Privacy Policy

SFAA / AZEK AG / AIWM Privacy Policy

Last Updated: 17 August 2023

The Swiss Financial Analysts Association (“SFAA“) is a non-profit professional membership association and network for financial professionals offering a broad range of continuing education opportunities.

AZEK AG is an SFAA Affiliate and leading provider of financial education in Switzerland. As of today, AZEK AG has developed over 6’200 financial professionals to highly qualified specialists in financial analysis & portfolio management, wealth management, financial market operations, financial data science and ESG.

The Association of International Wealth Management (“AIWM“) is an SFAA Affiliate and the international professional organisation for wealth managers, portfolio managers, investment advisors, asset managers and trust and estate practitioners worldwide, and the awarding body of the Associate Wealth Manager and the Certified International Wealth Manager Diploma.

All services under the banner of the respective company/association are provided through centralised IT services at the headquarter.

Privacy Policy Content

We collect Personal Information to help us better understand your needs, to provide you with personalized and efficient service, and for other purposes described in this Privacy Policy. We do not knowingly collect any Personal Information from persons under the age of 18, and users under the age of 18 are not permitted to submit any Personal Information to us.

This privacy policy (“Privacy Policy“) describes:

  • How we gather and protect individually identifiable information (“Personal Information“).
  • How we use, process, store, transfer, and share Personal Information
  • Your rights regarding your Personal Information

This Privacy Policy applies to Personal Information that we collect through any means, including information provided by you as well as information received from third parties.

Personal Information in this Policy, we are referring to “personal data” as defined under the Federal Act on Data Protection (FADP, SR 235.1, Switzerland), the EU General Data Protection Regulation (EU, 2016/679, GDPR); as well as “personal information” as defined under the Personal Information Protection Law (PIPL) of China.

The SFAA Affiliates are responsible for processing of Personal Information. The headquarter of the SFAA Affiliates have their seat in Bülach, Switzerland and can be contacted under the following address AZEK AG, Datenschutzbeauftragter, Feldstrasse 80, 8180 Bülach, Switzerland, and we own and operate the following websites and educational platforms (the “Sites“):

– sfaa.ch: general information about the SFAA and members area, designated holders list
– azek.ch: general information about AZEK courses and certificates, designated holders list
– portal.azeksfaa.ch: student information self-service portal
– mylearning.azek.ch: learning platform for Swiss and International students
– mylearning.azeksfaa.ch: new learning platform (>=2024) for Swiss and International students
– online-ciia.org: learning platform for Independent ACIIA students
– ecr.azek.ch: exam & correction platform
– aiwm.org: general information about the AIWM and members area, designated holders list

Which Categories of Personal Information We Process

SFAA Affiliates process the following categories of Personal Information:

  • Contact details
  • Gender
  • Date of birth
  • Application documents including current employment, work experience and references
  • Educational background
  • SFAA Affiliate examination data
  • Information regarding professional complaints, investigations, and violations of the SFAA Code of Conduct
  • Financial information and information related to credit worthiness
  • Credit card data
  • Identification data, such as Swiss Social Security Number and/or passport information
  • Data related to your business relationship with SFAA affiliates, including event, course and exam participation
  • Video recordings in the course of interviews, event, course, or exam participation
  • Health information as far as relevant to event, course, or exam participation
  • Religious affiliation as far as relevant to event, course, or exam participation
  • Login and user data pertaining to Sites
  • Web user information including, browsing data, IP address and device, operating system and web-client information

User Information We Obtain in the Course of Accessing Sites

Cookies and Other Tracking Technology

Cookies are small pieces of information that a website transfers to your computer. Our Sites uses session ID cookies (expire when you close the browser) and persistent cookies (persist even after you close the browser), which help our Site run more smoothly and tailor content for you. Our Sites use cookies and other tracking devices to collect information automatically which we may use for purposes outlined in this Privacy Policy such as advertising. These tracking devices may be placed by us or by our third-party partners or vendors.

By using the Sites, you agree to the use of cookies and other tracking devices as described below. You may configure your internet browser to notify you when a cookie is sent (giving you the option to decide whether to accept it or not), and to reject or remove cookies. To remove cookies, please follow your browser’s instructions or contact your browser provider for more information. You may also manage many of the cookies on our Sites through your Profile. By removing or refusing to accept cookies, you may be unable to use or access some features of our Sites.

Additionally, to manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents, we use the consent tool “Real Cookie Banner”. Details on how “Real Cookie Banner” works can be found at https://devowl.io/rcb/data-processing/.

Device IDs

Some portions of this Site and our learning and examination platform collect and store a unique device ID associated with your device to track the number of unique visitors using our Sites or mobile applications and to enable you to interact with and use those resources. We link your device ID with the technical information accessed through your use of our Site or the mobile application for the uses described in this Privacy Policy.

Clear Gifs (Web Beacons/Web Bugs)

Our Site may employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), which helps us to better manage content on our Site by informing us what content is viewed or clicked on. Clear gifs are tiny graphics with a unique identifier similar in function to cookies. In contrast to cookies, which are stored on a visitor’s computer, clear gifs are embedded invisibly on web pages and e-mails and are about the size of a period.

Log Files

We also gather Personal Information automatically and store it in log files. For instance, when you visit our Site or use our mobile app, the server may automatically recognize information about you, including: the date and time you visited our Site, the pages you visited, the referrer (the website you came from), the type of browser you are using (e.g., Firefox, Internet Explorer), the type of operating system you are using (e.g., Windows or Mac OS), and the domain name and address of your internet service provider.

Links

Our Sites or Education Platform provide links to websites or services created and maintained by other individuals or organisations, including SFAA Affiliates Member Societies. Please note that these websites’ privacy policies may differ from this Privacy Policy. We encourage you to read the privacy statement of any website you may visit, as we are not responsible for such websites’ content and policies. We do not control these links or sites nor are we responsible for the accuracy, timeliness, security, or continued availability or existence of the information provided on these sites. Other organisations linked from our Sites or Education Platform may collect information about you when you visit their websites. We cannot control this collection of information. You should contact these companies directly if you have any questions about how they use the information they collect.

How We Collect Personal Information

SFAA Affiliates primarily process your Personal Information that is provided by you in the context of any existing, prospective, or past business relationship with one or more SFAA Affiliate, such as registering for an account or any educational offering, as well as course, exam, webinar, and event participation, and signing up to receive newsletters.

Personal Information that arise in the course of using our Sites and Services, such as login information.

Personal Information related to your further education with an SFAA Affiliate can be obtained through your employer, other educational institutions, through any other SFAA Affiliate in the course of direct interactions between you and the SFAA Affiliate, or through SFAA Affiliate related Sites.

Personal Information related to your contact details can be obtained through digital advertising and event participation.

Purposes for Which We Use Personal Information

We process your Personal Information for the following purposes:

For Contractors, Members, Candidates, Attendees at our Events:

  • Processing applications and registrations
  • Membership and account management
  • Course and exam administration
  • Providing examination services
  • Preventing fraudulent activities
  • Processing membership and account related requests
  • Providing a networking platform
  • Distributing educational material through newsletters
  • Marketing
  • Measuring effectiveness of our products and services
  • Development and improvement of SFAA Affiliates’ organisation and services
  • Administrating the Sponsorship Program
  • Maintaining the SFAA Affiliate Institute Member directory and designated holders lists
  • Safeguarding the rights, obligations, and legitimate interests of SFAA Affiliates
  • Reporting possible criminal acts or threats to SFAA Affiliates, their staff, or public security to the competent authorities

For visitors and users of Sites:

  • Marketing
  • Measuring effectiveness of our products and services
  • Development and improvement of SFAA Affiliates’ organisation and services
  • Safeguarding the rights, obligations, and legitimate interests of SFAA Affiliates
  • Reporting possible criminal acts or threats to SFAA Affiliates, their staff, or public security to the competent authorities

Bases for Processing

Our bases for processing your Personal Information are:

  • Contractual necessity, as far as the processing of Personal Information is necessary to apply for or enter a business relationship with one or more SFAA Affiliates.
  • Compliance with legal obligations of one or more SFAA Affiliates.
  • Fulfilment of SFAA Affiliate’s duties as a recognized Swiss and International educational institution.
  • Fulfilment of SFAA Affiliate’s duties as required by employment and social security laws.

Legitimate interests of SFAA Affiliates, including but not limited to the continuous analysation of SFAA Affiliate’s services, fraud prevention.

  • Consent, wherever you are specifically asked to provide us with consent for the further processing of your Personal Information.

How We Share Personal Information

Third Party Processors

We engage third parties to perform services in connection with the operation of our Sites and our organisations. Examples of these third parties include IT service providers for software development, ERP system providers, website hosting service providers, testing vendors, technology service providers, payment processors, legal advisers and consultants, examination centres, research centres, and/or related services. We share Personal Information with these third parties, but we authorize them to use this Personal Information only in connection with the services they perform on our behalf. Such parties are bound by contract to establish appropriate measures to protect your Personal Information from unauthorized access, use, or disclosure. In addition, we share certain Personal Information with third parties as necessary to facilitate our offering of products and services to you.

Your Employer

We share Personal Information with your employer in the form of examination results if your education at the SFAA Affiliate is managed by your employer and your employer is requesting the results of your examination.

Supervising Bodies

We also share Personal Information with our National International Examination committee and otherwise share Personal Information as required by law or at the request of government regulators or other law enforcement officials and the courts.

Member Societies

If you create an account on our Site and provide your mailing address, register for a SFAA Affiliates educational program or certificate, or become a SFAA / AIWM Member, we will share your Personal Information with the SFAA Affiliates Member Society closest to your mailing address. This will enable the Member Society to contact you to communicate the broad range of educational, networking, and career support benefits that societies offer, and which complement SFAA Affiliates products and services. To identify the Member Society closest to your location, please contact us at info@sfaa.ch. If you receive these Member Society communications and decide you no longer wish to receive them, you may opt-out with the Member Society directly.

Under certain circumstances, we may share Personal Information of Candidates, Members, or other customers with their employers in order to validate membership or program status.

Educational and Financial Service Providers

If you authorize us to do so by opting in, we may share your Personal Information with select third parties that offer services or products that we believe may be of interest to you. These third parties may contact you with communications regarding their own services or products. Such third parties may include exam preparatory providers, exhibitors at and sponsors of SFAA Affiliates events, University Program Partners, and other SFAA Affiliates partners, such as our partner associations. Please note that if you receive any communications from these third parties, you may contact them directly to opt-out of receiving further communications from them.

Authorities

We share Personal Information of SFAA Affiliates charter holders with government regulators in connection with SFAA Affiliates charter holder reporting obligations and as otherwise required to do so by law.

Event Attendees

For some SFAA Affiliates events, we may make certain Personal Information of all event attendees available to other event attendees and event sponsors. The Personal Information made available may include name, employer, address, and email address.

General Public

We make Member name, location, and charter status information publicly available through the SFAA Affiliates online Member Directory and Designated Holders List, which is searchable on the SFAA Affiliates public website, as well as by phone and email upon a third party’s request. Members may choose to make this information not available by declining to be listed on the designated holders list.

Please contact us at info@sfaa.ch if you wish to do so.

Marketing Distribution Partners

SFAA Affiliates uses remarketing services (sometimes called interest-based advertising) to show relevant content on sites across the internet to previous visitors to our Site (as described below in “online behavioural advertising”) and email subscribers. These services allow us to tailor our advertising and marketing content so that it is relevant and suits your needs. If you have consented to receiving marketing communications from us, we may share certain pseudo-anonymized (hashed) portions of your Personal Information (e.g., your email) with social media and eCommerce platforms such as Facebook, Instagram, LinkedIn, Xing and Microsoft Azure. If you have an account on one of these platforms, this data sharing facilitates delivery of SFAA Affiliates advertising or messages while you are using those social media networks. If you do not want your Personal Information shared in this manner, you may withdraw consent to SFAA Affiliates marketing communications as described below, or you may adjust your settings in the relevant platforms so those networks may not use your Personal Information in this manner.

Our Site places and recognizes cookies, third-party web beacons and similar technologies on your browser or device when you visit it for purposes of serving you targeted advertising (a.k.a. “online behavioural advertising”). We also work with third party analytics and advertising companies who place their own cookies or similar cookie less technology on your browser or device when you visit our Site and other third-party websites, in order to provide analytics to us or serve customized advertisements to you. We work with advertising and analytics partners such as Google Ads, LinkedIn, Facebook, Twitter, Infomaniak and Microsoft.

As noted above in the Cookies section of this Policy, you can set your device or browser to accept or reject most cookies, or at least notify you in most situations that the technology is offered.

Please note that even if you reject these devices, you may continue to receive advertisements, but the advertisements will not be tailored to your browsing activities and interests.

The Sites offer opportunities to engage in social networking, interact with others and/or submit or post messages or other content, such as on SFAA Affiliates portal and education platform. The Sites may also provide for interactions with third party websites or services including social media websites through plug-ins. Please note that any information or materials that you post or submit through such SFAA Affiliates Networking Sites will be publicly posted to everyone that has access to the relevant Site. Posts to third party social media or other sites (“Social Media Sites”), including any content on our Site that you “share” or “like,” will be controlled by and subject to the terms of such social media or other sites. We encourage you to use caution when you submit any information or materials on or through any SFAA Affiliates Networking Site or interact with third party websites or services through plug-ins.

How We Use Cross-Border Data Transfers

SFAA Affiliates has its headquarters in Switzerland and IT service providers within the EU and India. By providing SFAA Affiliates with your Personal Information, you acknowledge that some of your Personal Information may be transferred outside Switzerland. We provide appropriate protections for cross-border transfers as required by law through technical and organizational security measures, data processing agreements and the use of EU Standard Contractual Clauses, where appropriate.

How We Secure Your Personal Information

We maintain reasonable and appropriate technical, physical, and organisational measures to protect the security of your Personal Information. Access to Personal Information is limited to only those employees, contractors, or authorized agents of SFAA Affiliates who have authorisation to access such Personal Information and such access is limited to the extent such information is needed to fulfil the purpose for which the Personal Information was collected.

While we strive to protect your Personal Information, we cannot ensure the security of the information you transmit. We recommend you take every precaution in protecting your Personal Information when you are on the internet. For example, change your passwords often, use a combination of letters and numbers that cannot be easily guessed when creating passwords, and make sure you use a secure browser and network.

How We Store and Archive Your Personal Information

We keep your information for the following time periods:

  • We retain information pertaining to your potential future education with an SFAA Affiliate for up to three (3) years.
  • We retain marketing communications for up to three (3) years.
  • We retain any information pertaining to a contractual relationship with one or more SFAA Affiliates, including participation at physical and virtual events, for as long as the SFAA affiliate is subject to duties of fulfilling said contractual obligations or providing proof of contractual fulfilment.

If you register for any exam and or are an SFAA Affiliates charter holder, we retain some of your personal information for longer than the above-mentioned time periods, in compliance with SFAA Affiliates’ record keeping duties as a Swiss and international educational institution.

How to Manage Your Personal Information

Your Communication Preferences

You may change your preferences for how we contact you at any time by visiting “My Account” on the SFAA Affiliates website, or by contacting us using the information provided under the “Contact Us” section of this Policy.

In order to provide you with superior service, we may contact you to resolve a problem even if you have asked us not to contact you for other purposes. For example, if you are a Member and we cannot deliver your Annual Dues Bill and Professional Conduct Statement, we may contact you to verify delivery details.

Accessing and Updating Your Personal Information

If you have entered a business relationship with an SFAA Affiliate, you may view your Personal Information on file with us at any time by visiting our portal site (account login required) on the SFAA Affiliates website, where you may change some of your Personal Information. You may also contact us via email if you do not have an account.

Your Rights Related to Your Personal Information

We provide you with the rights to:

  • Access your Personal Information.
  • Request rectification of inaccurate Personal Information or place a note of objection to the correctness of Personal Information.
  • Request deletion of your Personal Information.
  • Request restriction of processing of your Personal Information.

Request Personal Information which you have provided us with, in a structured, commonly used, and machine-readable format in order to provide them to another controller.

  • Object to the processing of your Personal Information and withdraw your consent to processing your Personal Information at any time, as far as the processing of your personal data is based on consent. The withdrawal of consent does not affect any processing of your Personal Information before the time of withdrawal. If you have entered a business relationship with an SFAA Affiliate, you may update your mailing preferences by visiting our portal site. If you do not have an account with us, but are subscribed to SFAA Affiliates marketing emails, you may withdraw your consent to receive such emails through the unsubscribe link contained in each email or by contacting us directly via email.

Please note that these are no absolute rights and our obligations to respond are limited by and subject to applicable law.

Moreover, you have the right to lodge a complaint with our Data Protection Officer or the Federal Data Protection and Information Commissioner.

Changes to This Policy

Except where limited by applicable law, we reserve the right to update this Policy to reflect changes to our information practices by prominently posting notice of the update on our Sites. Any updates will become effective immediately after posting the updates to this Policy and apply to all Personal Information processed by SFAA Affiliates.

Contact Us

For further information about SFAA Affiliates ‘s privacy practices, please contact us.

To manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents, we use the consent tool “Real Cookie Banner”. Details on how “Real Cookie Banner” works can be found at https://devowl.io/rcb/data-processing/. The legal basis for the processing of personal data in this context are Art. 6 (1) lit. c GDPR and Art. 6 (1) lit. f GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents. The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we will not be able to manage your consents.