Personal Data and Privacy Policy

Privacy Policy

Wall Street English Hong Kong* endeavors to ensure that all our collection, transmission, storage and usage of personal data shall be carried out in compliance with the Personal Data (Privacy) Ordinance (Chapter 486 of the laws of Hong Kong) as amended from time to time. 

Scope of this Privacy Policy

If you are directed to this Policy, it is because you have contacted us and you want us to manage your request.

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) managing your request; 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 request, including asking you about how we have managed your request. Note that we may use mathematical and/or statistical procedures to decide if and how we contact you for these purposes.

Why are we processing your Data?

We are processing your Data because you have accepted that we process your Data to manage your request. So, 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 all or part of the following data on you: Full name, address, email address, telephone number, your request. Also, we will store the messages you and we exchange on your request.

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 service teams, to manage your request. 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 may transfer, disclose, grant access to, or share your personal data with banks, financial institutions, and credit card issuing companies in connection with the processing of payment instructions or the collection of outstanding amounts related to the provision of our services.

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 manage your request and for the duration of your contract with us, as historical data. After the contract ends, we will keep your Data only during the time we keep your user data to allow you to access to those parts of the platform accessible to Wall Street English alumni.

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: 

Email Address: marketing [at] wallstreet.edu.hk

Address: Unit 1906-10, 19/F, Prosperity Place, 6 Shing Yip Street, Kwun Tong, Kowloon, Hong Kong SAR

Attention: Marketing Department

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 may 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 [email protected] or a letter to our EU representative postal address (Data Protection Officer, Franchise Support & Services, S.L., carrer Tuset 20-24 5º Izda, 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 Hong Kong is Far East Management Limited (遠東管理有限公司), a company with limited liability incorporated under the Laws of Hong Kong, with business registration number 30558366 and registered office at Unit 1906-10, 19/F, Prosperity Place, 6 Shing Yip Street, Kwun Tong, Kowloon, Hong Kong SAR. 

**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.