WAILIAN EDUCATION GROUP
Data Processing Policy

1. INTRODUCTION
This Data Processing Policy sets out how WAILIAN EDUCATION GROUP (”we”, “our”, “us”, “the Company”) handle the
Personal Data of our customers.
This Data Processing Policy applies to all Personal Data we Process regardless of the media on which that data is stored
or whether it relates to past or present customers, clients or website users.
This Data Processing Policy applies to all Company Customers (”you”, “your”).
2. SCOPE
We recognise that the correct and lawful treatment of Personal Data will maintain confidence in the Company and will
provide for successful business operations. Protecting the confidentiality and integrity of Personal Data is a critical
responsibility that we take seriously at all times.
The DPO is responsible for overseeing this Data Processing Policy and, as applicable, developing Related Policies and
Privacy Policy. That post is held by Steven He, Walian Education Group, Aldwych House, 77-91 Aldwych, London WC2B
4CH.
Please contact the DPO with any questions about the operation of this Data Processing Policy or the GDPR or if you have
any concerns that this Data Processing Policy is not being or has not been followed.
3. PERSONAL DATA PROTECTION PRINCIPLES
We adhere to the principles relating to Processing of Personal Data set out in the GDPR which require Personal Data to
be:
(a) Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency).
(b) Collected only for specified, explicit and legitimate purposes (Purpose Limitation).
(c) Adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (Data
Minimisation).
(d) Accurate and where necessary kept up to date (Accuracy).
(e) Not kept in a form which permits identification of Customers for longer than is necessary for the purposes for which
the data is Processed (Storage Limitation).
(f) Processed in a manner that ensures its security using appropriate technical and organisational measures to protect
against unauthorised or unlawful Processing and against accidental loss, destruction or damage (Security, Integrity and
Confidentiality).
(g) Not transferred to another country without appropriate safeguards being in place (Transfer Limitation).
(h) Made available to Customers and Customers are allowed to exercise certain rights in relation to their Personal Data
(Customers Rights and Requests).
We are responsible for and must be able to demonstrate compliance with the data protection principles listed above
(Accountability).
4. LAWFULNESS, FAIRNESS, TRANSPARENCY
4.1 LAWFULNESS AND FAIRNESS
Personal data must be Processed lawfully, fairly and in a transparent manner in relation to the Customer.
We will only collect, Process and share Personal Data fairly and lawfully and for specified purposes. The GDPR restricts
our actions regarding Personal Data to specified lawful purposes. These restrictions are not intended to prevent
Processing, but ensure that we Process Personal Data fairly and without adversely affecting the Customer.
The GDPR allows Processing for specific purposes, some of which are set out below:
(a) the Customer has given his or her Consent;
(b) the Processing is necessary for the performance of a contract with the Customer;
(c) to meet our legal compliance obligations;
(d) to protect the Customer’s vital interests;
(e) to pursue our legitimate interests for purposes where they are not overridden because the Processing prejudices the
interests or fundamental rights and freedoms of Customers. The purposes for which we process Personal Data for
legitimate interests need to be set out in applicable Privacy Notices.
4.2 CONSENT
Our Controllers will only process Personal Data on the basis of one or more of the lawful bases set out in the GDPR,
which include Consent.
A Customer consents to Processing of their Personal Data if they indicate agreement clearly either by a statement or
positive action to the Processing. Consent requires affirmative action so silence, pre-ticked boxes or inactivity are unlikely
to be sufficient. If Consent is given in a document which deals with other matters, then the Consent must be kept separate
from those other matters.

WAILIAN EDUCATION GROUP DATA PROCESSING POLICY – DEC 2019
Customers are easily able to withdraw Consent to Processing at any time and withdrawal will be promptly honoured.
Consent may need to be refreshed if we intend to Process Personal Data for a different and incompatible purpose which
was not disclosed when the you first consented.
Unless we can rely on another legal basis of Processing, Explicit Consent is usually required for Processing Special
Categories of Personal Data and Criminal Convictions Data, for Automated Decision-Making and for cross border data
transfers. Usually we will be relying on another legal basis (and not require Explicit Consent) to Process most types of
Special Categories of Personal Data and Criminal Convictions Data. Where Explicit Consent is required, we will issue a
Privacy Notice to you to capture Explicit Consent.
We will need to evidence Consent captured and will keep records of all Consents in accordance with Related Policies and
Privacy Guidelines so that the Company can demonstrate compliance with Consent requirements.
4.3 TRANSPARENCY (NOTIFYING YOU)
The GDPR requires Data Controllers to provide detailed, specific information to you depending on whether the
information was collected directly from you or from elsewhere. Such information must be provided through appropriate
Privacy Notices which must be concise, transparent, intelligible, easily accessible, and in clear and plain language so that
you can easily understand them.
Whenever we collect Personal Data directly from you, we must provide you with all the information required by the
GDPR including the identity of the Controller and DPO, how and why we will use, Process, disclose, protect and retain that
Personal Data through a Privacy Notice which must be presented when the Customer first provides the Personal Data.
When Personal Data is collected indirectly (for example, from a third party or publicly available source), we will provide
you with all the information required by the GDPR as soon as possible after collecting/receiving the data. We will also
check that the Personal Data was collected by the third party in accordance with the GDPR and on a basis which
contemplates our proposed Processing of that Personal Data.
5. PURPOSE LIMITATION
Personal Data will be collected only for specified, explicit and legitimate purposes. It will not be further Processed in any
manner incompatible with those purposes.
We cannot use Personal Data for new, different or incompatible purposes from that disclosed when it was first obtained
unless we have informed you of the new purposes and you have Consented where necessary.
6. DATA MINIMISATION
Personal Data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is
Processed.
We may only Process Personal Data when performing our job duties requires it. We cannot Process Personal Data for
any reason unrelated to our job duties.
We may only collect Personal Data that we require for our job duties: do not collect excessive data. We ensure any
Personal Data collected is adequate and relevant for the intended purposes.
We will ensure that when Personal Data is no longer needed for specified purposes, it is deleted or anonymised in
accordance with the Company’s data retention guidelines.
7. ACCURACY
Personal Data must be accurate and, where necessary, kept up to date. It must be corrected or deleted without delay
when inaccurate.
We will ensure that the Personal Data we use and hold is accurate, complete, kept up to date and relevant to the
purpose for which we collected it. We will check the accuracy of any Personal Data at the point of collection and at regular
intervals afterwards. We will take all reasonable steps to destroy or amend inaccurate or out-of-date Personal Data.
8. STORAGE LIMITATION
Personal Data will not be kept in an identifiable form for longer than is necessary for the purposes for which the data is
processed.
We will not keep Personal Data in a form which permits the identification of you for longer than needed for the
legitimate business purpose or purposes for which we originally collected it including for the purpose of satisfying any
legal, accounting or reporting requirements.
The Company will maintain retention policies and procedures to ensure Personal Data is deleted after a reasonable time
for the purposes for which it was being held, unless a law requires such data to be kept for a minimum time.
We will take all reasonable steps to destroy or erase from our systems all Personal Data that we no longer require in
accordance with all the Company’s applicable records retention schedules and policies. This includes requiring third parties
to delete such data where applicable.
We will ensure that you are informed of the period for which data is stored and how that period is determined in any
applicable Privacy Notice.
9. SECURITY INTEGRITY AND CONFIDENTIALITY
9.1 PROTECTING PERSONAL DATA
Personal Data will be secured by appropriate technical and organisational measures against unauthorised or unlawful
Processing, and against accidental loss, destruction or damage.

WAILIAN EDUCATION GROUP DATA PROCESSING POLICY – DEC 2019
We will develop, implement and maintain safeguards appropriate to our size, scope and business, our available
resources, the amount of Personal Data that we own or maintain on behalf of others and identified risks (including use of
encryption and Pseudonymisation where applicable). We will regularly evaluate and test the effectiveness of those
safeguards to ensure security of our Processing of Personal Data. We are responsible for protecting the Personal Data we
hold. We will implement reasonable and appropriate security measures against unlawful or unauthorised Processing of
Personal Data and against the accidental loss of, or damage to, Personal Data. We will exercise particular care in protecting
Special Categories of Personal Criminal Convictions Data from loss and unauthorised access, use or disclosure.
We will follow all procedures and technologies we put in place to maintain the security of all Personal Data from the
point of collection to the point of destruction. We may only transfer Personal Data to third-party service providers who
agree to comply with the required policies and procedures and who agree to put adequate measures in place, as
requested.
We will maintain data security by protecting the confidentiality, integrity and availability of the Personal Data, defined as
follows:
(a) Confidentiality means that only people who have a need to know and are authorised to use the Personal Data can
access it.
(b) Integrity means that Personal Data is accurate and suitable for the purpose for which it is processed.
(c) Availability means that authorised users are able to access the Personal Data when they need it for authorised
purposes.
9.2 REPORTING A PERSONAL DATA BREACH
The GDPR requires Controllers to notify any Personal Data Breach to the applicable regulator and, in certain instances,
the Customer.
We have put in place procedures to deal with any suspected Personal Data Breach and will notify you or any applicable
regulator where we are legally required to do so.
10. TRANSFER LIMITATION
The GDPR restricts data transfers to countries outside the EEA in order to ensure that the level of data protection
afforded to individuals by the GDPR is not undermined. We transfer Personal Data originating in one country across
borders when we transmit, send, view or access that data in or to a different country.
We may only transfer Personal Data outside the EEA if one or more of the following conditions applies:
(a) the European Commission has issued a decision confirming that the country to which we transfer the Personal Data
ensures an adequate level of protection for the Customers’ rights and freedoms;
(b) appropriate safeguards are in place such as binding corporate rules (BCR), standard contractual clauses approved by
the European Commission, a data sharing agreement that ensures that both parties adhere to the GDPR standards and
principles, an approved code of conduct or a certification mechanism, a copy of which can be obtained from the DPO;
(c) the Customer has provided Explicit Consent to the proposed transfer after being informed of any potential risks; or
(d) the transfer is necessary for one of the other reasons set out in the GDPR including the performance of a contract
between us and the Customer, reasons of public interest, to establish, exercise or defend legal claims or to protect the vital
interests of the Customer where the Customer is physically or legally incapable of giving Consent and, in some limited
cases, for our legitimate interest.
11. YOUR RIGHTS AND REQUESTS
You have rights when it comes to how we handle your Personal Data. These include rights to:
(a) withdraw Consent to Processing at any time;
(b) receive certain information about the Data Controller’s Processing activities;
(c) request access to your Personal Data that we hold;
(d) prevent our use of your Personal Data for direct marketing purposes;
(e) ask us to erase Personal Data if it is no longer necessary in relation to the purposes for which it was collected or
Processed or to rectify inaccurate data or to complete incomplete data;
(f) restrict Processing in specific circumstances;
(g) challenge Processing which has been justified on the basis of our legitimate interests or in the public interest;
(h) request a copy of an agreement under which Personal Data is transferred outside of the EEA;
(i) object to decisions based solely on Automated Processing, including profiling (ADM);
(j) prevent Processing that is likely to cause damage or distress to the Customer or anyone else;
(k) be notified of a Personal Data Breach which is likely to result in high risk to their rights and freedoms;
(l) make a complaint to the supervisory authority; and
(m) in limited circumstances, receive or ask for their Personal Data to be transferred to a third party in a structured,
commonly used and machine-readable format.
We will verify the identity of an individual requesting data under any of the rights listed above (do not allow third parties
to persuade us into disclosing Personal Data without proper authorisation).
12. ACCOUNTABILITY
12.1 The Controller will implement appropriate technical and organisational measures in an effective manner, to ensure
compliance with data protection principles. The Controller is responsible for, and must be able to demonstrate, compliance
with the data protection principles.

WAILIAN EDUCATION GROUP DATA PROCESSING POLICY – DEC 2019
The Company must have adequate resources and controls in place to ensure and to document GDPR compliance
including:
(a) appointing a suitably qualified DPO (where necessary) and an executive accountable for data privacy;
(b) implementing Privacy by Design when Processing Personal Data and completing DPIAs where Processing presents a
high risk to rights and freedoms of Customers;
(c) integrating data protection into internal documents including this Data Processing Policy, Related Policies, Privacy
Guidelines or Privacy Notices;
(d) regularly training Company Personnel on the GDPR, this Data Processing Policy, Related Policies and Privacy Guidelines
and data protection matters including, for example, Customer’s rights, Consent, legal basis, DPIA and Personal Data
Breaches. The Company must maintain a record of training attendance by Company Personnel; and
(e) regularly testing the privacy measures implemented and conducting periodic reviews and audits to assess compliance,
including using results of testing to demonstrate compliance improvement effort.
12.2 RECORD KEEPING
The GDPR requires us to keep full and accurate records of all our data Processing activities.
We will keep and maintain accurate corporate records reflecting our Processing including records of Customers’
Consents and procedures for obtaining Consents.
These records should include, at a minimum, the name and contact details of the Controller and the DPO, clear
descriptions of the Personal Data types, Customer types, Processing activities, Processing purposes, third-party recipients
of the Personal Data, Personal Data storage locations, Personal Data transfers, the Personal Data’s retention period and a
description of the security measures in place. In order to create such records, data maps should be created which should
include the detail set out above together with appropriate data flows.
12.3 TRAINING AND AUDIT
We are required to ensure all Company Personnel have undergone adequate training to enable them to comply with
data privacy laws. We must also regularly test our systems and processes to assess compliance.
We will undergo all mandatory data privacy related training and ensure our team undergo similar mandatory training.
We will regularly review all the systems and processes under your control to ensure they comply with this Data
Processing Policy and check that adequate governance controls and resources are in place to ensure proper use and
protection of Personal Data.
12.4 PRIVACY BY DESIGN AND DATA PROTECTION IMPACT ASSESSMENT (DPIA)
We are required to implement Privacy by Design measures when Processing Personal Data by implementing appropriate
technical and organisational measures (like Pseudonymisation) in an effective manner, to ensure compliance with data
privacy principles.
We will assess what Privacy by Design measures can be implemented on all programs/systems/processes that Process
Personal Data by taking into account the following:
(a) the state of the art;
(b) the cost of implementation;
(c) the nature, scope, context and purposes of Processing; and
(d) the risks of varying likelihood and severity for rights and freedoms of Customers posed by the Processing.
Data controllers must also conduct DPIAs in respect to high risk Processing.
We will conduct a DPIA (and discuss our findings with the DPO) when implementing major system or business change
programs involving the Processing of Personal Data including:
(e) use of new technologies (programs, systems or processes), or changing technologies (programs, systems or processes);
(f) Automated Processing including profiling and ADM;
(g) large scale Processing of Special Categories of Personal Data or Criminal Convictions Data Data; and
(h) large scale, systematic monitoring of a publicly accessible area.
A DPIA must include:
(i) a description of the Processing, its purposes and the Data Controller’s legitimate interests if appropriate;
(j) an assessment of the necessity and proportionality of the Processing in relation to its purpose;
(k) an assessment of the risk to individuals; and
(l) the risk mitigation measures in place and demonstration of compliance.
12.5 AUTOMATED PROCESSING (INCLUDING PROFILING) AND AUTOMATED DECISION-MAKING
Generally, ADM is prohibited when a decision has a legal or similar significant effect on an individual unless:
(a) a Customer has Explicitly Consented;
(b) the Processing is authorised by law; or
(c) the Processing is necessary for the performance of or entering into a contract.
If certain types of Special Categories of Personal Data or Criminal Convictions Data are being processed, then grounds (b)
or (c) will not be allowed but such Special Categories of Personal Data and Criminal Convictions Data can be Processed
where it is necessary (unless less intrusive means can be used) for substantial public interest like fraud prevention.
If a decision is to be based solely on Automated Processing (including profiling), then Customers must be informed when
we first communicate with them of their right to object. This right must be explicitly brought to their attention and
presented clearly and separately from other information. Further, suitable measures must be put in place to safeguard the
Customer’s rights and freedoms and legitimate interests.

WAILIAN EDUCATION GROUP DATA PROCESSING POLICY – DEC 2019
We must also inform you of the logic involved in the decision making or profiling, the significance and envisaged
consequences and give you the right to request human intervention, express their point of view or challenge the decision.
A DPIA must be carried out before any Automated Processing (including profiling) or ADM activities are undertaken.
12.6 DIRECT MARKETING
We are subject to certain rules and privacy laws when marketing to our customers.
For example, a Customer’s prior consent is required for electronic direct marketing (for example, by email, text or
automated calls). The limited exception for existing customers known as “soft opt in” allows organisations to send
marketing texts or emails if they have obtained contact details in the course of a sale to that person, they are marketing
similar products or services, and they gave the person an opportunity to opt out of marketing when first collecting the
details and in every subsequent message.
The right to object to direct marketing must be explicitly offered to the Customer in an intelligible manner so that it is
clearly distinguishable from other information.
A Customer’s objection to direct marketing must be promptly honoured. If a customer opts out at any time, their details
should be suppressed as soon as possible. Suppression involves retaining just enough information to ensure that marketing
preferences are respected in the future.
12.7 SHARING PERSONAL DATA
Generally we are not allowed to share Personal Data with third parties unless certain safeguards and contractual
arrangements have been put in place.
We may only share the Personal Data we hold with another employee, agent or representative of our group (which
includes our subsidiaries and our ultimate holding company along with its subsidiaries) if the recipient has a job-related
need to know the information and the transfer complies with any applicable cross-border transfer restrictions.
We may only share the Personal Data we hold with third parties, such as our service providers if:
(a) they have a need to know the information for the purposes of providing the contracted services;
(b) sharing the Personal Data complies with the Privacy Notice provided to the Customer and, if required, the Customer’s
Consent has been obtained;
(c) the third party has agreed to comply with the required data security standards, policies and procedures and put
adequate security measures in place;
(d) the transfer complies with any applicable cross border transfer restrictions; and
(e) a fully executed written contract that contains GDPR approved third party clauses has been obtained.
13. CHANGES TO THIS DATA PROCESSING POLICY
We reserve the right to change this Data Processing Policy at any time so please check back regularly to obtain the latest
copy of this Data Processing Policy. We last revised this Data Processing Policy on 24th May 2018.
This Data Processing Policy does not override any applicable national data privacy laws and regulations in countries
where the Company operates.
DEFINITIONS:
Automated Decision-Making (ADM): when a decision is made which is based solely on Automated Processing (including

profiling) which produces legal effects or significantly affects an individual. The GDPR prohibits Automated Decision-
Making (unless certain conditions are met) but not Automated Processing.

Automated Processing: any form of automated processing of Personal Data consisting of the use of Personal Data to
evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that
individual’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour,
location or movements. Profiling is an example of Automated Processing.
Company name: WAILIAN EDUCATION GROUP.
Company Personnel: all employees, workers contractors, agency workers, consultants, directors, members and others.
Consent: agreement which must be freely given, specific, informed and be an unambiguous indication of the Customer’s
wishes by which they, by a statement or by a clear positive action, signifies agreement to the Processing of Personal Data
relating to them.
Controller: the person or organisation that determines when, why and how to process Personal Data. It is responsible for
establishing practices and policies in line with the GDPR. We are the Controller of all Personal Data relating to our
Company Personnel and Personal Data used in our business for our own commercial purposes.
Criminal Convictions Data: means personal data relating to criminal convictions and offences.
Customer: a living, identified or identifiable individual about whom we hold Personal Data. Customers may be nationals or
residents of any country and may have legal rights regarding their Personal Data.
Data Privacy Impact Assessment (DPIA): tools and assessments used to identify and reduce risks of a data processing
activity. DPIA can be carried out as part of Privacy by Design and should be conducted for all major system or business
change programs involving the Processing of Personal Data.
Data Protection Officer (DPO): the person required to be appointed in specific circumstances under the GDPR. Where a
mandatory DPO has not been appointed, this term means a data protection manager or other voluntary appointment of a
DPO or refers to the Company data privacy team with responsibility for data protection compliance.
EEA: the 28 countries in the EU, and Iceland, Liechtenstein and Norway.
Explicit Consent: consent which requires a very clear and specific statement (that is, not just action).

WAILIAN EDUCATION GROUP DATA PROCESSING POLICY – DEC 2019
General Data Protection Regulation (GDPR): the General Data Protection Regulation ((EU) 2016/679). Personal Data is
subject to the legal safeguards specified in the GDPR.
Personal Data: any information identifying a Customer or information relating to a Customer that we can identify (directly
or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. Personal
Data includes Special Categories of Personal Data and Pseudonymised Personal Data but excludes anonymous data or data
that has had the identity of an individual permanently removed. Personal data can be factual (for example, a name, email
address, location or date of birth) or an opinion about that person’s actions or behaviour.
Personal Data Breach: any act or omission that compromises the security, confidentiality, integrity or availability of
Personal Data or the physical, technical, administrative or organisational safeguards that we or our third-party service
providers put in place to protect it. The loss, or unauthorised access, disclosure or acquisition, of Personal Data is a
Personal Data Breach.
Privacy by Design: implementing appropriate technical and organisational measures in an effective manner to ensure
compliance with the GDPR.
Privacy Policy: the Company privacy/GDPR related policy provided to assist in interpreting and implementing this Data
Processing Policy and Related Policies, available at our website
Privacy Notices (also referred to as Fair Processing Notices) or Privacy Policies: separate notices setting out information
that may be provided to Customers when the Company collects information about them. These notices may take the form
of general privacy statements applicable to a specific group of individuals (for example, employee privacy notices or the
website privacy policy) or they may be stand-alone, one time privacy statements covering Processing related to a specific
purpose.
Processing or Process: any activity that involves the use of Personal Data. It includes obtaining, recording or holding the
data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using,
disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties.
Pseudonymisation or Pseudonymised: replacing information that directly or indirectly identifies an individual with one or
more artificial identifiers or pseudonyms so that the person, to whom the data relates, cannot be identified without the
use of additional information which is meant to be kept separately and secure.
Related Policies: the Company’s policies, operating procedures or processes related to this Data Processing Policy and
designed to protect Personal Data.
Special Categories of Personal Data: information revealing racial or ethnic origin, political opinions, religious or similar
beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic
data.

WAILIAN EDUCATION GROUP
GLOBAL PRIVACY AND DATA PROCESSING POLICY

WAILIAN EDUCATION GROUP is committed to protecting the privacy and security of your personal information. The information that you share with us helps us to provide you with the best experience with our services. We have a dedicated Global Privacy program that protects all of the personal information we collect and helps ensure that the personal information is handled properly worldwide.

This Policy Notice explains the privacy practices of WAILIAN EDUCATION GROUP, including our management of and co- operation with third parties who provide us data collection and storage services. Please read the policy notice to understand exactly how we will look after your personal information and please contact us if you require any further information.

Date Effective:

This policy notice was most recently issued on 1st December 2019 and is effective immediately.

1. Data Protection Law
The EU General Data Protection Regulation 2016/679 (GDPR) and the Data Protection Act 2018 (which supplements the

GDPR) came into force on 25 May 2018. We refer to these as “data protection law”.

Data protection law regulates the processing of “personal data” relating to individuals by organisations (known as “data controllers”).

2. Key definitions
On this page, and the pages which it links to, we have used some words and phrases, and these are explained below.

“Personal data” means any information which relates to a living, identifiable person. It can include names, addresses, telephone numbers, email addresses etc but it is wider than that and includes any other information relating to that person or a combination of information which, if put together, means that the person can be identified.

“Special category data” means personal data about a person’s race, ethnic origin, politics, religion, trade union membership, genetics, biometrics (where used for ID purposes), health, sex life or sexual orientation.

“Processing” covers all activities relating to the use of personal data by an organisation, from its collection through to its storage and disposal and everything in between.

“Data subject” means the person whose personal data is being processed.

“Data controller” means the organisation which is responsible for processing data and ensuring that personal data is processed in accordance with data protection law.

3. Privacy notices

Personal data must be processed in accordance with specific principles set out in Data Protection Law. These include the principle that personal data should be processed ‘lawfully, fairly and in a transparent manner’. In order to comply with this principle, WAILIAN EDUCATION GROUP will advise you on how it will process your information at the time we collect it. This information is normally set out in a “privacy notice” which we publish on our website.

WAILIAN GROUP GLOBAL PRIVACY POLICY - DEC 2019

4. WAILIAN EDUCATION GROUP as data controller
WAILIAN EDUCATION GROUP is the data controller for any personal data that we process in relation to you.

Occasionally, WAILIAN EDUCATION GROUP may be a joint data controller with other organisations, or we may be processing data about you on behalf of another organisation, but when this is the case, we will make you aware of this when the information is collected. Similarly we may be provided with your personal information by third parties. In these cases, we have data sharing agreements in place with those third parties which ensure that your private data is processed in the same way by all parties, wherever they may be in the World.

5. What personal data will be processed?

Any personal details provided to us at the point of enquiry or reservation, or that are provided to us by those parties we share data with, are stored in our database, along with any subsequent relevant data provided to us at a later stage during the reservation process or during your attendance at any of our events.

Information is gathered through our web-based enquiry forms, during telephone or face to face communications with us, and by email or post. Additionally, we exchange information with our partners within the Wailian Group. These partners may be outside the European Economic Area. We will always ensure that data exchanged with our partners is subject to both parties entering into a Data Sharing Agreement that requires both parties to meet or exceed the requirements of GDPR wherever the party is located.

Personal data collected may include: your name, home address, business address (if booking on behalf of an organisation), a contact telephone number (landline and mobile where possible), email address, or any other personal information that you disclose to us at the point of your enquiry, reservation or during your attendance at any of our events.

In addition to this, we may need to process some data about you that is classed as ‘special category’ or sensitive personal data. We will usually ask you for consent to do this. This includes any relevant health and disability information you provide us. We will make sure that access to, and the sharing of, your special category personal data is controlled very carefully.

Cookies are collected on the website to improve your experience. 6. What is the purpose of the processing?

WAILIAN EDUCATION GROUP will process your personal data for a range of purposes. These include the following:

  • To deliver services and facilities to you.

  • To administer any billing information.

  • To support your medical, safety, wellbeing and welfare requirements.

  • To communicate with you by post, phone, email or other electronic media, in order to provide you with relevant

    information and updates relating to your transactions with WAILIAN EDUCATION GROUP.

  • To enable us to contact others in the event of an emergency (we will assume that you have checked with

    individuals before you supply their contact details to us).

  • To fulfil and monitor our responsibilities under equalities, immigration and public safety legislation.

  • To provide post-immigration support to you where relevant.

  • With your consent, to communicate with you for marketing and promotional purposes.

  • To compile statistics for reporting purposes.

7. What is the legal basis of the processing?

If we require your consent for any use of your specific data, we will collect it at the appropriate time, explaining why we are collecting the data and how we will use it, and you can withdraw this consent at any time. In other cases, we consider the processing of your personal data for these purposes to be necessary for:

WAILIAN GROUP GLOBAL PRIVACY POLICY - DEC 2019

  • The performance of our contractual obligations with you (e.g. to assit with the management of accommodation, academic studies, events, functions and overall customer experience.

  • Compliance with any legal obligations.

  • The pursuit of legitimate interests of WAILIAN EDUCATION GROUP in managing and developing its business.

    We usually process your special category data with your explicit consent. In other cases, we do so because we consider it necessary:

  • Very occasionally, for the establishment, exercise or defence of legal claims.

  • For statistical purposes (but not to take decisions about you).

8. Who will my personal data be shared with?
Your personal data may be shared, on a considered and confidential basis, with a range of external organisations as is

necessary for the purposes set out above and as permitted or required by law, including the following:

  • Occasionally and when necessary the police and other law enforcement agencies, for the prevention or detection of crime.

  • Occasionally and when necessary internal and external auditors and regulators.

  • Third parties with whom we have entered into a data sharing agreement for the purposes of providing our

    services to you.

    Except as we have explained above, we will not normally publish or disclose any personal data about you to other external enquirers or organisations unless you have asked us to do or have consented to it, or unless it is in your vital interests to do so (e.g. in an emergency situation).

9. How long is my personal data kept?

Personal data relating to an academic placement, internship, occupational placement, accommodation or event booking with us will be kept on our systems for up to seven years after the academic placement/internship/event is completed or the event is held.

Personal data collected as part of a customer enquiry which did not result in a booking will be stored on our systems for a shorter period of time, as permitted by law.

We do this to ensure we can respond to any queries you or any third parties raise regarding current, future or past events or accommodation bookings held with us.

10. Howweprotectyourpersonaldata

WAILIAN EDUCATION GROUP handles a substantial amount of information about individuals. It is important that they have trust and confidence that WAILIAN EDUCATION GROUP will protect their privacy, and we take great care to ensure that personal data is handled, stored and disposed of confidentially and securely. Our staff receive regular data protection training, and we have put in place organisational and technical measures to ensure that personal data is processed in accordance with the 6 data protection principles set out in Data Protection Law.

WAILIAN EDUCATION GROUP insists that any third-party suppliers who provide data storage or payment processing services on our behalf have an Information Security Management System with a range of controls covering the protection of personal information and, where applicable, enter into a data sharing agreement with us.

Your personal data is collected, stored and transmitted securely in a variety of paper and electronic formats. Only relevant staff that require access to your personal data for the purpose for delivering our services will be able to access this data. Our use of your data will be strictly limited to the purpose and legal basis outlined below. We exchange data with subjects and with our data sharing partners using secure electronic channels including, but not limited to, email, wechat and other encrypted messaging services, letter, facsimile and via telephone calls.

WAILIAN GROUP GLOBAL PRIVACY POLICY - DEC 2019

WAILIAN EDUCATION GROUP and its suppliers store and process your data in a number of locations within the United Kingdom, throughout the European Union and in other regions including China.

Regardless of where your data is stored and processed, WAILIAN EDUCATION GROUP is committed to ensuring that your personal information is protected in accordance with our privacy policy. We insist that our suppliers who process or store your data meet or exceed the protections within the GDPR, regardless of their physical location.

WAILIAN EDUCATION GROUP review the privacy policies and general data storage practices of our suppliers regularly and not less frequently than every 12 months.

11. Yourrightsasadatasubject
As a data subject, you have the following rights in relation to your personal data which is processed by Business Horizon

International Group:

  • to access the personal information WAILIAN EDUCATION GROUP holds about you. This is known as a Subject Access Request. More information about making Subject Access Requests and exercising your rights is available below;

  • to correct inaccuracies or, where appropriate and taking into account the purpose for which we process your data, the right to have incomplete data completed;

  • to have your personal data erased. This is a limited right which applies, among other circumstances, when the data is no longer required, or the processing has no legal justification. There are also exceptions to this right, such as when the processing is required by law or in the public interest (e.g. when WAILIAN EDUCATION GROUP needs to retain a historical archive);

  • to object to the processing of your personal data for marketing purposes. If you ask us to delete your personal data, we will continue to maintain a core set of personal data comprising very brief information to ensure that we do not inadvertently contact you in future. We may also need to retain some financial records for statutory purposes;

  • to object to the processing of your personal data when that processing is based on specific criteria such as the public interest or other legitimate interests, unless we have compelling lawful grounds to continue;

  • to restrict the processing of your personal data. This is a limited right which will apply in specific circumstances and for a limited period;

  • to ask for the transfer of your data electronically to a third party;

  • where the legal basis for us processing your personal data is your consent, to withdraw that consent at any time.

    12. Exercisingyourrights,queriesandcomplaints If:

  • you would like more information on your rights;

  • you would like to exercise any right;

  • you have any queries relating to WAILIAN EDUCATION GROUP’s processing of your personal data; or

  • you wish to complain;

    Please contact:

    The Data Protection Officer, WAILIAN EDUCATION GROUP, Aldwych House, 71-91 Aldwych, London, WC2B 4HN

Wailian Education Group Limited is a UK registered company. Company No: 10702664.

Registered Address: Aldwych House, 71-91 Aldwych, London, United Kingdom, WC2B 4HN