Legal Information Terms & Conditions Privacy Policy

Terms and Conditions of Use

1. Nature of the Service

PharosFolio® is an online educational platform that allows users to simulate investment portfolios composed of exchange-traded assets such as ETFs and ETCs.

The Service does not constitute financial advice, investment solicitation, or a public offer of financial instruments under Directive 2014/65/EU (MiFID II) or Italian Legislative Decree No. 58/1998 (TUF).

The platform's results are theoretical and designed solely to explain risk and asset-allocation principles.

Users are solely responsible for any investment decisions made independently of PharosFolio®.

2. Beta / Pilot Disclaimer

During the pilot phase, the Service is provided on an "as-is" and "as-available" basis.

Features may be incomplete or experimental.

Outputs (including simulations and rebalancing results) are for educational testing only and must not be used for real trading or portfolio decisions.

3. No Advisory Relationship

Using PharosFolio® does not create any advisory, fiduciary, or professional relationship between users and the platform's owners.

4. Regulatory Disclaimer and User Eligibility

  • No Regulated Activity. PharosFolio® is not a financial intermediary, investment firm, asset manager, or advisor.
  • Private Use Only. The Service is intended for private, non-commercial use.
  • Eligibility. Users must be 18 or older and have full legal capacity.
  • Local Compliance. Users must ensure that access and use are lawful under their local laws.

5. Market Data and Third-Party References

PharosFolio® uses historical market data from open and publicly available sources, including but not limited to Yahoo Finance, MSCI, central-bank datasets, and public index data.

These data are processed exclusively for educational simulations, without any redistribution, commercial use, or modification of proprietary datasets.

All third-party trademarks, names, and indices remain the property of their respective owners and imply no affiliation, endorsement, or approval.

The extraction or reuse of substantial portions of data or databases is prohibited.

PharosFolio® does not claim any license or ownership over such data.

PharosFolio® does not guarantee the accuracy, completeness, or timeliness of any data used in simulations.

6. Investment Risk Warning

All investments involve risk, including possible total loss of capital.

Past performance is not indicative of future results.

Simulations and model outputs do not account for users' personal, fiscal, or financial situations.

Users are encouraged to consult qualified financial advisors before making investment decisions.

7. Permitted and Acceptable Use

Users shall not:

(a) copy, resell, or redistribute the Service;

(b) automate or scrape data;

(c) reverse-engineer or reproduce source code or algorithms;

(d) use the Service or its outputs for professional or commercial advisory purposes.

8. Intellectual Property

All PharosFolio® intellectual property — including software, algorithms, models, logos, and design — remains the exclusive property of its owners.

Users receive a limited, non-transferable license for personal use only.

Any unauthorized reproduction or redistribution may result in legal action.

9. Service Availability and Backup

PharosFolio® applies reasonable security and backup measures but does not guarantee uninterrupted access or full data recovery in all circumstances.

The Service may be modified, suspended, or discontinued at any time.

10. Subscriptions and Withdrawal (Future Paid Version)

Paid plans will be offered on an annual subscription basis with automatic renewal.

Total price, renewal date, and duration are clearly displayed at checkout and in the confirmation email.

Consumers have a 14-day right of withdrawal, unless they expressly request immediate activation of the digital service.

By confirming payment and ticking the acknowledgment box, the user:

  1. explicitly requests immediate activation of the PharosFolio® paid plan; and
  2. acknowledges and agrees that once the service has been made fully available — including access to the simulator or rebalancing tool — the right of withdrawal is lost, pursuant to Article 16(m) of Directive 2011/83/EU and Article 59(o) of the Italian Consumer Code.

This clause prevents the misuse of the withdrawal right after accessing the service.

Renewal cancellation and withdrawal (when applicable) can be exercised online or by contacting info@pharosfolio.com

11. Limitation of Liability

PharosFolio® and its owners are not liable for indirect, incidental, or consequential losses.

Nothing herein limits liability for fraud, willful misconduct, or gross negligence, nor any non-waivable consumer rights.

12. Indemnification

Users agree to indemnify and hold harmless PharosFolio® and its owners against any claims arising from misuse or breach of these Terms.

13. Governing Law and Jurisdiction

These Terms are governed by Italian law and applicable EU legislation.

Consumers retain mandatory protections under the law of their country of residence and may litigate before courts of that country.

All other disputes fall under the exclusive jurisdiction of the Court of Turin (Italy).

14. Digital Services Act (DSA) Compliance

PharosFolio® complies with the transparency and contact requirements under Regulation (EU) 2022/2065 (Digital Services Act).

User contact point: info@pharosfolio.com

15. Language

The official and legally binding version of these Terms and the Privacy Policy is in English.

Privacy Policy

1. Data Controller

Pierpaolo Savi, owner of the PharosFolio® trademark and domain within the European Union.

Contact: info@pharosfolio.com

2. Data Collected (Pilot Phase)

Users are not required to register.

Personal data may be voluntarily provided in the following cases:

  • Pricing page: email for notifications about future updates.
  • Contact form: optional name, surname, email, and message.

Data are used only to respond or send requested updates and are not used for marketing or profiling.

Providing data is optional but necessary to receive a reply.

3. Legal Basis and Retention

  • Legal basis: user consent (Art. 6(1)(a) GDPR).
  • Retention: contact messages deleted after handling; notification emails stored until update or deletion request.

Technical logs (IP, time, browser, OS) kept for 30 days for security.

Users may withdraw consent anytime via email or unsubscribe link.

4. Processors and Transfers

Data may be processed by authorized providers (hosting, email, security) within the EU/EEA.

If transferred outside the EEA, transfers rely on Standard Contractual Clauses or equivalent safeguards.

5. Security and Backup

PharosFolio® implements technical and organizational measures (encryption, access control, monitoring, backups).

Continuous service or full data recovery cannot be guaranteed in all circumstances.

6. Data Collection and Usage for Analytics

6.1 Data Collected

PharosFolio® collects anonymous usage data from the platform for:

a) Improving the service and developing new features

b) Understanding user needs

c) Producing aggregated market statistics

d) Offering premium features based on community comparisons

Types of data collected:

  • Simulation parameters (selected assets, risk levels, time horizons)
  • Simulation results (returns, volatility, drawdown)
  • Rebalancing calculator usage
  • Portfolio activity (when using MyPharos)
  • Frequently asked questions viewed
  • Add-ons purchased and used
  • Session metrics (pages visited, usage time, device)
6.2 Anonymization and Pseudonymization

ALL user data is protected using GDPR-compliant techniques:

FREE users (without account):

  • Unique identifier generated by the browser (stored locally)
  • Non-reversible SHA-256 cryptographic hash
  • No personal data collected or stored
  • Impossible to trace back to user identity

PAID users (with account):

  • Pseudonymization compliant with Art. 4.5 GDPR
  • Email hashed with SHA-256 (irreversible)
  • Hash ↔ email link stored in separate system with limited access
  • Analytics team does NOT have access to real emails
  • Only authorized personnel can identify users (for support and GDPR requests)

For everyone:

  • Aggregation with minimum 20 users per category in B2B analyses
  • B2B reports: ZERO personal identifiers included
  • Impossible to trace back to individual users from aggregated data
6.3 Data Usage

Anonymous data may be used for:

a) Internal Improvement

  • Optimizing user experience
  • Identifying technical issues
  • Developing new features

b) Premium Features

  • Comparing your portfolio with the community (only for users with paid plans)
  • Monthly reports on market trends
  • Personalized alerts based on aggregated behaviors

c) B2B Market Research

  • Sale of aggregated and anonymous reports to:
    • ETF issuers (e.g., asset selection trends)
    • Brokers and investment platforms (e.g., rebalancing behaviors)
    • Research institutes (e.g., risk appetite studies)
  • Example of data sold: "65% of users prefer annual rebalancing"
  • NEVER sold: Emails, names, personal data, individual simulations
6.4 Legal Basis for Processing

Processing is based on:

  • Explicit consent (Art. 6.1.a GDPR) for market research
  • Legitimate interest (Art. 6.1.f GDPR) for service improvement
  • Contract execution (Art. 6.1.b GDPR) for premium features
6.5 Data Retention
  • Retention: 24 months (GDPR compliance)
  • Automatic deletion: Data older than 24 months is deleted
  • Archive: Aggregated data (>100 users) may be retained indefinitely for historical research
6.6 User Rights

You have the right to:

  • Access: Request a copy of your anonymous data
  • Rectification: Correct inaccurate data
  • Erasure: Request immediate deletion of your data
  • Objection: Object to processing for market research purposes
  • Portability: Receive your data in a readable format
  • Restriction: Limit processing under certain circumstances

To exercise these rights: privacy@pharosfolio.com

6.7 Cookies and Tracking Technologies

We use the following technologies:

A) Strictly Necessary Cookies (always active)

  • PHPSESSID: PHP session cookie to manage login and authentication
  • Purpose: Keep user session active
  • Duration: Until browser is closed
  • Legal basis: Legitimate interest (Art. 6.1.f GDPR) - necessary for the service

B) Web Storage (sessionStorage) (requires consent)

  • session_tracking_id: Anonymous session identifier for analytics
  • pages_visited: List of pages viewed (navigation analysis)
  • Purpose: Anonymous analytics, user experience improvement
  • Duration: Until browser is closed
  • Legal basis: Consent (Art. 6.1.a GDPR)

C) Consent Cookie (always active)

  • pharos_analytics_consent: Stores your privacy preferences
  • Duration: 12 months
  • Legal basis: Legitimate interest - necessary to respect your choices

No Third-Party Cookies:

  • ❌ We do not use profiling cookies for advertising
  • ❌ We do not share data with Google Analytics, Facebook, or other third parties
  • ❌ No cross-site tracking
6.8 Consent Management
  • On first visit, we ask for consent via banner
  • You can modify your preferences at any time
  • By rejecting analytics, the site works normally (only necessary data collected)
  • You can delete cookies from your browser or contact us at privacy@pharosfolio.com
6.9 Security

Security measures implemented:

  • SHA-256 encryption for user identifiers
  • Protected databases with limited access
  • Daily encrypted backups
  • Audit logs of changes
  • ISO 27001 standard compliance
6.10 Data Transfer

Data is stored on servers in the EU.

No transfer outside the EU without adequate safeguards (Art. 44-50 GDPR).

6.11 Changes to This Section

Any changes will be communicated via email and published on this page.

Last updated: 2026-01-15

For questions: privacy@pharosfolio.com

7. User Rights

Users may exercise GDPR rights (access, rectification, erasure, restriction, objection, portability) by emailing info@pharosfolio.com

Complaints may be filed with the Garante per la protezione dei dati personali or the competent EU authority.

8. Cookies and similar technologies

The website uses only technical cookies that are strictly necessary for its proper operation. In addition, with the user’s consent, we rely on privacy-friendly analytics that store data in the browser (for example, localStorage or sessionStorage) to collect aggregated, non-identifying statistics on how the Service is used.

Under Italian and EU law, purely technical cookies do not require consent. Analytics are activated only after the user has given consent via the banner or an equivalent mechanism.

No profiling cookies or third-party advertising trackers are used.

9. Minors

Service intended only for users aged 18 years or older.

No data of minors are knowingly collected.

10. Updates

This Policy may change due to legal or technical updates.

The latest version is always available on this page.

Effective date: 2025-11-06