1. Data Controller Identification
The data controller for personal data collected through this digital portal is SIPDOLCE SAS, a commercial corporation identified with Tax ID (NIT) 901871840-5, registered with the Chamber of Commerce of Bogotá, Republic of Colombia.
Data handling operations adhere strictly to Colombian Statutory Law 1581 of 2012, Regulatory Decree 1377 of 2013 (compiled in Single Regulatory Decree 1074 of 2015), and international privacy-by-design and data minimization standards.
2. Purpose and Specific Processing per Active Form
SipDolce Labs processes personal data solely through enabled web outreach forms, strictly limiting collection to information essential for declared technical purposes:
2.1. Technical Collaboration Form (/colaborar/ and /en/collaborate/)
- Data fields: Full name, institutional or personal email, phone or WhatsApp (optional for direct coordination), affiliated farm or company (optional), selected collaboration pathway, and technical scope message.
- Purpose: Evaluating research feasibility, verifying laboratory capacity, and establishing direct institutional contact.
- Legal basis: Explicit, prior, and informed consent recorded via required checkbox verification prior to form submission.
- Non-marketing phone guarantee: Any telephone or WhatsApp number voluntarily provided is strictly used for bilateral liaison regarding the proposal and will never be enrolled in automated broadcast campaigns or unsolicited messaging.
2.2. Institutional Contact Form (/contacto/ and /en/contact/)
- Data fields: Full name, institutional or personal email, phone or WhatsApp (optional), organization (optional), subject of inquiry, and message.
- Purpose: Routing general questions, technical liaison, and scientific outreach to the responsible laboratory department.
- Legal basis: Explicit consent registered upon submission.
- Privacy guarantee: Phone numbers are kept confidential within our offline storage and are never used for unsolicited communications.
2.3. Editorial Newsletter Form (/media/ and /en/media/)
- Data fields: Email address.
- Purpose: Periodic distribution of coffee science research papers, Journal entries, and Media Lab multimedia updates.
- Legal basis: Voluntary consent of the subscriber, with instant opt-out revocation rights available at any time.
3. Storage Architecture: "Save First → Automate After"
In alignment with the DCP Flow engineering blueprint, form intake at SipDolce Labs follows an atomic persistence architecture:
- Decoupled ingestion: Forms submit HTTP POST requests to isolated companion PHP endpoints (`/api/proposal-intake.php` and `/api/lead-intake.php`).
- Private local storage: Submissions are written atomically into a relational SQLite database configured with WAL mode outside the public web document root (`backend/storage/submissions.sqlite`).
- Consent audit logging: Every record immutably captures an ISO 8601 UTC timestamp, the active policy version (`consent_revision: privacy-v1.0`), the source route, and affirmative consent verification.
- Idempotency controls: Deterministic RFC 9562 UUIDv7 identifiers paired with SHA-256 payload hashes prevent duplicate database entries caused by client-side network interruptions.
4. Clear Boundary: Active vs. Future Integrations
To ensure absolute transparency and prevent misleading claims regarding data telemetry, our architectural boundaries are defined as follows:
4.1. Active MVP integration (Currently in production)
Upon form validation, the backend records the submission atomically into `form_submissions` and simultaneously creates an outbox event in `integration_outbox` (`proposal.created` or `newsletter.subscribed`). Personal data is safely quarantined within our local private infrastructure.
4.2. Decoupled asynchronous worker (n8n)
A dedicated CLI worker (`dispatch-outbox.php`) asynchronously queries pending outbox events and dispatches canonical JSON payloads to authenticated n8n webhooks via Bearer token, strictly separated from user web traffic.
4.3. Future integrations (EspoCRM)
Automated synchronization with an internal EspoCRM instance represents a subsequent phase integration. In this MVP, NO direct or synchronous connection to any external CRM exists.
4.4. Web analytics subject to prior consent (Google Analytics 4)
Audience measurement across the portal operates via Google Analytics 4 (G-E5RGSD3F5W) under Google Consent Mode v2, exclusively activated upon explicit user consent via the cookie banner. Analytics telemetry remains entirely decoupled from contact forms and with all advertising capabilities disabled.
5. Absolute Prohibition on Data Commercialization
SIPDOLCE SAS enforces a strict no-sale policy:
- We do NOT sell, rent, license, or exchange personal data with third-party advertisers, ad networks, or commercial data brokers.
- Information is accessible only to authorized lab personnel bound by professional non-disclosure agreements.
6. Retention Periods and Data Subject Rights
Personal data is retained solely for the period necessary to review and execute technical collaborations (maximum 24 months), or until the data subject requests deletion.
Data subjects hold statutory rights to access, update, rectify, and suppress their personal records, as detailed in our Habeas Data Manual.