We last updated this policy on 7 August 2018
Scope of this policy
If you are directed to this policy, it is because you wish to find out more about learning English with us.
Purpose of the processing
The data you provide (Data) will be included in WSE Hong Kong Limited’s database for the purpose of contacting you to tell you more about learning English with us.
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*).
Your Data will also be shared with the WSE partner which is closest to the address you provided.
Our retention policy
We will keep your Data for 12 months from the date your consent is given.
Data Protection Officer
WSE Hong Kong Limited
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, we may transfer your Data outside of the EEA, to our group companies (see below*). We understand that this is necessary to manage your queries and that it does not impact on your interest and rights as data subject (legitimate interest). As said, we may also transfer your Data to franchisees outside of the EEA in the case you wish information about a non-EEA country. In these cases, we understand that you consent to it. Our franchisees are numerous and changing. We will do our best to inform you of their exact names, but do not hesitate to contact us if you wish for any clarification.
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 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, and Wall Street English India Private Limited, an Indian company.