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Legal Information Terms & Conditions Privacy Policy

Legal Information

PharosFolio® is a pilot service, currently provided free of charge.

Contact: info@pharosfolio.com

Data controller: see Privacy Policy, Section 1.

Disclaimer

PharosFolio® provides online software tools for portfolio simulation, allocation and rebalancing calculations, for informational purposes only.

It does not provide financial advice, investment recommendations, or portfolio management.

All data and results are illustrative, based on publicly available market sources.

To the extent permitted by applicable law, PharosFolio® makes no warranty for accuracy or completeness and assumes no liability for any loss arising from its use, except in cases of fraud or gross negligence.

Terms and Conditions of Use

These Terms govern the use of the PharosFolio® website and services (the “Service”). By using the Service or creating an account, users accept these Terms.

1. Nature of the Service

1.1 PharosFolio® is an online software platform designed to support advanced investors in managing their portfolio autonomously. The Service allows users to:

(a) simulate portfolios composed of exchange-traded assets, such as ETFs and ETCs, on historical market data;

(b) calculate target allocations by applying a proprietary rules-based model to the risk level selected by the user;

(c) calculate indicative buy/sell quantities to rebalance a portfolio, including in connection with deposits and withdrawals;

(d) save portfolios and monitor their composition through the Portfolio Tracker (user registration required).

1.2 Simulation results are theoretical reconstructions based on historical data and do not reflect all real-world factors, such as transaction costs, taxes, liquidity or differences between quoted and execution prices. Past performance is not indicative of future results.

1.3 The Service does not constitute investment advice, portfolio management, reception and transmission of orders, investment solicitation or a public offer of financial instruments under Directive 2014/65/EU (MiFID II) and the national laws implementing it in each EU Member State, including Italian Legislative Decree No. 58/1998 (TUF). PharosFolio® does not execute orders and does not hold users’ funds or financial instruments.

1.4 Users remain solely responsible for their investment decisions.

2. Pilot Phase and Nature of Outputs

2.1 During the pilot phase, the Service is provided on an “as-is” and “as-available” basis. Features may be incomplete, experimental or modified without notice, and outputs may contain errors. Users should check the consistency of any output before acting on it.

2.2 Target allocations and buy/sell quantities are generated automatically by applying a predefined, rules-based model to the parameters selected by the user (assets, investment amount, risk level, deposits and withdrawals). They are not based on any assessment of the user’s personal, financial or tax situation, knowledge, experience or objectives, they are not presented as suitable for the user, and they do not constitute a personal recommendation or investment advice under MiFID II (see Section 1.3).

2.3 The choice of risk level is made by the user. Descriptions of risk levels provided by the Service are general in nature and do not constitute an assessment of suitability or appropriateness.

2.4 Any decision to place orders, and their execution through the user’s own broker, is taken solely by the user under their own responsibility.

2.5 Prices used by the Service are delayed and buy/sell quantities are indicative. Actual execution prices may differ. Before placing any order, users should verify prices, quantities, costs and tax implications.

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. User Accounts

5.1 Registration is optional and is required only for features that store user data, such as the Portfolio Tracker. Users must provide accurate information, keep their login credentials confidential and are responsible for activity carried out through their account.

5.2 Users may stop using the Service and request the deletion of their account at any time by contacting info@pharosfolio.com.

5.3 PharosFolio® may suspend or close accounts used in breach of these Terms, or close accounts if the Service is discontinued, giving notice to the user where reasonably possible.

6. Market Data and Third-Party References

PharosFolio® uses historical market data from publicly available sources, including but not limited to Yahoo Finance, MSCI, central-bank datasets and public index data. Where fund data are not available for older periods, histories are extended with index data or synthetic reference series, as described in the FAQ.

These data are processed solely to provide the Service’s simulations and calculations and are not redistributed as raw data.

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 and does not guarantee the accuracy, completeness or timeliness of any data used in the Service.

7. 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.

8. 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.

9. 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.

10. 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.

11. Limitation of Liability

To the extent permitted by applicable law, 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

To the extent permitted by applicable law, users agree to indemnify and hold harmless PharosFolio® and its owners against claims by third parties arising from the user’s breach of these Terms or unlawful use of the Service.

13. Changes to these Terms

PharosFolio® may update these Terms. The current version is always published on this page with its effective date. Material changes will be communicated to registered users by email. Continued use of the Service after the effective date constitutes acceptance of the updated Terms; users who do not accept them may stop using the Service and request the deletion of their account.

14. 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).

15. Digital Services Act (DSA)

Single point of contact for users and authorities under Regulation (EU) 2022/2065 (Digital Services Act): info@pharosfolio.com

16. Language

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

Effective date: 2026-10-06

Privacy Policy

1. Data Controller

Pierpaolo Savi, owner of the PharosFolio® trademark.

Contact: info@pharosfolio.com

2. Data Collected (Pilot Phase)

The Service is currently free of charge. Most features (including the Simulator and Compass) can be used without registration. Personal data are collected only in the following cases:

  • Account registration: required to save portfolios and use the Portfolio Tracker. We collect your name, email address and password. If you sign in with Google, we receive from Google basic account information, such as your name and email address; Google acts as an independent controller under its own privacy policy.
  • Portfolio data: the data you enter when you save a portfolio. These data are linked to your account and used only to provide the Portfolio Tracker and related features to you.
  • Contact form: your name, email address and message, if you contact us.

Personal data are used only to provide the Service and respond to requests. They are not used for advertising or profiling, and they are not sold.

Providing personal data is optional; however, registration is required to use the Portfolio Tracker, and contact details are required to receive a reply.

3. Legal Basis and Retention

  • Account and portfolio data: processed to provide the Service you have requested (Art. 6(1)(b) GDPR). Retained until your account is deleted, then deleted without undue delay.
  • Contact form: processed on the basis of your consent (Art. 6(1)(a) GDPR). Contact messages are deleted after handling.
  • Technical logs (IP address, time, browser, operating system): processed for security purposes on the basis of legitimate interest (Art. 6(1)(f) GDPR) and kept for 90 days.

You may withdraw your consent at any time, and you may request the deletion of your account at any time by contacting info@pharosfolio.com.

4. Processors, Recipients and Transfers

Data may be processed by service providers acting on our behalf (hosting, email, security) located within the EU/EEA.

Google acts as an independent controller when you use Google sign-in and for the reCAPTCHA service (see Section 6.6).

Where data are transferred outside the EEA, transfers rely on an adequacy decision (such as the EU-U.S. Data Privacy Framework) or on Standard Contractual Clauses.

5. Security

PharosFolio® implements appropriate technical and organizational measures to protect personal data (Art. 32 GDPR). Continuous service or full data recovery cannot be guaranteed in all circumstances.

6. Usage Data (Analytics)

6.1 Data Collected

If you accept analytics through the cookie banner, PharosFolio® collects usage data to improve the Service, understand user needs and produce aggregated usage statistics. Usage data are not collected if you select “Necessary Only”.

Types of data collected:

  • Simulation parameters (selected assets, risk levels, time horizons)
  • Simulation results (returns, volatility, drawdown)
  • Compass usage (allocation and rebalancing calculations)
  • Portfolio Tracker usage (registered users only)
  • Frequently asked questions viewed
  • Session metrics (pages visited, usage time, device)
6.2 Pseudonymization and Aggregation

Usage data are collected under a pseudonymous identifier and are not used to identify you. Only authorized personnel can link usage data to a registered user, where necessary for support or to handle requests to exercise your rights. Statistics are produced only in aggregated form and contain no personal data.

6.3 Data Usage

Usage data are used to optimize the user experience, identify technical issues, develop new features and produce aggregated usage statistics for internal purposes.

6.4 Legal Basis

Usage data are processed on the basis of your consent (Art. 6(1)(a) GDPR), given through the cookie banner and withdrawable at any time. Strictly necessary cookies are used without consent, as permitted by applicable law.

6.5 Data Retention

Usage data are retained for 24 months and then deleted. Aggregated statistics, which contain no personal data, may be retained without time limit.

6.6 Cookies and Similar Technologies

A) Strictly Necessary Cookies and localStorage (always active)

  • PHPSESSID: PHP session cookie to manage login and authentication
  • Purpose: keep the user session active
  • Duration: until the browser is closed
  • just_logged_in: localStorage flag used to refresh the interface after login
  • Purpose: complete the login flow
  • Duration: removed after login
  • login_pending: localStorage flag during the login process
  • Purpose: complete the login flow
  • Duration: removed when login completes or fails
  • logged_out: localStorage flag after logout
  • Purpose: complete the logout flow
  • Duration: until the next login or until storage is cleared
  • simulator_info_dismissed: localStorage flag when the simulator info box is dismissed
  • Purpose: remember the user’s choice
  • Duration: until the user clears browser storage
  • pharos_sim_cache_v1::*: localStorage cache of the last simulation results
  • Purpose: restore results on the same device without repeating the request
  • Duration: 24 hours

B) Web Storage (sessionStorage and localStorage) (requires consent)

  • session_tracking_id: anonymous session identifier for analytics
  • pages_visited: list of pages viewed (navigation analysis)
  • session_start: session start timestamp
  • simulations_run: number of simulations in the session
  • rebalances_calculated: number of rebalancing calculations in the session
  • faqs_viewed: number of FAQs viewed in the session
  • Purpose: analytics and user experience improvement
  • Duration: until the browser is closed
  • pharos_browser_id: localStorage anonymous browser identifier
  • pharos_user_hash: localStorage pseudonymous user identifier
  • Purpose: analytics identification on a pseudonymous basis
  • Duration: until the user clears browser storage

C) Consent Cookie (always active)

  • pharos_analytics_consent: stores your privacy preferences
  • Duration: 12 months

D) Google reCAPTCHA (security)

  • Purpose: protecting the Service and its forms against spam and abuse
  • Google may collect device and browser information and set its own cookies, under the Google Privacy Policy and Terms of Service
  • Legal basis: legitimate interest in the security of the Service (Art. 6(1)(f) GDPR)

We do not use advertising or profiling cookies and do not perform cross-site tracking. Analytics data are not shared with third parties. Apart from Google reCAPTCHA and Google sign-in (if you choose to use it), no third-party services set cookies on the Service.

6.7 Consent Management
  • On your first visit, we ask for your consent through a banner
  • You can change your preferences at any time
  • If you reject analytics, the Service works normally and only necessary data are collected
  • You can delete cookies from your browser or contact us at info@pharosfolio.com

7. User Rights

You may exercise your rights of access, rectification, erasure, restriction, objection and data portability, and withdraw your consent at any time, by emailing info@pharosfolio.com.

You may lodge a complaint with the Garante per la protezione dei dati personali or with the supervisory authority of your EU country of residence.

8. Minors

The Service is intended only for users aged 18 or older. No data of minors are knowingly collected.

9. Updates

This Policy may change due to legal or technical updates. The latest version is always available on this page; material changes will be communicated to registered users by email.

Effective date: 2026-10-08

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Privacy and Cookies

We use privacy-friendly analytics (with your consent) to improve the site. Logs are pseudonymized and include only minimal usage data, so linking activity to a specific person is intentionally difficult. Analytics data are not shared with third parties. Learn more