privacy

Notice relating to the Personal Data (Privacy) Ordinance

Summary

Purpose

Providing you access to Wall Street English courses
Legal grounds for this processing

Performing a contract signed with you (if you are a student); your consent (if you are testing our courses); legitimate interest (if we record your online classes)
Data transfers

Your data will be shared with (i) Wall Street English companies, and (ii) our IT providers and teachers.
Origin of your Data

Yourself
Your rights

You retain your rights to access, modify and delete your personal data, together with other legal rights. Please check these rights in detail and how to exercise them below.

Full Privacy Policy

Scope of this Privacy Policy

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.

If you are a minor, you must not access the platform unless (i) you have appropriate parental consent, or (ii) you have entered into the corresponding contract.

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 (including SMS, Whatsapp, WeChat, and similar platforms), about your progress, performance and satisfaction with the services. Note that we may use mathematical and/or statistical procedures to decide if and how we contact you for these purposes.

We may record the online classes ("Recordings of Online Classes") for training purposes, quality control and for your and our staff's protection.

If you have consented to it (and only then), we intend to use the Data in direct marketing related to Wall Street English products and services, and products and services offered by our co-branding partners (the names of such co-branding partners will be provided during the application for the relevant products and services, as the case may be). Such services and products may be provided by us, by any of our group companies, by any of our franchisees and/or by any of our co-branding partners.

Why are we processing your Data?

If you are a Wall Street English student, you have entered into a contract us that entitles you to have access to our resources and services. Thus, we are processing your Data to comply with the contractual arrangements in place.

The Recordings of Online Classes are necessary to train our staff, control the quality of our services and protect you and our staff from harassment and similar unlawful acts. We ensure that these recordings are proportionate and therefore should not impact our staff's and our students' rights unfairly.

If you are 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?

You have provided us with the following data on you: Full name, address, email address, telephone number, registration date, purchase dates, payment details (we don’t process those, our payment providers do), last 4 numbers of the payment details. You may have provided us with additional data by completing the "Profile" section on the platform. Also, we store the messages you post on our social spaces.

In the case of Recordings of Online Classes, we may be processing your name, your image, your voice, and the fact that you are participating in such online class.

We may also use Cookies to make the platform work better for you. If this is the case, you will find the details of this processing in our Cookie Policy.

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 into different Wall Street English group companies (see below*).

We use third-party providers to host the platform and to manage your access. These include Microsoft (www.microsoft.com) and Shopify (www.shopify.com). We will also share your e-mail address with SurveySparrow (https://surveysparrow.com/) and Reviews.io (https://www.reviews.io/) for them to carry out satisfaction surveys on our behalf. If you are using our online teaching services, your Data will be shared with the corresponding teacher and, if applicable, with the company providing the teacher.

We are using a third-party provider to provide customer service support.

Please contact us if you wish to know more about our providers.

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 to 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.

Your Data collected through Recordings of Online Classes will be deleted as soon as the relevant purposes are achieved, and never later than six months after the class is recorded.

If 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) the date we reasonably think, in our own discretion, that you are not going to become a Wall Street English student, which shall not be later than 12 months after you last accessed the platform.

Data access rights

You have the right:

  1. To check whether we hold data about you and to access such data;
  2. To require us to correct any data relating to you which is inaccurate; and
  3. To ascertain our policies and practices in relation to data and to be informed of the kind of data held by us.

In accordance with the provisions of the Ordinance, we have the right to charge a reasonable fee for the processing of any data access request.

Nothing in this Privacy Notice shall limit your rights as a data subject under the Ordinance.

Contact details

If you have any questions about our Privacy Policy or you wish to exercise any of your statutory rights, do not hesitate to contact us at:

Data Protection Officer

WSE Hong Kong Limited

Rm. 2608, W50, 50 Wong Chuk Hang Road,

Hong Kong SAR

- or email us at privacy@wallstreetenglish.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 Izda, 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 the EEA to our group companies (see below*). Also, if you are using our online teaching services, your Data will be shared with the corresponding teacher and, where applicable, with the company providing the teacher, which may be outside the EEA as well.

We understand that these transfers are necessary to provide you with the service you purchased and that they don’t impact your interest and rights as data subject, since we have ensured that (i) all transfers of your Data outside the EEA are subject to appropriate safeguards, by signing standard data protection clauses; and (ii) the relevant IT environments are subject to adequate security measures.

Your rights: The GDPR also requires that we list your statutory rights. These rights are the following:

  1. Right to request access to and rectification or erasure of personal data.
  2. 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.
  3. 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 your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
  4. Right to data portability. We will provide you, or a third party you choose, with your Data, in a structured, commonly used, machine-readable format.
  5. Right to withdraw consent at any time (without affecting the lawfulness of the processing based on consent before its withdrawal).
  6. 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 privacy@wallstreetenglish.com 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 26 October 2023

*Wall Street English group companies are Franchise Support & Services, S.L., a Spanish company, WSE Italy Srl, an Italian company, and Wall Street English India Private Limited, an Indian company.