Privacy policy

01Who is responsible for your data

D-Legacy SAS, a company incorporated in Ecuador and based in Quito, is the controller of the personal data it receives through dalekicapital.com, the LOBO assistant, The Letter and the contact channels of Daleki Capital, a Daleki Global brand.

Contact for anything related to your data: dalekicapital@gmail.com or +593 99 785 4652. We process your data under Ecuador’s Organic Law on Personal Data Protection (LOPDP) and its General Regulation.

02What data we process and why

Contact form: name, email, company and country if you provide them, the type of inquiry and your message. We use them to reply and we send you a confirmation email. If you request private access to a fund, they are also recorded as a prospect to prepare the profile conversation.

The Letter: your email, language, the date and exact wording of the consent you accepted with its version, where you subscribed from and a code to unsubscribe. We use them only to send you The Letter and related communications, and to record which issues you received.

LOBO: your messages are processed to generate the answer. If you choose to give it your name, email, phone, country, fund of interest, risk profile, horizon, estimated amount or notes, they are recorded as a prospect, we notify the team by email so a manager can contact you and we send you a confirmation.

Account: if you sign in, we process your email and name, and the basic profile data Google shares if you choose to sign in with Google.

WhatsApp and email: if you write to us through those channels, we use what you send to reply. Those services also apply their own policies.

Technical data: your IP address is used temporarily to limit abuse of the forms and the chat. We do not store it with your name or use it to identify you.

03On what legal basis

Your consent: for The Letter, for site analytics and to answer the inquiries and messages you send us on your own initiative. You can withdraw it at any time, without retroactive effect.

Pre-contractual measures at your request: when you request private access or leave your details so a manager can contact you.

Contractual relationship: to manage your account and, if you invest, whatever your contract provides.

Legitimate interest: to protect the site against abuse and attacks, with the minimum data needed.

Legal obligation: when a law requires us to keep or hand over information.

04LOBO and artificial intelligence

LOBO answers are generated automatically with third-party language models, based on public information about Daleki Capital. No one on the team reads the chat in real time and the conversation is not stored on our servers: it stays only in your browser while the tab is open. What we do keep is the contact data you choose to leave.

We do not make decisions based solely on automated assessments that produce legal effects on you. LOBO does not decide whether a fund is right for you: a person on the team makes that assessment in the profile conversation.

05Who else is involved

Providers that process data on our behalf and only to deliver their service to us: Vercel (site hosting and cookieless analytics), Supabase (database, accounts and files), Resend (email delivery, including The Letter), Google (Gmail, the inbox where the team receives your messages and prospect alerts), and OpenRouter, Anthropic, OpenAI and Vercel AI Gateway (processing LOBO messages and searching our knowledge base).

Third parties with their own policies, only if you use them: Google, if you sign in with your Google account, and Meta, if you write to us on WhatsApp.

Market data from Binance and CoinGecko is requested from our server without sending your IP address, cookies or other browser data to those providers. Editorial images are generated with Fal without personal data.

We do not sell your data or share it with third parties for advertising.

06Data outside Ecuador

Several of these providers process data outside Ecuador: in the United States (Vercel, Resend, Google, OpenRouter, Anthropic, OpenAI) and in Ireland, within the European Union, where our Supabase database is hosted. Vercel serves visits from its global server network.

We send them only the data each service needs and work with providers that take on contractual commitments of confidentiality, security and limited use of the data. If a law requires an additional mechanism for any of these flows, we will apply it.

07How long we keep them

Inquiries and prospects: while the conversation remains open and up to 24 months from the last contact if we do not sign a contract. If you invest, your data is then governed by your contract and by the periods the law requires.

The Letter: while you remain subscribed. When you unsubscribe we stop sending immediately and keep only your email, the unsubscribe date and the record of your consent, to respect your decision and to be able to show how it was obtained.

Account: while it is active or until you ask us to delete it.

LOBO chat: only in your browser, until you close the tab. Language model providers may retain messages for a limited time under their terms, for example to prevent abuse.

IP addresses for abuse control: deleted automatically once the control window expires, usually within a few hours. Hosting technical logs are kept for the limited time the provider sets.

08Your rights

You can request access to your data, its correction and update, its deletion, object to its processing, request its portability, request the suspension of processing and not be subject to decisions based solely on automated assessments. You can also withdraw your consent whenever you want.

Email us at dalekicapital@gmail.com with your name, the right you want to exercise and the data concerned. If we need to confirm you are the data subject, we will ask for an identity document. It is free and we reply within ten business days at most. If your request needs clarification, we will tell you once at the start.

If you disagree with the answer or do not receive it on time, you can file a complaint with Ecuador’s Superintendency for Personal Data Protection (spdp.gob.ec).

09How we protect your data

The site runs only over encrypted connections (HTTPS with HSTS). The database enforces row-level security, so prospect and subscriber information is only accessible to authenticated administrators. Service keys live in an environment variable manager and we avoid writing personal data to technical logs.

If a security breach affects your data, we will notify Ecuador’s Superintendency for Personal Data Protection and, when there is a risk to your rights, you as well, within the terms set by law.

10Minors

The site and our funds are intended for people over 18. We do not knowingly collect data from minors; if we find we have received it, we delete it.

11Cookies and browser storage

We only use cookies and storage needed for the site to work (language, theme, your cookie choice, the LOBO conversation during the session and, if you sign in, your session). Site analytics, which uses no cookies, only runs if you accept it. We do not use advertising or cross-site tracking cookies. The details are in the Cookie policy.

12Changes to this policy

This is version 2026-10-09, dated above. With every subscription to The Letter we store the version in force when you subscribed. If we make a material change, we will announce it visibly on the site and by email to subscribers, and if the change requires new consent, we will ask for it.