Notice relating to compliance with Information Technology Act 2020 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules 2011

Summary

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.

Purpose of the processing

The data you provide (Data) will be included in Wall Street English India Private 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

Wall Street English India Private Limited

Ground Floor, Block -7, DLF IT SEZ, 1/124 Shivaji Gardens, Nandambakkam,

Chennai - 600 089

- or email us at privacy@wallstreetenglish.com

We last updated this policy on 18 December 2023

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