Scope of this policy
If you are directed to this policy, it is because you wish to have access to Wall Street English training platform.
Purpose of the processing
Your email address (Data) will be included in WSE Hong Kong Limited’s database for the purpose of managing your access and use of Wall Street English training platform.
We will process your Data because you consented to it. You can withdraw your consent at any time, and we will delete your Data promptly.
Who are we going to share your Data with?
Your Data will be managed by our specialists and consultants, and will be shared with other Wall Street English group companies (see below*). These Wall Street English companies will have access to your Data with the exclusive purpose of managing your access and use of Wall Street English training platform.
Your Data may also be shared with your employer and your employer’s group of companies, if you are an employee of one of our franchisees.
Your data will be shared with LearnUpon Ltd and AWS, both Irish companies, which are the companies providing the IT infrastructure of the training platform.
Our retention policy
We will keep your Data until (i) you request us to cancel your access; or (ii) your employer request us to cancel your access; or (iii) we decide to cancel your data, in our absolute discretion; whichever occurs first.
Data Protection Officer
WSE Hong Kong Limited
Rm. 2608, W50
50 Wong Chuk Hang Road
– or email us at firstname.lastname@example.org
WSE Hong Kong Limited is a Hong Kong company, with registered number 2587136, and with registered address at WSE Hong Kong Limited, Rm. 2608, W50, 50 Wong Chuk Hang Road, Hong Kong.
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, we may transfer your Data outside of the EEA, to our group companies (see below*). We understand that this is necessary to ensure proper management of your access and use of Wall Street English training platform and that it does not impact on your interest and rights as data subject (legitimate interest).
We have ensured that all transfers of 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 to you, or a third party you have chosen, the personal data you have provided to us, 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, 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 27 March 2019
*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, and Wall Street English India Private Limited, an Indian company.