Privacy Policy

Privacy policy for the El Fondo platform

Last Updated: February 6, 2026

1. Controller and Contact Information

The Service is currently operated by the following individuals (acting as Joint Controllers):

  • David Siegl
  • Valeria Morote
  • Friedrich Roesel

(Collectively referred to as "El Fondo," "we," or "us").

  • Mailing Address: Calle Independencia 1274, Miraflores, Lima, Peru.
  • Privacy Contact: Valeria Morote – valeria(at)el-fondo.com
  • DPO (Encarregado de Dados) for Brazil: Pursuant to Art. 41 of the LGPD, the designated contact for Brazilian data subjects is Valeria Morote at valeria(at)el-fondo.com.

Note on Corporate Transition: As stated in our Terms of Service, we are currently in the process of establishing a formal legal entity in Latin America. Upon completion of this process, the role of Data Controller will transfer to the new entity. We will notify you of this change.

2. Personal Data We Process

Depending on how you interact with El Fondo, we may process:

  • Contact Data: Name, email address, phone number, and country/city and your investor preferences and inputs from but not limited to the registration process, including experience level, investment objectives, planned capital, time horizon, and risk tolerance.
  • Platform Activity Data: including but not limited to portfolio simulations, asset allocations, watchlist items, leaderboard positions, and contest results.
  • Technical Data: IP address, device type, browser information, and interaction events (clicks, page views).
  • Communications: Support requests, feedback, marketing, and email interactions.

3. Purposes of Processing

We may process your personal data for the following specific purposes:

A. Necessary Purposes (To operate the Service):

  • User Verification: Sending verification emails to unverified users to validate account creation.
  • Service Delivery: Providing access to simulated portfolios, watchlists, and marketing communications.
  • Security & Fraud: Detecting abuse, preventing multiple account creation in contests, and ensuring platform integrity.
  • Performance Monitoring: Using technical logs to fix errors and ensure site uptime.

B. Optional Purposes (With your consent):

  • Marketing: Sending newsletters and updates.
  • Analytics: Using tools like PostHog to understand product usage and improve features.
  • Affiliate Attribution: If you click on a broker partner link, limited technical data (e.g., click timestamp) is processed to verify eligibility for the referral.

C. Market Intelligence & Partner Insights:

We process onboarding data to generate anonymized and aggregated market reports. This helps our partners (Asset Managers) understand regional investment trends and design better financial products for the LATAM market.

4. Vendors & Partners (Processors)

To provide the Service, we share data with trusted third-party service providers (processors). These providers are contractually bound to confidentiality and may not use your data for their own purposes.

  • Customer.io (USA): CRM, Email Automation, User Nurturing.
  • GoDaddy (EU/USA): Hosting & Infrastructure.
  • PostHog (EU): Product Analytics & Session Recording.
  • Grafana Faro (EU): Performance Monitoring & Error Logging.

Anonymized Sharing: We may share aggregated statistical data with our financial partners. Important: This data is strictly anonymized; it does not contain names, emails, or any information that could identify an individual user. Partners never receive your PII (Personally Identifiable Information) unless you explicitly request a product or service via a "Partner Profile" page.

Note: If you interact with a third-party broker link, you are subject to that third party's privacy policy.

5. International Transfers

Your personal data is stored and processed on servers located in the European Union (e.g., PostHog, Grafana) and the United States (e.g., Customer.io).

By using the Service, you expressly consent to this cross-border transfer. We ensure that our providers (acting as data processors) maintain security standards and contractual protections that comply with: Peru, Law No. 29733 and its Regulations; Mexico,The Federal Law on Protection of Personal Data Held by Private Parties (LFPDPPP) and Chile, Law No. 19.628 on the Protection of Private Life. For transfers of Brazilian user data, El Fondo utilizes Standard Contractual Clauses (SCCs) or equivalent mechanisms to ensure a level of protection consistent with LGPD.

All transfers are conducted to jurisdictions that offer an adequate level of protection or through providers that adhere to international frameworks such as the GDPR or equivalent standards recognized by the aforementioned authorities.

6. Retention

We retain personal data only as long as necessary:

  • LEADS: Unverified emails are deleted after a reasonable period if no action is taken.
  • REGISTERED/SUBSCRIBERS: Retained for the duration of your active relationship with us.
  • Legal: We may retain data longer if required by tax or legal obligations.

7. Your Rights (ARCO & More)

You may exercise your rights at any time by contacting david(at)el-fondo.com.

  • Global Rights: Access, Rectification, Deletion, and Objection.
  • Peruvian Rights (ARCO): Access, Rectification, Cancellation, and Opposition (via the email above).
  • Mexican Rights (LFPDPPP): In addition to ARCO rights, you have the right to limit the use or disclosure of your data and to revoke consent.

7.1. Your Rights: Specific Rights for Users in Brazil (LGPD)

"In accordance with the LGPD, Brazilian users have the following additional rights:

  • Confirmation: Confirmation of the existence of data processing.
  • Anonymization/Blocking: Requesting the anonymization, blocking, or deletion of unnecessary or excessive data.
  • Portability: The right to request the transfer of your data to another service provider.
  • Information on Sharing: Information about the public and private entities with which we have shared data.
  • Revocation: The right to revoke consent at any time without affecting the legality of previous processing."

8. Cookie Policy

What are Cookies? Cookies are small text files stored on your device that help us improve your experience.

Your Control When you first visit, you see a banner where you can:

  • Accept All: Enable Essential + Analytics.
  • Reject Non-Essential: Enable only Strictly Necessary cookies.
  • Manage Preferences: Customize your choice.
  • Settings: You can change your preferences anytime via the Cookie Settings link in the footer.

Types of Cookies We Use:

A. Strictly Necessary (Always Active) Required for the website to function (login sessions, security).

  • el_fondo_consent: Stores your cookie choice (Duration: 1 year).
  • el_fondo_session: Keeps you logged in (Duration: Session).

B. Analytics & Performance (Requires Consent)

  • PostHog (EU): Used for product analysis and session recording to see how features are used.
  • Grafana Faro (EU): Used for technical health monitoring.
    • Data: Load times, error logs.
    • Duration: Session.

9. RNPD Registration (Peru)

In compliance with Peruvian Law No. 29733, El Fondo is currently in the process of registering its personal data banks with the National Authority for Personal Data Protection (Autoridad Nacional de Protección de Datos Personales).

10. Updates

We may update this Privacy Notice to reflect changes in our legal entity or technology. Material changes will be notified via email or a prominent notice on the site.