Privacy Policy

This Privacy Policy explains how Fondo Inc ("Fondo," "we," "us," or "our") collects, uses, discloses, and protects your personal information when you visit our website at tryfondoinc.com (the "Website"), contact us, or otherwise interact with us in connection with our venture capital business activities. Please read this Policy carefully.

1. Who We Are and How to Contact Us

Fondo Inc is a venture capital firm organized under the laws of the State of Delaware with its principal office at 1200 Park Avenue, Suite 450, New York, NY 10065, United States.

For privacy-related inquiries, you may contact us as follows:

• Privacy Team: privacy@tryfondoinc.com
• Data Protection Officer: dpo@tryfondoinc.com
• EU Representative: eu-privacy@tryfondoinc.com
• UK Representative: uk-privacy@tryfondoinc.com
• Postal Address: Fondo Inc, Attn: Privacy Team, 1200 Park Avenue, Suite 450, New York, NY 10065

2. Information We Collect

2.1 Information You Provide Directly

We collect information that you provide directly to us, including:

• Contact and Identity Information: Your name, email address, phone number, and mailing address when you contact us, submit a pitch, or communicate with our team.
• Business Information: Company name, website, business description, funding stage, financial metrics (ARR, growth rate), team composition, and other information about your business that you share when submitting a pitch or engaging in investment discussions.
• Professional Information: Your title, employer, professional experience, educational background, and other professional details that you share in your capacity as a founder, executive, or business contact.
• Communications: The content of emails, messages, and other communications you send to us, including pitch materials, presentations, and supporting documents.
• Meeting and Event Information: Information about your attendance at events, conferences, or meetings where we interact with you, including any business cards or contact information exchanged.

2.2 Information We Collect Automatically

When you visit our Website, we automatically collect certain technical information, including:

• Log Data: Your IP address, browser type and version, operating system, the pages of our Website you visit, the time and date of your visit, and the time spent on each page.
• Device Information: Information about the device you use to access our Website, including hardware model, operating system, and unique device identifiers.
• Usage Data: Information about how you interact with our Website, including which pages you visit, which links you click, and which features you use.
• Location Data: General geographic location based on your IP address.
• Cookie Data: Information collected through cookies and similar tracking technologies as described in our Cookie Policy.

2.3 Information from Third Parties

We may receive information about you from third parties, including:

• Business partners, co-investors, and advisors who refer founders or business contacts to us
• Publicly available sources, including company databases, professional networking sites (such as LinkedIn), news sources, and public filings
• Due diligence and background check service providers that we engage in connection with investment evaluation
• Portfolio company founders and executives who share information about contacts in connection with potential introductions or co-investment opportunities
• Analytics and data enrichment providers who supplement the contact information you provide with additional publicly available professional information

3. How We Use Your Information

3.1 Investment Activities

We use personal information to evaluate potential investments and manage our investment portfolio, including:

• Reviewing and assessing founder pitches and investment opportunities
• Conducting due diligence on potential portfolio companies and their founding teams
• Communicating with founders, executives, and other stakeholders in connection with investment evaluation and monitoring
• Managing our ongoing relationships with portfolio companies
• Supporting portfolio companies with introductions, co-investment opportunities, and other value-add activities

3.2 Business Operations

• Operating, maintaining, and improving our Website
• Managing relationships with limited partners, co-investors, and advisors
• Organizing and facilitating events, conferences, and meetings
• Maintaining accurate records of our business contacts and interactions
• Analyzing our investment pipeline and portfolio performance

3.3 Communications and Marketing

• Responding to your inquiries and providing information you request
• Sending newsletters, investment insights, market commentary, and other content that we believe may be of interest to you (with your consent where required)
• Notifying you about updates to our terms, policies, or Website

3.4 Legal and Compliance Purposes

• Complying with applicable laws and regulations, including securities laws and anti-money laundering requirements
• Responding to legal process and lawful requests from government authorities
• Enforcing our legal rights and the rights of our partners and portfolio companies
• Preventing fraud, unauthorized access, and other security incidents

4. Legal Basis for Processing (GDPR)

For individuals located in the European Economic Area (EEA), the United Kingdom, or Switzerland, our processing of your personal information is based on the following legal bases under the General Data Protection Regulation (GDPR) and applicable national implementing legislation:

Processing Activity	Legal Basis	GDPR Article
Investment evaluation and due diligence	Legitimate interests in conducting investment activities	Art. 6(1)(f)
Responding to founder pitch submissions	Performance of a contract / pre-contractual steps	Art. 6(1)(b)
LP and investor relationship management	Performance of a contract; legitimate interests	Art. 6(1)(b)(f)
Marketing and newsletters	Consent (where required); legitimate interests	Art. 6(1)(a)(f)
Legal and regulatory compliance	Legal obligation	Art. 6(1)(c)
Website analytics	Legitimate interests in improving our services	Art. 6(1)(f)

5. How We Share Your Information

5.1 Within Fondo Inc

Personal information is shared among Fondo Inc investment professionals, advisors, and administrative staff who have a legitimate need to access it in connection with our investment activities, portfolio management, or business operations.

5.2 With Third-Party Service Providers

We engage third-party service providers who process personal information on our behalf, including:

• Technology and software providers (CRM systems, data analytics platforms, email service providers)
• Professional services firms (legal counsel, auditors, due diligence specialists)
• Background check and reference checking services
• Event management and hospitality providers
• Cloud computing and data storage providers

All third-party service providers are contractually obligated to use personal information only for the purposes for which we have engaged them and to maintain appropriate security measures.

5.3 With Co-Investors and Business Partners

In connection with specific investment opportunities, we may share founder and company information with co-investors, advisors, and other business partners who have agreed to keep such information confidential and use it only for investment evaluation purposes.

5.4 For Legal Reasons

We may disclose personal information if required to do so by law, court order, regulatory requirement, or other legal process, or if we believe in good faith that disclosure is necessary to protect our rights, your rights, or the rights of others, or to prevent fraud, illegal activity, or threats to safety.

5.5 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of all or substantially all of our assets, personal information held by us may be among the assets transferred. We will notify you of any such change in ownership or control of your personal information.

6. International Data Transfers

Fondo Inc is headquartered in the United States. If you are located outside the United States, your personal information will be transferred to and processed in the United States, which may not provide the same level of data protection as the laws of your home country.

For transfers of personal information from the EEA, UK, or Switzerland to the United States, we rely on the following transfer mechanisms:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• UK International Data Transfer Agreements (IDTAs) where applicable
• The EU-US Data Privacy Framework, to the extent applicable
• Your explicit consent, where other mechanisms are not available

You may request a copy of the safeguards we use for international transfers by contacting our Privacy Team.

7. Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, as described in this Policy, and as required or permitted by applicable law. Our general retention periods are:

• Pitch and due diligence materials (companies we did not invest in): 3 years from last contact
• Portfolio company information: Duration of investment plus 7 years after disposition
• LP and co-investor records: Duration of relationship plus 7 years
• Website analytics data: 26 months
• Marketing communications records: Until you unsubscribe or opt out, plus 3 years
• Legal and compliance records: As required by applicable law, typically 7-10 years

When personal information is no longer required, we securely delete or anonymize it in accordance with our data disposal procedures.

8. Your Privacy Rights

8.1 Rights Under GDPR (EEA, UK, and Switzerland)

If you are located in the EEA, UK, or Switzerland, you have the following rights under applicable data protection law:

• Right of Access (Art. 15): You have the right to request a copy of the personal information we hold about you and information about how we process it.
• Right to Rectification (Art. 16): You have the right to request that we correct inaccurate or incomplete personal information about you.
• Right to Erasure (Art. 17): You have the right to request that we delete your personal information in certain circumstances, such as when it is no longer needed for the purposes for which it was collected.
• Right to Restriction of Processing (Art. 18): You have the right to request that we restrict our processing of your personal information in certain circumstances.
• Right to Data Portability (Art. 20): You have the right to receive personal information you have provided to us in a structured, commonly used, machine-readable format, and to transmit it to another controller.
• Right to Object (Art. 21): You have the right to object to our processing of your personal information where we rely on legitimate interests as our legal basis, including for direct marketing purposes.
• Right to Withdraw Consent (Art. 7): Where we process your personal information on the basis of your consent, you have the right to withdraw that consent at any time.
• Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority in your country of residence.

8.2 Rights Under CCPA (California Residents)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

• Right to Know: The right to request that we disclose what personal information we have collected about you, the categories and purposes of collection, and the categories of third parties with whom we share your information.
• Right to Delete: The right to request that we delete personal information we have collected from you, subject to certain exceptions.
• Right to Correct: The right to request that we correct inaccurate personal information we hold about you.
• Right to Opt Out of Sale or Sharing: The right to opt out of the sale of your personal information or the sharing of your personal information for cross-context behavioral advertising. Fondo Inc does not sell personal information and does not share it for behavioral advertising purposes.
• Right to Limit Use of Sensitive Personal Information: The right to limit our use of sensitive personal information to specified purposes.
• Right to Non-Discrimination: The right not to receive discriminatory treatment for exercising your privacy rights.

To submit a CCPA request, contact us at privacy@tryfondoinc.com or call +1 (212) 555-0182.

9. Security

We implement appropriate technical and organizational measures to protect personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit using TLS/SSL
• Encryption of sensitive data at rest
• Access controls limiting access to personal information to authorized personnel on a need-to-know basis
• Regular security assessments and penetration testing
• Employee training on data protection and security practices
• Incident response procedures for potential data breaches

In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay in accordance with applicable law. We will notify the relevant supervisory authority within 72 hours of becoming aware of a qualifying breach.

10. Cookies and Tracking Technologies

We use cookies and similar tracking technologies on our Website. For detailed information about the cookies we use, their purposes, and how you can manage your preferences, please see our Cookie Policy.

11. Third-Party Websites and Services

Our Website may contain links to third-party websites and services. We are not responsible for the privacy practices of these third parties, and we encourage you to review their privacy policies before providing any personal information. The inclusion of a link on our Website does not constitute an endorsement of the linked website's privacy practices.

12. Children's Privacy

Our Website and services are intended for business professionals and are not directed to individuals under the age of 16. We do not knowingly collect personal information from children under 16. If we learn that we have inadvertently collected personal information from a child under 16, we will promptly delete it.

13. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will notify you by posting a prominent notice on our Website and updating the "Effective Date" at the top of this Policy. For significant changes that affect your rights, we may also notify you by email. Your continued use of our Website following notification of changes constitutes your acknowledgment of the updated Privacy Policy.

14. How to Exercise Your Rights

To exercise any of the privacy rights described in this Policy, or to submit a question or complaint about our privacy practices, please contact us:

• Email: privacy@tryfondoinc.com
• Phone: +1 (212) 555-0182
• Mail: Fondo Inc, Attn: Privacy Team, 1200 Park Avenue, Suite 450, New York, NY 10065

We will respond to your request within 30 days (or within the timeframe required by applicable law). We may need to verify your identity before fulfilling your request. Verification may require you to provide information that we already have on file about you.

15. Supervisory Authority

If you are located in the EEA and believe that we have not addressed your privacy concerns adequately, you have the right to lodge a complaint with the data protection supervisory authority in your country of residence. For individuals in Germany, this is the relevant state data protection authority (Landesbeauftragter). For individuals in France, this is the CNIL. For individuals in the UK, this is the Information Commissioner's Office (ICO).