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Horizon privacy policy

Last updated: 13 October 2026

This policy explains how the data of people who visit the horizonscope.net website and of people who use the Horizon Android app is handled. Horizon is a personal project for people who invest in ETFs: it offers guides, an ETF catalogue, video and podcast content and simulation tools.

1. Who we are

  • Data controller: Gabriele Fasulo.
  • Contact: [email protected].
  • Horizon does not require you to create an account.

2. The website

  • Technical access data. The website is hosted by Cloudflare, which processes some technical data for every visit, such as the IP address, the browser's technical information and the page requested. They are needed to run the website and to protect it.
  • Cookies and advertising. The website does not set cookies and does not use advertising or tracking tools. This applies to the tools used by the website: when your browser loads content hosted by others (point 4), those services may process data according to their own rules.
  • Visit statistics. The website uses Cloudflare Web Analytics to count visits in an aggregated and anonymous way. This tool does not use cookies, does not create profiles of individual visitors and does not follow people across other sites. We only see general information: the pages visited, the site the visit comes from, the country, and the type of browser and device. The IP address is not used to identify the person. Cloudflare provides the service on our behalf. The purpose is to understand which pages are most useful, in order to improve the website, on the basis of our legitimate interest (Art. 6(1)(f) GDPR). If you do not want to be counted, you can write to us at [email protected]. This measurement concerns only the website: the app does not use it.
  • Search results. We use Google Search Console to see, in aggregated form, how the website appears in search results. This tool does not install anything on the website and does not collect visitors' data.
  • Data saved in your browser. To make its features work, the website saves on your device:
    • the ETFs you add to your Favourites and the ETFs you opened most recently;
    • a copy of the catalogue and of the Media list;
    • the data you enter in the Rebalancing, Projection and Benchmark simulators.

    This data stays on your device and we do not receive it. You can delete it with the simulators' "Azzera" (reset) button, from your browser settings or by clearing the site data: this way you lose the saved information.

  • Market data. The catalogue, the ETF pages and the simulators ask our server for ETF prices, price histories and details. The server receives your IP address and the codes (ISIN) of the ETFs requested. These codes can reveal which securities you are interested in, and Rebalancing sends more than one in the same request. The server does not receive the amounts, the units, the purchase prices, the weights or the dates you enter in the simulators, nor the text you type in the search.
  • Address of the ETF page. The ETF's code appears in the page address (for example /etf/?isin=…), so whoever hosts the website also sees it.

3. The Android app

  • Your data stays on your phone. Portfolios, transactions, units, purchase prices and settings are saved only on your phone, which Android isolates from other apps and, when the screen lock is active, encrypts together with the storage. We recommend protecting it with the screen lock.
  • What our server receives. When you use the app, the server receives your IP address and the codes (ISIN) of the ETFs for which the app requests prices, price histories, details, composition and dividends. It also receives the requests for exchange rates, interest rates, inflation, guides, glossary and Media content.
  • What it does not receive. The app does not tell the server whether a security is in your real portfolio or in a simulation, nor the units or the amounts: the server does not know them. The app does not use device identifiers or libraries for advertising, statistics or automatic error reporting.
  • Backup. The app's data is excluded from the automatic backup of Android and Google. To change phone you can use the profile export (Profile → "Create backup file"). You can protect the file with a password, if you wish. You manage the file yourself: the app does not send it to anyone. Whoever exports it is responsible for keeping it and for protecting the password.

4. Content loaded from other sites

  • Video and podcast thumbnails. On the website and in the app, the preview images of videos and podcasts are loaded directly from the servers of Google/YouTube and of the services that host the podcasts, including Podigee, Acast, Megaphone (Spotify), imgix, Libsyn, Podbean and Captivate, depending on the content. These services receive your IP address and the technical data of your browser or device, and may process other data according to their own privacy policies. Some are located outside the European Union (United States and United Kingdom). The website does not tell them the address of the page you are viewing.
  • External links. When you open a video, a podcast or another external link you go to the source's site, and from there its rules apply. Horizon does not control the processing that those services carry out on their own.

5. Why we process data

  • To show you the pages and the data you request and to run the website and the app.
  • For security and abuse prevention, that is, to protect the server, detect malfunctions and stop abusive requests, on the basis of our legitimate interest (Art. 6(1)(f) GDPR).
  • To reply to the messages you choose to send us.

Horizon does not sell data, does not carry out profiling and does not make automated decisions that produce effects on you.

6. Who we share data with

  • Cloudflare, which hosts the website, the server and the database, which provides the website's visit statistics (point 2) and which handles the incoming mail at [email protected], forwarded to the controller's mailbox. For visitors' technical data Cloudflare acts partly as an independent controller and partly on our behalf.
  • Google/YouTube and the podcast services, when your browser or your app loads the thumbnails or when you open their links (point 4).

Our server also requests data from external sources (prices, exchange rates, interest rates, inflation, content). These are requests made by the server, separate from those made directly by your device: your IP address does not reach those sources.

7. Transfers outside the European Union

Cloudflare and Google may also process data outside the European Union. They state that they adhere to the EU-US Data Privacy Framework and, failing that, that they use the standard contractual clauses. The actual safeguards depend on the provider and on the service.

8. How long we keep data

  • Our server does not log the addresses requested. Cloudflare's technical logs for our server are kept for 7 days at most. For the other technical data processed by Cloudflare, the retention periods in its privacy policy apply.
  • The Horizon database contains market data, guides, glossary, Media content and technical management information. It does not contain visitors' personal data.
  • Data in the browser and in the app: it stays on your device until you delete it or remove the website's or the app's data.
  • Emails received at [email protected]: we keep them for as long as needed to reply to you and for the subsequent obligations.

9. Your rights

You can ask us for access to your data, rectification, erasure, restriction, objection and portability, where applicable, by writing to [email protected]. We have no accounts and we do not link portfolios to an identity on our server, so for requests tied only to the IP address we may not be able to find the data concerning you. You can lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali): www.garanteprivacy.it.

10. Changes

If in the future we introduce advertising, affiliate links, other statistics tools, tracking tools or other features that involve different processing, we will update this policy before activating them and, where the law requires it, we will ask for your consent. The updated version will be published on the website and will also be reachable from the app.