Last updated: 7 August 2018
If you are directed to this Policy, it is because you are considering to (1) install our Say Hello app, or (2) request that we transfer your data to the Wall Street English operator in your country to get free English services at centers near you, and learning advice and course information (“request to receive marketing notifications“).
Purpose of the processing
The data you provide (“Data”) will be included in WSE Hong Kong Limited’s database for the purpose of enabling you to access the app and engage with it in ways that support your English learning. If you requested to receive marketing notifications, we will transfer your Data to the Wall Street English operator in your country, as better explained below.
Why are we processing your Data?
We are processing your Data because you consented to it. Remember that you can withdraw your consent at any time.
Which Data are we processing?
- Contact details – email address, phone number
- English level
- Engagement with the app and messages related to the app
- Geolocation – only for those who have consented to geolocation permissions
Who are we going to share your Data with?
Your Data may be accessed by our IT teams, to maintain the app and troubleshoot, and by our marketing teams, to ensure a quality app experience and alert you to events or services in your area, to help you improve your English. These teams are split in different Wall Street English group companies (see below*).
We use third-party providers to host the app and to manage it. Since these providers change from time to time, please contact us if you wish to know more about them.
If you request to receive marketing notifications, we will share your Data with the Wall Street English operator in your country, which will be one of the following:
- Argentina: Education Group S.A., with registered address at Reconquista 617, Piso 1º, Buenos Aires, Argentina.
- Israel: W.S.I. Wall Street Israel Ltd., with registered address at 26 HaRokmim Street, Building B, 9th floor Holon.
- Italy: WSE Italy srl, with registered address at Viale Abruzzi, 94 – 20131 – Milan, Italia.
- Turkey: EKSEN Egitum Kurumlari A.S., with registered address at Büyükdere Caddesi, 15/A Sisli, Istanbul, Turkey.
Our retention policy
We will keep your Data during the time you have the app installed on your mobile phone. After uninstall or inactivity of six months, your Data will be kept for no longer than three years. Data is retained so that, in case of reinstallation of the app, we can provide a quality user experience, and to carry out analyses on app usage that help us improve the app experience and messaging related to English learning advice, events or services.
Data Protection Officer
Rm. 2608, W50
50 Wong Chuk Hang Road
– or email us at firstname.lastname@example.org
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 third party providers (which are based in the EEA, but have sub-contractors outside of the EEA). We understand that this is necessary to manage the app 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:
- Right to request access to and rectification or erasure of personal data.
- 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.
- 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 Data for direct marketing purposes.
- 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.
- Right to withdraw consent at any time (without affecting the lawfulness of processing based on consent before its withdrawal).
- 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 email@example.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).
*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.