Privacy policy
This policy explains what personal data ETF Portfolio Growth Simulator processes, why, and what your rights are under the EU General Data Protection Regulation (GDPR) and the Italian Personal Data Protection Code.
1. Who is responsible
The data controller is Andrea Pizzini (ditta individuale), Via Schaffer 35, 39012 Merano (BZ), Italia, VAT number IT03088570217. Contact for all privacy questions and requests: admin@myfreedometf.com.
2. Using the simulator
All calculations run in your own browser. Your country, amounts and ETF choices are not sent to us while you use the simulator. Your browser stores a few settings on your device (language, cookie choices and a random visitor number) so the page works as expected. See the cookie policy for details.
3. Data we process, why and on what legal basis
| What | Why | Legal basis | How long |
|---|---|---|---|
| Email address, chosen alerts, country and saved portfolio, when you subscribe | To send the alerts you asked for and to keep your portfolio | Your consent (Art. 6(1)(a) GDPR). You can withdraw it at any time. | Until you unsubscribe or ask us to delete it. Unconfirmed sign-ups are deleted after 30 days. Saved portfolios that are not used for 24 months are deleted. |
| Proof of your consent (date, time, what you agreed to, shortened IP address) | To be able to show that you gave consent | Legal obligation (Art. 6(1)(c) and Art. 7(1) GDPR) | As long as the subscription or cookie choice applies, plus up to 24 months |
| Error reports you send: your message, optional email address, the settings you were using | To fix errors and, if you wish, to reply to you | Our legitimate interest in a correct tool (Art. 6(1)(f) GDPR) | 12 months |
| Shortened IP address and time of requests to our server | Security and preventing abuse (for example spam sign-ups) | Our legitimate interest in a secure service (Art. 6(1)(f) GDPR) | 30 days |
| Usage statistics through Google Analytics and Clicky | To understand how the simulator is used and improve it | Your consent (Art. 6(1)(a) GDPR). Nothing is loaded unless you accept. | See the cookie policy |
4. Who receives your data
- Hosting: GoDaddy (GoDaddy Operating Company, LLC) hosts this website and its database as our processor, under a data processing agreement.
- Email: confirmation emails are sent through our hosting provider's mail server.
- Google Analytics (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland), only if you accept analytics cookies. IP addresses are not logged or stored by Google Analytics 4 in the EU. Data sharing with Google and Google signals are switched off.
- Clicky (Roxr Software Ltd., USA), only if you accept, with privacy options enabled.
We do not sell your data and do not use it for advertising profiles.
5. Transfers outside the EU
Some providers (Google, Clicky and possibly our hosting provider) are based in, or may process data in, the United States. Such transfers rely on the EU–US Data Privacy Framework for certified companies, or on the European Commission's Standard Contractual Clauses.
6. Partner links to brokers
When you click a broker link, you leave our website. The broker may then process your data under its own privacy policy. We only receive anonymous totals of accounts opened through our links; we do not receive your name or account details.
7. Your rights
You have the right to access your data, to have it corrected or deleted, to restrict or object to its processing, to data portability, and to withdraw consent at any time without affecting earlier processing. To use these rights, write to admin@myfreedometf.com. We reply within one month. Every alert email contains a link to unsubscribe.
You also have the right to lodge a complaint with a supervisory authority, in particular the Italian Garante per la protezione dei dati personali (www.garanteprivacy.it) or the authority in the EU country where you live.
8. Other information
- Giving your email address is voluntary. Without it we cannot send alerts.
- We do not make automated decisions with legal or similar effects about you.
- The alerts are meant for people aged 16 or older.
- We protect data with HTTPS, access controls, shortened IP addresses and automatic deletion.
9. Changes
We may update this policy, for example when the law or our services change. The date at the top shows the latest version.