legitimate interests exception in the PDPA. You may object to this at any time using the controls set out in section 8.

Where we send you marketing communications, we rely on your express consent, which you may withdraw at any time.

We do not require you to consent to marketing as a condition of booking an appointment, purchasing from us, or receiving warranty service.

5. Cookies and similar technologies

Our website, and the appointment booking pages you are taken to as part of booking, use cookies and similar technologies. We use them to:

• understand how visitors use our website, including which collections and boutiques attract interest;
• keep the booking process working correctly between our website and our booking platform;
• measure which advertising leads to a visit, an enquiry or a booking;
• show our own advertising to people who have previously visited our website.

When you move from our website to our booking pages, a technical identifier associated with your browser is passed between the two so that your visit is recognised as one visit rather than two. That identifier does not by itself contain your name or contact details. If you go on to book an appointment, it may be linked to the name and email address you provide.

Our website analytics has a Google feature called Google Signals enabled. Where you are signed in to a Google account and have allowed advertisement personalisation in your Google settings, this allows Google to associate your activity on our website with your Google account, so that we can see anonymised age, gender and interest information about our visitors as a group, and so that a visit made on one device can be recognised as the same person on another. You can turn this off for every website at once in your own Google account settings, through Ads Settings at adssettings.google.com.

You can control cookies through your browser settings, including refusing some or all of them. Doing so may affect the booking process but will not prevent you from browsing our website.

6. Session recording

We use Microsoft Clarity, a session recording and heatmap service, on our website. Microsoft Clarity records mouse movement, clicks, taps and scrolling, and reconstructs that activity so that we can see how our pages are actually used and improve them.

Microsoft Clarity is set to its Balanced masking mode. This means anything you type into a form field, and any dropdown selection, is masked before we are able to see it, and email addresses and numbers appearing on the page are masked automatically. Other text shown on the page is captured. We do not use session recordings to identify individual visitors by name, and access to recordings is limited to staff who need it to improve the website. Session data collected through Microsoft Clarity expires after 365 days.

Microsoft Clarity also reads and sets identifiers used by Microsoft Advertising. This means information about your visit may be used by Microsoft for advertising measurement as well as for improving our website.

We have also connected Microsoft Clarity to our Google Analytics and Google Ads accounts. This means a reference to your session recording can appear in our Google Analytics reporting, and details of the advertisement that brought you to our website can be shown alongside your session in Clarity.

Microsoft Clarity is provided by Microsoft, and the data it collects is processed on servers located outside Singapore.

7. Advertising and remarketing

We advertise our boutiques and collections online. As part of this:

• we track when a visit to our website or a click on one of our advertisements leads to an appointment booking or an enquiry;
• we use a cookie placed by Google to help match a click on one of our advertisements to a later visit or booking, including across our website and our booking pages;
• we may show you our own advertisements on other websites, apps and platforms based on the pages you have viewed on our website. This is known as remarketing;
• we advertise on Facebook and Instagram, both operated by Meta. Where we use Meta's advertising technologies on this website, we and Meta use cookies and similar technologies to measure how our advertising performs and to show you relevant advertising on Meta's platforms;
• we may also advertise on, and use the equivalent measurement technologies of, TikTok, Xiaohongshu (also known as RedNote), Lemon8, LinkedIn, X (formerly Twitter), YouTube, Reddit, Pinterest and Snapchat. Where we do, that platform may set or read identifiers in your browser or on your device in the same way as described above, and may use them to measure how our advertising performs and to show you our advertisements on its own services. We are not using all of these platforms today. They are named here so that you are told before we begin, rather than afterwards.

Where you give us your email address or contact number, we may in future share it with an advertising platform in an encrypted, irreversible form, so that we can measure which advertising led to an enquiry, a booking or a purchase. The platform does not receive your details in readable form, and does not use them to advertise other businesses to you. We will update this policy, and the date at the top of it, before we begin doing this.

Where a purchase is completed at one of our boutiques following a visit or booking linked to one of our advertisements, we may match that purchase back to the original click and report to the advertising platform that a sale occurred, without sharing what you bought or what you paid.

Social media pages and messaging channels

We maintain pages and accounts on social media platforms. Today those are Facebook and Instagram. We may open accounts on the other platforms named above.

If you send us a message, comment on a post, react to our content, or complete a form or a lead advertisement on one of those accounts, we collect what you send us, together with the public profile name or handle you send it from. We use it to answer you and to keep a record of the conversation, in the same way as an enquiry sent through our website.

We do not control what a platform itself collects about you when you use it, or how it uses that information. That is governed by that platform's own privacy policy and by the settings in your own account with it, and not by this policy. Where information about you reaches us through a platform, this policy governs what we do with it.

Where a platform gives us statistics about the people who follow or view our pages, we receive those as grouped figures about an audience and not as information about you individually.

If you contact us through WhatsApp or another messaging application, we collect your telephone number, the name shown on that account, and the content of your messages. Section 12 explains how we treat marketing sent through those channels, which is different from how we treat a message about your booking.

8. Your choices about advertising

You can control how your information is used for advertising:

• Google: manage your advertising settings at adssettings.google.com, or install the Google Analytics Opt-out Browser Add-on at tools.google.com/dlpage/gaoptout.
• Meta: manage your advertising preferences in the Accounts Centre on Facebook or Instagram.
• Other platforms: TikTok, Xiaohongshu, Lemon8, LinkedIn, X, YouTube, Reddit, Pinterest and Snapchat each provide advertising and personalisation settings inside your own account with that platform.
• Your browser: most browsers allow you to block or delete cookies in their privacy settings.
• Your mobile device: you can limit advertising tracking in your device settings.

Opting out does not stop you seeing advertising. It stops advertising being personalised based on your activity on our website.

9. Who we share your personal data with

We do not sell your personal data. We share it only with service providers who help us operate our business, and only to the extent they need it.

We may also disclose your personal data where we are required or permitted to do so by law, or where it is necessary to protect the life, health or safety of any individual.

10. Transfer of personal data outside Singapore

Several of the service providers listed above are based outside Singapore, and your personal data will be transferred to and processed in countries other than Singapore. In particular, appointment bookings are processed by Cal.com in the United States, and our website analytics and advertising data is processed by Google and by Microsoft on servers outside Singapore.

The social media and messaging platforms named in this policy are also based outside Singapore, and personal data they receive is processed outside Singapore. TikTok states that its service in this region is provided by TikTok Pte. Ltd., a company registered in Singapore, and that information may be stored on servers in Singapore, Malaysia, Ireland and the United States. Platforms operated from other countries, including those operated from China, process personal data in the countries in which they operate.

We do not upload your contact details to any advertising platform until we have satisfied ourselves that it is bound to a standard of protection comparable to that required under the PDPA, and we will update this policy and the date at the top of it before we begin doing so.

When we transfer your personal data outside Singapore, we take steps to ensure it continues to receive a standard of protection comparable to that required under the PDPA, including through contractual commitments with those providers. Our booking platform operates a data processing agreement which applies to it and to each of its own subprocessors. We do not otherwise transfer your personal data outside Singapore without your consent, unless the law permits or requires us to do so.

11. How long we keep your personal data

We keep your personal data only for as long as it is needed for the purpose for which it was collected, or for as long as we are required to keep it by law.

When personal data is no longer needed, we delete it or remove the information that identifies you.

12. Marketing communications and telephone contact

If you book an appointment with us, our boutique staff may telephone or email you to confirm that you are attending and to check the details of your booking. These are service communications about a booking you have made. They are not marketing.

We will only send you marketing by telephone, text message or email where you have agreed to receive it. You may withdraw that agreement at any time, by telling the boutique, by using the unsubscribe link in any marketing email, or by contacting our Data Protection Officer using the details in section 16.

Where we contact Singapore telephone numbers for marketing purposes, we do so in accordance with the Do Not Call provisions of the PDPA. This applies whether we telephone you, send you a text message, or send you a message through an application such as WhatsApp or Telegram that uses your telephone number to identify you. A marketing message sent through one of those applications is treated in exactly the same way as a marketing text message, and we either hold your consent or check the relevant register before sending it.

A message from us that only confirms, reschedules or reminds you about an appointment you have made is a service message about your booking, and it is not marketing. If we want to tell you about a promotion, a new collection or an event, we will send that as a separate message, and only if you have agreed to receive marketing from us.

13. How we protect your personal data

We put in place reasonable security arrangements to protect your personal data against unauthorised access, collection, use, disclosure, copying, modification or disposal. These include restricting access to customer records to staff who need it, using reputable service providers, and reviewing our arrangements from time to time.

No method of transmission or storage is completely secure. If a data breach occurs which is likely to result in significant harm to you, or which affects a significant number of individuals, we will notify the Personal Data Protection Commission and, where required, we will notify you, in accordance with the PDPA.

14. Your rights

Access and correction

You may ask us what personal data we hold about you, and how it has been used or disclosed by us in the year before your request. You may also ask us to correct any error or omission. Please write to our Data Protection Officer using the details in section 16. We will respond as soon as reasonably possible, and in any event within 30 days. If we cannot respond within that time, we will tell you when we will. In some circumstances permitted by law we may not be able to provide certain information or make certain corrections, and if so we will explain why. We may charge a reasonable fee for an access request, and we will tell you the amount before we proceed.

Withdrawing your consent

You may withdraw your consent to our collection, use or disclosure of your personal data at any time by writing to our Data Protection Officer. We will tell you what this means in practice. For example, we may no longer be able to confirm your appointment, send you reminders, or provide warranty service that depends on holding your record. Withdrawing consent does not affect anything we lawfully did before you withdrew it, and does not affect personal data we are required or permitted by law to keep. In particular, we cannot delete identity verification records for a qualifying transaction, or our accounting records, because the law requires us to keep them for the periods set out in section 11.

15. Complaints

If you have any concern about how we handle your personal data, please contact our Data Protection Officer first, using the details in section 16. We will look into it and respond to you.

If you are not satisfied with our response, you may lodge a complaint with the Personal Data Protection Commission of Singapore at www.pdpc.gov.sg.

16. How to contact us

Our Data Protection Officer is responsible for ensuring that we comply with this policy and with the PDPA.

17. Changes to this policy

We may update this policy from time to time. The date at the top of this page shows when it was last updated. Where a change materially affects how we use your personal data, we will take reasonable steps to bring it to your attention.