El Fondo

Terms of Service

Terms and conditions for using the El Fondo platform

Last Updated: February 6, 2026

1. Who we are and how to contact us

The Service is a private and non-profit initiative operated by David Siegl, Valeria Morote, and Friedrich Roesel (collectively, "El Fondo," "we," or "us"). Mailing Address: Calle Independencia 1274, Miraflores, Lima, Peru. All information provided within El Fondo is strictly for educational purposes and is provided on an 'as-is' basis without any warranties. It does not constitute professional, legal, or financial advice. We are currently in the process of setting up an entity in Latin America and will inform you about any updates related to it.

Contact point: Valeria Morote - valeria(at)el-fondo.com

Support/privacy: Friedrich Roesel - friedrich(at)el-fondo.com

2. Other documents

These Terms incorporate by reference:

If you participate in a promotion, challenge, giveaway, contest, or similar campaign, it will be governed by separate Promotion/Contest Rules (if provided). If there is a conflict, the Promotion/Contest Rules apply only to that campaign.

3. Children and Sensitive Data

This Website is not directed towards individuals under the age of 18. We do not knowingly collect personal information from individuals below the age of 18. We also do not knowingly collect sensitive personal data, such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data used for identification, health data, or data concerning sex life or sexual orientation (and any other categories treated as sensitive under applicable law). If you believe we have inadvertently collected such information, please contact us immediately so that we can delete it or, where required and appropriate, obtain a valid legal basis (including explicit consent).

If you create an account, you agree to:

  • provide accurate information and keep it up to date;
  • keep your credentials confidential; and
  • be responsible for activity under your account.

You must promptly notify us if you suspect unauthorized access.

4. What the Service is (education, simulation, and information)

The Service may include educational content, market information, simulated portfolios, rankings, watchlists, calculators, and performance metrics.

Unless we explicitly state otherwise in writing:

  • the Service is not a broker, not a custodian, and does not execute real-money trades;
  • any portfolio performance, rankings, and analytics may be simulated, delayed, estimated, or derived using methodology choices; and
  • the Service is provided for informational and educational purposes only.

5. No financial advice; no offer or solicitation

El Fondo does not provide investment advice, recommendations, research, or personalized suitability assessments, and does not act as an investment adviser. El Fondo is not a financial entity regulated by the SMV (Peru), CMF (Chile), CNBV (Mexico), or CVM (Brazil). Our content has not been reviewed by these authorities. El Fondo provides information and educational tools and does not provide personalized advice or recommendations.

RISK WARNING: The value of investments can fall as well as rise. You may get back less than you invested. Investing in any asset could lead to a total loss of your capital. Furthermore, in certain cases - such as trading with leverage or margin - losses may exceed your initial deposit, requiring you to pay additional fund.

Nothing on the Service constitutes an offer, solicitation, or recommendation to buy or sell any security, cryptocurrency, or other asset. You are solely responsible for your decisions. Past performance does not guarantee future results. Additionally, some brokers offer derivative financial instruments such as CFDs. These are complex products and carry a high risk of rapid losses due to leverage. Most retail investor accounts lose money when trading CFDs. Make sure you understand how CFDs work and consider whether you can afford the high risk of losing your money. If you need advice, consult a licensed professional.

6. Affiliate & Paid Partnership Disclosure

The Service includes affiliate links to third-party brokers and platforms (specifically on asset-related pages). These links are used strictly to fund and maintain the ongoing operations of our platform, allowing us to provide our educational content at no cost to you.

This means that if you click on a link and subsequently open an account or perform a transaction, El Fondo may receive a referral fee or commission at no additional cost to you.

We prioritize educational integrity; however, you should be aware that such compensation may influence the placement or order in which these partners appear on our site. El Fondo does not provide personalized recommendations, and the existence of an affiliate relationship does not constitute an endorsement of the broker's suitability for your specific financial situation.

7. Third-party services, links, and partners (including affiliates)

The Service may contain links to third-party websites, products, or services (e.g., brokers, exchanges, platforms). Those third parties operate under their own terms and privacy policies, and El Fondo does not control them.

Affiliate / paid partnership disclosure: We may receive compensation (e.g., referral fees) if you click a partner link and open an account, subscribe, or purchase a product. Compensation may affect how partners are displayed (e.g., placement or prominence). This does not change that El Fondo does not provide financial advice.

8. Data sources and accuracy

Market data, prices, charts, and other information may be provided by third parties (including but not limited to FMP or Financial Modeling Prep). We do not guarantee that any information is accurate, complete, timely, or error-free. Delays, outages, and discrepancies can occur.

Institutional Portfolio Data: The Service displays information regarding the portfolios of institutional investment managers. This information is derived from public regulatory filings, specifically Form 13F, filed with the U.S. Securities and Exchange Commission (SEC). El Fondo acts solely as a platform to visualize this public data; we do not verify the current accuracy of these holdings, which are typically reported with a significant time lag and may not reflect the current positions of the managers.

To the extent the Service displays "real-time" information, it may still be subject to latency or provider limitations.

9. Acceptable use

You agree not to (and not to assist others to):

  • access or use the Service in a way that violates applicable laws or infringes third-party rights;
  • use bots, scrapers, or automated means to access the Service without our permission;
  • interfere with, disrupt, or reverse engineer the Service or its security features;
  • attempt to gain unauthorized access to accounts, systems, or data;
  • upload malware or misuse the Service to harm others; or
  • manipulate metrics, rankings, referrals, or other integrity mechanisms.

We may implement reasonable technical measures to protect the Service and users.

10. User content

If the Service allows you to submit content (e.g., feedback, messages, profile information, comments) ("User Content"), you:

  • remain responsible for your User Content and represent you have the rights to submit it; and
  • grant El Fondo a worldwide, non-exclusive, royalty-free license to host, store, reproduce, and display User Content only as necessary to operate and improve the Service and to enforce these Terms.

We may remove User Content that violates these Terms or applicable law.

11. Intellectual property

The Service (including software, design, trademarks, text, graphics, and other content) is owned by El Fondo or its licensors and protected by intellectual property laws.

We grant you a limited, non-exclusive, non-transferable, revocable license to use the Service for your personal, non-commercial use, subject to these Terms.

Third-Party Trademarks & Logos: All third-party logos, trademarks, and service marks (including those of publicly traded companies, asset managers, and financial institutions) displayed on the Service are the property of their respective owners. Their use on El Fondo is strictly for nominative, identification, and educational purposes—specifically to identify the entity associated with certain financial data or public filings.

Unless explicitly stated otherwise (such as in our Affiliate & Paid Partnership Disclosure), the display of these marks does not imply any affiliation with, endorsement by, or sponsorship by the respective trademark owners. El Fondo is not a partner of the institutional managers whose public 13F data we visualize.

12. Suspension and termination

We may suspend or terminate your access (or particular features) if we reasonably believe:

  • you violated these Terms;
  • your use creates risk for the Service, other users, or third parties; or
  • suspension/termination is required for security, legal, or regulatory reasons.

You may stop using the Service at any time. Sections that by nature should survive will survive termination (e.g., IP, disclaimers, limitation of liability).

13. Disclaimers

THE SERVICE IS PROVIDED "AS IS" AND "AS AVAILABLE." TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE DISCLAIM ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT.

WE DO NOT WARRANT THAT THE SERVICE WILL BE UNINTERRUPTED, SECURE, OR ERROR-FREE.

Nothing in these Terms affects statutory rights that you cannot waive, including mandatory consumer protection rights.

14. Limitation of liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW, EL FONDO WILL NOT BE LIABLE FOR INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, OR FOR LOSS OF PROFITS, REVENUE, DATA, OR GOODWILL, ARISING OUT OF OR RELATED TO YOUR USE OF THE SERVICE.

EL FONDO'S TOTAL LIABILITY FOR ANY CLAIM RELATING TO THE SERVICE WILL NOT EXCEED THE AMOUNT YOU PAID US (IF ANY) TO USE THE SERVICE IN THE 12 MONTHS BEFORE THE EVENT GIVING RISE TO THE CLAIM.

Nothing in these Terms limits liability for intent, gross negligence, or for damages resulting from injury to life, body, or health, or any liability that cannot be excluded under mandatory law.

Nothing in these Terms limits liability that cannot be excluded under mandatory law (including applicable consumer rights). These limitations apply only to the maximum extent permitted by law and do not limit non-waivable consumer rights or liability that cannot be excluded under applicable law.

15. Changes to the Service or Terms

We may modify the Service or update these Terms. Updated Terms will be posted at T&C and apply from the "Last updated" date.

If changes materially affect your rights, we will provide additional notice where feasible (e.g., in-product notice or email, if we have it).

16. Governing law and disputes

These Terms are governed by the laws of the Federal Republic of Germany, unless mandatory laws of your country of residence (including consumer protection laws) require a different law to apply.

If you are a consumer resident in Mexico, Chile, Peru, or Brazil, you may bring claims in your country of residence, and mandatory local rules on jurisdiction and venue will apply. In all other cases, disputes arising out of or in connection with these Terms shall be submitted to the courts of Frankfurt am Main, Germany.

17. Data Protection

We process data in accordance with the GDPR (European Union), Law No. 29733 (Peru), Law No. 13.709/2018 (LGPD - Brazil), the LFPDPPP (Mexico), and Law No. 19.628 (Chile)

In accordance with the Peruvian Personal Data Protection Law (Law No. 29733), all personal data collected through the Service is stored in a private database. El Fondo is currently in the process of formally registering its personal data banks with the National Registry for the Protection of Personal Data (Registro Nacional de Protección de Datos Personales).

Users may exercise their rights of access, rectification, cancellation, and opposition by contacting us at valeria(at)el-fondo.com. Personal data may be stored and processed on servers located in the United States (including but not limited to Customer.io) and/or the European Union or other jurisdictions in or outside of Latin America. Where applicable law requires it, we will implement appropriate safeguards for international data transfers (such as contractual protections with our service providers) and/or rely on other lawful transfer mechanisms and legal bases permitted under applicable data protection laws. Please refer to the cookie policy for any further information.

Disclosure to Third Parties: To provide the Service, we share personal data with trusted third-party service providers (processors), such as but not limited to email delivery platforms (e.g., Customer.io), hosting providers, and analytics services. These third parties are contractually obligated to protect your data and may only process it according to our instructions. Some of these providers are located outside of Peru, Chile, Brazil, Mexico or the European Economic Area (EEA). We disclose personal data to such providers only as necessary to operate the Service, under written agreements requiring confidentiality, security, and processing only on our instructions, and using lawful bases and transfer mechanisms recognized by applicable law. Under certain circumstances, those third parties may be allowed this consent to reach out to you directly for marketing purposes.

Third-party service providers may only contact you for marketing where you have provided a valid opt-in (where required by law) or where otherwise permitted under applicable law. You can opt out of marketing communications at any time using the unsubscribe link in our messages or by contacting us.

18. Virtual Complaints Book

Please submit complaints via our Virtual Complaints Book.