Privacy policy

From 25 May 2018 EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and free movement became applicable data and repealing Directive 95/46/EC - General Regulation on Data Protection.

The protection of your personal data is a priority for APAF and we take the issue of transparency and independence very serious. We collect and use the personal data you have shared with us, only to the extent necessary for the development of our activities.

In accordance with the respective Regulation, we hereby communicate to you our Data Protection Policy which contains the new rules applicable to the processing of your personal data, including:

  1. Data collection.
    In the exercise of its activity, APAF collects and uses the data necessary to carry out the activities it provides.

  2. Goal.
    The personal data collected by APAF are intended to provide activities previously requested by the user. Personal data is also collected and processed to respond to users' questions, suggestions or complaints. Other data necessary for the provision of services or compliance with legal obligations may also be collected.

  3. Responsible for the treatment.
    The person responsible for processing the personal data collected is the APAF Associação Portuguesa de Analysts Financeiros, with postal address at Apartado 12088 - 1061-001 Lisbon. Email: APAF may also use subcontractors for all or part of the purposes identified above, as well as for the maintenance, accommodation and management of its computer systems and equipment, under the terms permitted by the legislation that regulates the processing of personal data, with these entities being obliged to maintain secrecy and guarantee security regarding the data provided to which they have access, and shall not use this data for any other purpose, or for their own benefit, nor link them with other data they possess.
    Personal data may be made available to the courts and other competent authorities, in strict compliance with the provisions of the law, in particular when necessary for the resolution of disputes relating to the protection of public security, defense and State security and prevention, investigation or detection of criminal offenses

  4. Conservation period and Security.
    Personal data are kept only for the period necessary to carry out the activity, or to comply with legal obligations. To ensure the protection of the security of the personal data made available to it, APAF has adopted several security, technical and organizational measures, in order to protect personal data against destruction, loss, alteration, disclosure or unauthorized access or against any other form of unlawful treatment. If APAF subcontracts to other entities the provision of services that involve the transfer of personal data, these entities will be obliged to adopt the necessary technical and organizational measures in order to protect the personal data against destruction, loss, alteration, disclosure , unauthorized access or any other unlawful processing.

  5. Rights of Personal Data Subjects
    Under applicable law, users, holders of personal data, have the following rights:

    (a) Right of Information, which consists of the right of users to be informed by APAF, among other aspects, about the purpose of the data processing, to whom they can be communicated, what rights they have and under what conditions. can exercise, as well as which data they must provide;

    (b) Right of Access, which consists of the right of users to access the respective personal data that they have provided, without restrictions, without delay or excessive costs, as well as to know any available information about the origin of such data;

    (c) Right of Rectification, which is the right of users to demand that their data be accurate and current, and may request their rectification from APAF;

    (d) Right of Elimination (or "forgetfulness"), which consists of the right of users to demand the deletion of their personal data from APAF's records when they are no longer used for the purposes for which they were collected, without prejudice, however, the retention periods that are imposed by law;

    (e) Right of Opposition, which consists of the right of users to oppose, at their request and free of charge, the processing of their personal data for direct marketing purposes, or when the processing of data by APAF is based on their legitimate interest ;

    (f) Right to Limit the Processing, which is the right that users have, in certain circumstances, to request APAF to limit the processing of their data, namely (i) when they dispute the accuracy of their personal data, for a period that allows APAF to verify its accuracy; (ii) if the processing is illegal and the user opposes the deletion of the data, requesting, in return, the limitation of its use; or (iii) when APAF no longer needs the user's personal data for processing purposes, but these data are required by the user for the purposes of declaration, exercise or defense of a right in a legal proceeding;

    (h) Right to Complain to the National Data Protection Commission, which is the right to file, without prejudice to any other means of administrative or judicial recourse, a complaint to a supervisory authority, especially in the Member State of your residence habitually, from his place of work or from the place where the infringement was allegedly committed, if the data subject considers that the processing of personal data concerning him violates the General Data Protection (Regulation (EU) 2016/679) and other applicable national legislation. In Portugal, the supervisory authority is the National Data Protection Commission.

    For the exercise of any of their rights, including to access their data or request its rectification, deletion or to oppose its treatment under the terms of the law, users may address themselves in writing by any of the following means, including, in any case, a copy of a document proving your identity and specifying the right or rights you wish to exercise:
    Postal address: Apartado 12088 - 1061-001 Lisbon, Portugal; email:

    Users may also withdraw their consent at any time, when applicable, by contacting APAF in the manner identified above.

  1. Security of personal data.
    APAF undertakes to respect the legislation regarding the protection of the privacy of personal data and to treat these data only for the purposes for which they were collected, as well as to ensure that these data are treated with adequate levels of security and confidentiality. APAF employees also undertake not to disclose to third parties or use for purposes contrary to the law.

  1. Miscellaneous provisions.
    APAF reserves the right to introduce changes and additions to the Privacy Policy at any time and without prior notice, placing the new terms and conditions on the Site for this purpose. The User should periodically consult updates to the Privacy Policy. Use of the Site, after posting any changes or additions, constitutes acceptance of the new terms, as indicated above.