Privacy Policy

Introduction

This Privacy Policy explains how Fondo Claro ("we", "us", or "our") collects, uses, shares, and protects personal data when you visit our website and interact with our services. Fondo Claro is operated by Carlos Méndez Rivera from Calle López Cotilla 1540, Colonia Americana, 44160 Guadalajara, Jalisco, México. You can contact us by email at [email protected] or by phone at +52 33 4172 9085.

Scope

This policy applies to personal data collected through our website and forms, including course registrations and contact requests. It covers cookies and tracking technologies used for site functionality, analytics, and advertising. It does not apply to information collected offline or by third parties unrelated to our services.

SECTION 1: COOKIE CATEGORIES

1. ESSENTIAL COOKIES

Purpose: core site functionality, security, session management. Examples: session_id, csrf_token, cookie_consent_status. Consent required: NO — activated automatically. Retention: session duration or up to 12 months for preference storage.

2. ANALYTICS COOKIES

Purpose: measuring traffic, user behavior, site performance. Tools: Google Analytics 4. Examples: _ga, _ga_XXXXXXX, _gid, _gat. Consent required: YES — activated only after user accepts. Retention: up to 14 months.

3. MARKETING / ADVERTISING COOKIES

Purpose: remarketing, personalized ad delivery, conversion tracking. Consent required: YES — activated only after user accepts. Retention: up to 540 days (Google Ads default).

SECTION 2: MARKETING COOKIES — MANDATORY SUB-DISCLOSURES

a) Third-party ad serving:

"Third-party vendors, including Google, use cookies to serve ads based on a user's previous visits to this website and other sites on the internet."

b) Advertising partners:

"We may work with advertising partners such as Google and Meta to deliver advertisements tailored to your interests across various websites and platforms."

c) Remarketing:

"We may use remarketing services to advertise to previous visitors of our website. After visiting our site, you may see our ads on other websites, apps, or platforms you visit."

d) YouTube and Display Network:

"Advertisements may appear across Google services including YouTube, Gmail, and the Google Display Network."

e) Tracking technologies — list ALL that apply:

"We use the following tracking technologies on this website: - Cookies (first-party and third-party) - Tracking pixels (Google Ads tag / gtag.js, Meta Pixel) - Device identifiers (browser fingerprint, IP address) - Conversion event tags"

f) Advertising measurement:

"We use conversion tracking to understand which advertisements lead to actions on our website — such as form submissions, calls, or purchases. This allows us to measure campaign effectiveness and allocate budget appropriately. Conversion data may be shared with Google Ads and Meta."

g) Technologies in use — list explicitly:

"Advertising and analytics technologies active on this site: - Google Ads (gtag.js / Google Tag Manager) - Google Analytics 4 - Google Remarketing Tag - Meta Pixel (Facebook / Instagram)"

h) Opt-out from personalized advertising:

"You may opt out of personalized advertising at any time: - Google Ads Settings: https://adssettings.google.com - Your Online Choices (EU): https://www.youronlinechoices.eu - Network Advertising Initiative: https://optout.networkadvertising.org - Digital Advertising Alliance: https://optout.aboutads.info Opting out does not remove ads entirely — you will continue to see non-personalized advertisements."

i) Cookie preference management:

A visible option labeled "Manage cookie preferences" is available in the site footer and cookie banner to open the cookie preferences panel where users can accept or reject categories independently.

SECTION 3: CONSENT REQUIREMENTS

Consent banner behavior:

• Offers three options: "Accept All", "Reject Non-Essential", "Manage Preferences".
• Analytics and marketing cookies are not activated until the user grants consent by selecting Accept All or enabling categories in Manage Preferences.
• Choice is stored in localStorage for 12 months.
• Banner is dismissible without accepting; rejecting leaves only essential cookies active.
• Banner includes a link to this Privacy Policy at /privacy/.

Consent statement:

"By clicking 'Accept All Cookies', you consent to the storing of cookies on your device for analytics and advertising purposes, including personalized advertising delivered by Google and Meta. You may withdraw consent at any time through the cookie preferences panel without affecting the lawfulness of processing that occurred before withdrawal."

EEA / UK users:

"Users in the European Economic Area and the United Kingdom receive this consent notice in compliance with the General Data Protection Regulation (GDPR) and UK GDPR. Marketing and analytics cookies are activated solely after explicit, informed, freely given consent under GDPR Article 6(1)(a). Consent is recorded with a timestamp and may be audited upon request."

Withdrawal of consent:

"You may withdraw consent at any time by clicking 'Manage cookie preferences' in the website footer, or by clearing cookies via your browser settings. Withdrawal does not affect processing that occurred while consent was valid."

SECTION 4: DATA SHARING WITH ADVERTISING PARTNERS

Data Sharing with Advertising Partners

We share certain data with advertising partners for campaign delivery and measurement. Recipients and the data categories shared include:

• Google LLC: cookie identifiers, conversion events, anonymized behavioral data, remarketing lists. Governed by Google's Privacy Policy: https://policies.google.com/privacy
• Meta Platforms, Inc.: pixel events, conversion data, custom audiences. Governed by Meta's Data Policy: https://www.facebook.com/privacy/policy

We do not sell personal data. All transfers to Google and Meta operate under Standard Contractual Clauses where applicable. Data is processed for ad targeting and campaign measurement only — not resold to unaffiliated third parties.

Google and Meta may use this data across their own platforms in accordance with their respective policies. We encourage users to review those policies directly.

SECTION 5: LEAD FORMS AND CONTACT REQUESTS

Lead Forms and Contact Requests

When you submit a contact form, request a quote, or register interest in our services such as the Fondo Claro course, we collect the information you provide. This typically includes: full name, email address, phone number, and your message.

Legal basis: consent (GDPR Art. 6.1.a) and, where a service relationship exists, performance of a contract (GDPR Art. 6.1.b).

Retention: form submission data is retained for up to 2 years from the date of submission, unless a longer period is required by applicable law.

You may request deletion of your data at any time by contacting us at [email protected].

A link to this Privacy Policy appears adjacent to every submission button on this site. Submitting a form constitutes acknowledgment of this policy.

SECTION 6: GOOGLE SERVICES — FULL DISCLOSURE

Google Services and Advertising

• Google Analytics 4: collects anonymized usage data, device info, and behavioral signals. IP anonymization is enabled. Data retention is set to 14 months. Users may opt out via the Google Analytics Opt-out Browser Add-on: https://tools.google.com/dlpage/gaoptout
• Google Ads Conversion Tracking: records when a user completes a defined action (form submission, call, purchase) after clicking one of our ads. This data is used solely for measuring ad campaign performance.
• Google Remarketing: allows us to show ads to previous visitors across Google's network. Remarketing lists are not created from sensitive data categories (health, finance, religion, sexual orientation).
• Google Tag Manager: deploys tracking tags on our behalf. No personal data is collected by GTM itself; it acts as a container for the tags listed above.

Google's advertising products are governed by: https://policies.google.com/technologies/ads

SECTION 7: META ADVERTISING SERVICES — FULL DISCLOSURE

Meta Advertising Services

This website uses the Meta Pixel to measure the effectiveness of our advertising on Facebook and Instagram. The pixel may record:

• Page views and time on site
• Specific conversion events (form submissions, purchases)
• Custom audience membership for retargeting purposes

We do not use the Meta Pixel to collect sensitive personal data, nor to target users based on health status, financial situation, religion, political views, sexual orientation, or any other special-category attribute prohibited under Meta's advertising policies.

Meta acts as an independent data controller for data collected via its Pixel and processed within its own platform. Refer to Meta's Data Policy: https://www.facebook.com/privacy/policy

To manage your ad preferences on Meta platforms, visit: https://www.facebook.com/adpreferences/

SECTION 8: PROHIBITED CONTENT SELF-DECLARATION

This website does not promote, sell, or facilitate access to prohibited product or service categories including but not limited to: weapons, controlled substances, counterfeit goods, gambling services (unlicensed), adult content, or services that make misleading health or financial claims. All advertising conducted through Google Ads and Meta Ads complies with the respective platform policies in full.

SECTION 9: LANDING PAGE INTEGRITY STATEMENT

The content of this website accurately represents the products and services advertised. No bait-and-switch practices are employed. The experience delivered to users arriving from paid advertisements is identical to the experience for all other visitors. Cloaking, automatic redirects, and content variation by traffic source are not used on this website.

SECTION 10: CHILDREN'S PRIVACY

This website is not directed at individuals under the age of 16. We do not knowingly collect personal data from minors. If we discover that data has been collected from a person under 16 without verifiable parental consent, we will delete it promptly. Contact us at [email protected] if you believe we have received data from a minor.

SECTION 11: INTERNATIONAL DATA TRANSFERS

Personal data collected through this website may be transferred to and processed in countries outside the European Economic Area, including the United States, where Google LLC and Meta Platforms, Inc. are based.

These transfers are conducted under Standard Contractual Clauses (SCCs) approved by the European Commission, which provide appropriate safeguards for personal data. A copy of the applicable SCCs can be requested by contacting us directly at [email protected].

SECTION 12: USER RIGHTS (GDPR ARTICLES 15-22)

If you are located in the EEA or UK, you have the following rights:

• Access (Art. 15): request a copy of data we hold about you
• Rectification (Art. 16): correct inaccurate or incomplete data
• Erasure (Art. 17): request deletion ('right to be forgotten')
• Restriction (Art. 18): limit how we process your data
• Portability (Art. 20): receive your data in a structured, machine-readable format
• Objection (Art. 21): object to processing based on legitimate interest
• Withdraw consent (Art. 7.3): revoke consent at any time without penalty

To exercise any right, email us at [email protected]. We will respond within 30 days. You also have the right to lodge a complaint with your local supervisory authority: - EU users: https://edpb.europa.eu - UK users: https://ico.org.uk

SECTION 13: WHAT DATA WE COLLECT

We may collect the following categories of data:

• Full name
• Email address
• Phone number
• IP address
• Browser type and version
• Device type and operating system
• Cookies and tracking identifiers
• Usage data (pages visited, time on site, click paths)
• Form submission content
• Conversion events (form submits, calls, purchases)

SECTION 14: LEGAL BASIS FOR PROCESSING (GDPR ART. 6)

We process personal data on the following legal bases:

• Contact form data: consent (Art. 6.1.a) and contract performance (Art. 6.1.b)
• Analytics data: consent (Art. 6.1.a)
• Marketing/remarketing data: consent (Art. 6.1.a)
• Security and fraud prevention: legitimate interest (Art. 6.1.f)

SECTION 15: RETENTION PERIODS

We retain personal data for the following periods unless a longer retention period is required by law:

• Contact form submissions: 2 years
• Analytics data (GA4): 14 months
• Marketing cookies (Google Ads): up to 540 days
• Email communications: duration of relationship + 1 year
• Server logs: 90 days
• Cookie consent records: 3 years (audit requirement)

SECTION 16: POLICY METADATA

Last Updated: January 15, 2026

Effective Date: January 15, 2026

Changes will be notified via a homepage banner at least 14 days before taking effect.

This Privacy Policy is written in clear language and provides information about our practices regarding data collection and processing. If you have questions, contact us at [email protected] or write to Calle López Cotilla 1540, Colonia Americana, 44160 Guadalajara, Jalisco, México.

Additional operational notes

We use reasonable technical and organizational measures to protect personal data, including encryption in transit and restricted access to systems. We retain records of cookie consent for audit purposes and implement mechanisms to honor user preferences for analytics and marketing cookies. If you wish to request deletion, access, or portability of your data, contact [email protected]. We will respond within the statutory timeframe.