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# ETF Cost Advisor — Terms of Use **Version 1.1.0** — effective 2026-09-10 ## 1. What this tool does The ETF Cost Advisor is a free educational tool that compares the **Total Expense Ratio (TER)** of a UCITS ETF against cheaper peers. You can supply an ETF by ISIN, upload a CSV of holdings, or — if you are signed in to InvestTrack — run the comparison over portfolios you already hold here. Peers are surfaced in three tiers: - **Same index** — same index, same distribution policy (Accumulating or Distributing), same product structure, and the same replication family. Physical and Sampled replication are treated as one family (both hold the underlying securities); Synthetic is kept separate, because a swap carries counterparty risk that a physically-backed fund does not. - **Similar exposure** — a different index with the same asset class, region, and category. These are *not* substitutes; they are shown so you can see what the cost floor looks like for that exposure. - **Different replication** — same index and distribution policy, but the other replication family. Hidden until you ask for it, because the swap vs. physical distinction is a risk decision, not a cost one. Where a cheaper peer exists it is shown with an estimate of the annual TER saving based on the holding value you enter (if any). Where none exists, we say so. ## 2. What this tool is NOT This tool does **not** constitute investment, legal, or tax advice. - TER is one cost component. Total cost of ownership also depends on bid/ask spread, foreign-exchange cost, securities-lending revenue, tracking difference, withholding tax, stamp duty, and your broker's trading and transfer fees. None of these are modelled in this tool. - Results do not consider your personal circumstances, goals, risk tolerance, or tax residence. - Past performance is not indicative of future performance. - We do not verify whether any suggested alternative is available through your broker, tradeable in your jurisdiction, or compatible with your tax wrapper. **You must do your own research before acting on anything shown here.** ## 3. What we record **Usage log.** Every analysis writes one row recording whether it was a single-ETF run or a multi-holding run (a CSV upload and a run over your own portfolios are recorded identically), how many ISINs it covered, how many alternatives we returned, whether any were cheaper, and which version of these terms was in force. This row holds no identifier of any kind — no IP address, no email, no ISINs, no holding values. **Click-stream log.** Separately, we record which parts of the results you interact with — results viewed, alternatives clicked, details expanded, data flagged. **These rows do contain the ISINs concerned**, together with a salted, irreversible hash of your IP address used only to group events from one session. They contain no email address, no holding values, and no account identity. **Rate limiting.** A salted, irreversible hash of your IP address and a daily request count are stored so we can enforce the limits in §6. The original IP address is never stored. **ISINs we don't recognise.** If you submit an ETF that is missing from our catalogue, we record the ISIN so we can add it. If you asked to be told when it lands, your email is stored alongside it; if you were signed in, your account id is stored instead. **Email features.** If you opt into an emailed copy of your analysis or into alternative notifications, we additionally store your email address and the results payload (ISINs, TERs, and savings — not your raw CSV) for those purposes. You can unsubscribe and request deletion at any time via the link in every email we send. **Signed-in analyses.** Running the advisor over your own InvestTrack portfolios reads the holdings already stored in your account. It does not copy them into the advisor's own tables. ## 4. Retention Usage-log and click-stream rows are deleted 24 months after they are written. Records tied to an email opt-in are deleted 24 months after your last interaction with them, and we send a reminder 30 days before that deadline with a link to extend retention. Rate-limit counters are deleted after 30 days. ## 5. Accuracy The underlying ETF catalogue is assembled from issuer product pages, openFIGI identifier lookups, and ESMA's FIRDS registry. Values drift — TERs change, funds merge, ISINs are renamed. Every row carries a "last verified" timestamp; rows older than 60 days are excluded from suggestions. If you spot incorrect data, please use the "Report incorrect data" button — we review flagged rows and exclude them from alternatives while the review is pending. ## 6. Availability We may rate-limit, pause, or discontinue this tool at any time, particularly where upstream data sources become unavailable or where abuse is detected. ## 7. Contact Questions, data corrections, or deletion requests: **c.barneveld@investtrack.net**. --- By clicking "I agree and continue" you confirm that you have read and accept these Terms and understand that this tool is an educational TER comparison, not investment advice.