Legal
Personal Data Policy
How GCR collects, uses, stores and protects personal data — on this website and in research fieldwork — and how you exercise your rights over it under Colombian Law 1581 of 2012.
In force from 25 August 2026
1. Who is responsible for your data
GC Ventures S.A.S. (“GCR”, “we”), a Colombian company registered with the Cámara de Comercio de Medellín under NIT 900.256.843-6, is the data controller — the Responsable del Tratamiento — for the personal data described in this policy.
| Registered address | Cra 42 # 3 Sur 81, Torre 1, Piso 15, El Poblado — Medellín, Colombia |
| Data protection contact | [email protected] |
| Phone | +57 311 278 0813 |
This policy is issued under Law 1581 of 2012, Decree 1377 of 2013 and Decree 1074 of 2015 — Colombia's Habeas Data regime.
2. What this policy covers
GCR processes personal data in two clearly separate ways, and this policy covers both:
- This website — the contact forms, the newsletter signup, and the technical records our hosting provider keeps in order to serve the site. Section 3.
- Research fieldwork — data from the people who take part in our studies, across every methodology we run. Section 4.
The two are kept apart. A research participant is never added to a marketing list, and a website enquiry is never used as a research contact. Data collected for a study is used for that study.
3. The website: what we collect and why
We collect only what you type into a form. There is no hidden collection, no profiling, and no purchase of contact data from third parties.
| Where it comes from | What we collect | Why | Processor |
|---|---|---|---|
| Book a call · Send a brief | First and last name, email, company, job title, mobile number, and what you write in the free-text field. For a brief, also country, methodology, sample size, timeline and budget range. All optional except name, email and the free-text field. | To answer your enquiry, arrange a call, and prepare a proposal. | HubSpot |
| Newsletter | Email address, and first name if you give one. | To send the newsletter you asked for. Nothing else. | EmailOctopus |
| Every form | The date and time you gave authorization, the page you gave it on, and the IP address it came from. | To evidence your authorization, as Law 1581 requires. It is not used to profile you. | HubSpot |
| Visiting the site | Standard server records: IP address, request time, page requested, browser user agent. | To operate the site, diagnose faults and defend against abuse. | Vercel |
This site sets no cookies. We run no analytics, no advertising tags, no tracking pixels and no social media widgets, and we store nothing in your browser. Typefaces are served from our own domain, so viewing a page does not disclose your visit to a font provider. See the Cookies notice.
4. Research fieldwork: participants
If you have taken part in one of our studies — a focus group, an interview, a phone or online survey, a face-to-face intercept or an observational session — this section is the one that applies to you.
GCR is a member of ESOMAR, and fieldwork is conducted under the ICC/ESOMAR International Code on Market, Opinion and Social Research and Data Analytics as well as Colombian law. Two commitments in that code sit above everything else here: participation is voluntary, and what you say is reported so that it cannot be traced back to you.
| Stage | What we collect | Why |
|---|---|---|
| Recruitment and screening | Name, phone number, email, city, and the screening answers a study requires — typically age bracket, gender, household composition, occupation and category usage. | To check whether you qualify for the study and to fill its quotas. Screening data from people who do not qualify is discarded. |
| Focus groups, in-depth interviews, face-to-face | Your responses, and an audio or video recording of the session where you have agreed to it. Attendance records. For face-to-face fieldwork, a photographic and GPS record of the interview location. | To conduct and analyse the session accurately — a recording exists so the analyst works from what you actually said rather than from notes. The location record evidences that the interview took place where and when it is recorded as having taken place. |
| Telephone (CATI) | Your responses, your phone number, and a recording of the call where you have agreed to it. | To conduct the interview and to allow quality control of the interviewer's work. |
| Online (CAWI) | Your responses, email address, and technical metadata: IP address, device and browser, and timestamps. | To conduct the survey and to detect duplicate or fraudulent responses, which is a data-quality safeguard, not profiling. |
| Observational and ethnographic work | Photographs or video of the setting, and of you where you have agreed to it. | To record behaviour in context, which is the point of the method. |
| Incentives | Name, identification number, signature, and payment or transfer details. | To pay you, and to keep the accounting and tax records Colombian law requires of us for that payment. |
| Quality control | A short re-contact — a back-check — with a portion of participants. | To verify the interview took place as recorded. This is required by the ESOMAR code and by our own quality standard. |
What the client receives. Findings are delivered in aggregate. Your name and contact details are not passed to the client, and no answer is attributed to you personally, unless you have separately and explicitly agreed to that — for example where a study includes named expert interviews, or where a verbatim quote or a video clip is to be shown and you have authorized it.
Sensitive data. Some studies ask about matters that Colombian law treats as sensitive under article 5 of Law 1581 — health, for example. Where they do, we tell you so before you answer, your authorization is explicit and separate, and you are never obliged to answer. Declining a sensitive question does not remove you from the study or affect your incentive.
Withdrawing. You may stop at any point, decline any individual question, and ask us to delete your data afterwards. You do not have to give a reason, and it does not affect an incentive you have already earned.
Where the study is commissioned by a client, responsibility may be shared: GCR may act as Encargado del Tratamiento on the client's instructions while the client is the Responsable. The study-specific consent you are given at recruitment states which applies. This policy governs GCR's own handling in either case.
5. Your authorization, and withdrawing it
We process your data because you authorized it — you ticked the consent box before submitting a form, or you gave your consent at the start of a fieldwork session. That authorization is prior, express and informed, as Law 1581 requires, and we record when and how you gave it.
You may withdraw it at any time, without giving a reason and at no cost, by writing to [email protected]. Every newsletter also carries a one-click unsubscribe link. Withdrawing authorization does not affect processing already carried out lawfully before the withdrawal.
6. Who else sees your data
We do not sell personal data, and we do not share it for anyone else's marketing. It is disclosed only to those who need it to do the work, under contract and on our instructions:
- HubSpot, Inc. (United States) — customer relationship management, for website enquiries.
- EmailOctopus Ltd (United Kingdom) — newsletter delivery.
- Vercel Inc. (United States) — website hosting.
- Fieldwork partners across Latin America — recruiters, moderators, interviewers and transcribers, bound by confidentiality and by the ESOMAR code, and given only the data a specific study requires.
- The commissioning client — in aggregate, and identifiable only where you have explicitly authorized it (section 4).
We may also disclose data where a Colombian authority lawfully requires it, or where disclosure is necessary to establish or defend a legal claim.
International transfer. Some providers process data outside Colombia, in the United States and the United Kingdom, and a study run in another Latin American market is handled by a partner in that market. By authorizing the processing you authorize that transfer. We contract each provider and partner on terms that require a level of protection no lower than that required by Colombian law.
7. How long we keep it
Colombian law sets no minimum retention period. Article 11 of Decree 1377 of 2013 sets a limit instead: personal data may be kept only for as long as is reasonable and necessary for the purpose that justified collecting it. Once that purpose is met we are required to delete it, and holding data indefinitely without a live purpose is itself a breach.
In practice, personal data from a study is deleted or irreversibly anonymised within six months of the project closing.
| Data | Retention |
|---|---|
| Enquiries and briefs | While the enquiry is live and the commercial relationship is active. If it does not become an engagement, it is deleted once that purpose is exhausted. If it does, the resulting records fall under the legal retention below. |
| Newsletter subscription | Until you unsubscribe or ask for deletion. |
| Screening data from people who did not qualify | Discarded once the study's quotas are closed. |
| Fieldwork responses | Held in identifiable form only while the study needs it — analysis, quality control, delivery — and in any case deleted or irreversibly anonymised within six months of the project closing. The anonymised dataset is kept as the study record; it is no longer personal data. |
| Recordings and transcripts | Deleted once analysis and quality control are complete, and no later than six months after the project closes — unless you separately authorized a longer use, such as a video clip in a deliverable. |
| Incentive payment records | Kept as accounting vouchers for the statutory period set out below. This is a legal obligation, longer than the study itself, and we cannot shorten it at request. |
| Evidence of authorization | For as long as the underlying data is held, and afterwards for as long as needed to demonstrate the processing was lawful. |
| Server records | Short-term, for operational and security purposes only. |
The databases described here remain in force for as long as the purposes above require, and are reviewed when those purposes are met.
The one exception is data we are legally obliged to keep. Where a legal or contractual duty applies, the data is retained for that duty alone — not reused for anything else — and a deletion request cannot override it:
| Obligation | Period | Basis |
|---|---|---|
| Accounting books, vouchers and business correspondence | 10 years | Article 28 of Law 962 of 2005, amending article 60 of the Commercial Code. |
| Tax records | Aligned to the término de firmeza of the corresponding return — generally 3 years, and longer where net operating losses or transfer pricing apply. | Article 304 of Law 1819 of 2016, which aligned the general term in article 632 of the Tax Statute with the firmeza period. |
Once those periods run out, the data goes the same way as everything else: deleted or irreversibly anonymised.
8. Your rights
Article 8 of Law 1581 of 2012 gives you, as the Titular of the data, the right to:
- Know, update and rectify your personal data — including data that is partial, inaccurate, incomplete, misleading, or whose processing is prohibited.
- Request proof of the authorization you gave us, except where the law does not require it.
- Be informed, on request, how your data has been used.
- Bring a complaint before the Superintendencia de Industria y Comercio for breaches of the law.
- Revoke your authorization and request deletion of your data, where no legal or contractual duty requires us to keep it.
- Access your data free of charge.
One limit worth stating plainly: once a fieldwork dataset has been anonymised, the data is no longer personal data and there is nothing left to identify, correct or delete. We cannot reverse anonymisation, and we would not want to be able to.
9. How to exercise them
Write to [email protected], or to the registered address above. Tell us who you are, how to reach you, and what you want. Attach something that identifies you, so we do not disclose data to the wrong person. If someone acts on your behalf, we will ask for proof of authority. If your request concerns a study, telling us roughly when and how you took part helps us find your record.
| Request | Our deadline |
|---|---|
| Query (consulta) — you want to know what we hold or how it has been used | 10 business days. If we cannot answer in time we will tell you why and give a new date, no more than 5 business days later. |
| Complaint (reclamo) — you want data corrected, updated or deleted, or you believe we have breached the law | 15 business days. If we cannot answer in time we will tell you why and give a new date, no more than 8 business days later. |
| Incomplete complaint | We will ask you within 5 days for what is missing. If we hear nothing for two months, the request is treated as withdrawn. |
Requests are handled by GCR's data protection contact. Under article 16 of Law 1581, a complaint to the Superintendencia de Industria y Comercio can only be brought once you have gone through this process with us first.
10. Security
The site is served over TLS. Form submissions are transmitted encrypted and processed on the server, never assembled in a third-party script in your browser. Access to the CRM is restricted to the people who need it, and credentials for our processors are held as encrypted environment secrets, never in the site's code.
Fieldwork data is held on access-controlled systems. Recordings and transcripts are available only to the research team working on that study, and fieldwork partners receive only what their part of the work requires. Everyone handling participant data is bound by confidentiality.
No system is perfectly secure. If a breach occurs that affects your data, we will report it as Colombian law requires and inform you where we are obliged to.
11. Children and adolescents
This website is a business-to-business site, it is not directed at children, and we do not knowingly collect personal data from minors through it. If you believe a minor has given us data through the site, write to us and we will delete it.
Research is different: some studies legitimately include minors. Where they do, we obtain verifiable authorization from a parent or guardian, we also seek the young person's own agreement to take part, and the processing respects their best interests and fundamental rights as article 7 of Law 1581 and the ESOMAR code require. A minor may stop at any time regardless of the authorization given for them.
12. Changes to this policy
If we change how we process personal data, we will update this page and change the date below. Where a change is substantial and affects the purposes you authorized, we will ask for your authorization again.
13. In force from
This policy is in force from 25 August 2026. It replaces the privacy and cookies policy previously published on gc-research.com.