If you are directed to this Policy, it is because (1) you are a student of Wall Street English, or (2) you are considering becoming a student of Wall Street English and you are accessing our platform for a trial, to complete a placement test, or for similar reasons.
Purpose of the processing
The data you provide (Data) will be included in WSE Hong Kong Limited’s database for the purpose of (1) providing you access to our English Language Teaching resources; and (2) contacting you through the platform, by email, by telephone or in any other way, about your progress, performance and satisfaction with the services.
Why are we processing your Data?
As a Wall Street English student, you have entered into a contract with one of our partners that entitles you to have access to our resources and services. In turn, our contractual agreements with our partners oblige us to provide these resources and services to you. Thus, we are processing your Data in order to comply with the contractual arrangements in place.
As a potential Wall Street English student, you have accepted that we process your Data to provide you with the resources and services that you are using. In this case, we are processing your data based on your consent, which you can withdraw at any time.
Which Data are we processing?
The Wall Street English partner you have dealt with has provided us with the following data on you: Center, name, email address, registration date, expiration date, latest placement test score, Student ID. You may have provided us with additional data by completing the “Profile” section in the platform. Also, we store your replies to the exercises and quizzes, and the relevant scores; as well as the messages you posted in our social tools.
Who are we going to share your Data with?
Your Data may be accessed by our IT teams, to maintain the platform and troubleshoot, and by our product teams, to ensure a good learning experience. These teams are split in different Wall Street English group companies (see below*).
Your Data will also be shared with the WSE partner you have your relationship with, so that they can follow your progress and help you with your learning.
We use third-party providers to host the platform and to manage your access to digital books. Since these providers change from time to time, please contact us if you wish to know more about them.
Our retention policy
If you are a Wall Street English student, we will keep your Data for the time necessary to comply with the contract. After the contract ends, we will keep your Data to allow you access to those parts of the platform accessible to Wall Street English alumni until the earlier of (i) the date you tell us to cancel your Data and your access; and (ii) the date we reasonably think, in our own discretion, that you are not going to use our alumni services any more.
I you are a potential Wall Street English student, we will keep your Data until the earlier of (i) the date you withdraw your consent to us keeping this Data; and (ii) we reasonably think, in our own discretion, that you are not going to become a Wall Street English student.
Data Protection Officer
WSE Hong Kong Limited
Level 54, Hopewell Centre,
183 Queen's Road East,
- or email us at email@example.com
Special note to individuals in the EEA
Representative: In order to ensure compliance with the European Union General Data Protection Regulation (GDPR), note that you can contact our Data Protection Officer in our EU representative company, Franchise Support & Services, S.L., a Spanish company, Tax ID B60662533, with registered address at carrer Tuset 20-24 5º 3ª, Barcelona 08006, Spain.
Transfers outside the EEA: As stated above (see “Who are we going to share your Data with?”), we may transfer your Data outside of the EEA, to our group companies (see below*) and to our digital books provider (which is based in the EEA, but has a secondary platform in Singapore). We understand that this is necessary to manage the platform and that it does not impact on your interest and rights as data subject. We have ensured that all transfers of your Data outside of the EEA are subject to appropriate safeguards, by signing standard data protection clauses.
Your rights: The GDPR also requires that we list your statutory rights. These are the following:
a) Right to request access to and rectification or erasure of personal data.
b) Right to restriction of processing. This enables you to ask us to suspend the processing of your Data in the following scenarios: (a) if you want us to establish the Data's accuracy; (b) where our use of the Data is unlawful but you do not want us to erase it; (c) where you need us to hold the Data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your Data but we need to verify whether we have overriding legitimate grounds to use it.
c) Right to object to processing. Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
d) Right to data portability. We will provide you, or a third party you have chosen, with the personal data you have provided us with, in a structured, commonly used, machine-readable format.
e) Right to withdraw consent at any time (without affecting the lawfulness of processing based on consent before its withdrawal).
f) Right to obtain a copy of the documentation showing that we comply with GDPR when we transfer your personal information outside the EEA.
In order to exercise any of these rights, send an email to firstname.lastname@example.org or a letter to our EU representative postal address (Data Protection Officer, Franchise Support & Services, S.L., carrer Tuset 20-24 5º 3ª, Barcelona 08006, Spain).
Remember that, if you think that we have breached your data protection rights, you can file a complaint with the Spanish Data Protection Agency (www.agpd.es).
We last updated this policy on 15 June 2018
*Wall Street English group companies are Franchise Support & Services, S.L., a Spanish company, WSE Italy Srl, an Italian company, Wall Street English Training Centre (Guangdong) Co. Ltd., a Chinese company, Beijing Wall Street English Training Centre Co. Ltd., a Chinese company, Wall Street English Training Centre (Shanghai) Co. Ltd., a Chinese company, Gamma Master China, Limited, a Hong Kong SAR (PRC) company, and Wall Street English India Private Limited, an Indian company.