Privacy
Personal Data Processing Policy
TSG Claims S.A.S. · Tax ID 902.101.612-3. This Policy sets out the rules for the collection, use, storage, circulation, transmission, transfer, retention, anonymisation and deletion of personal data in Colombia.
1 · Data controller
TSG CLAIMS S.A.S., a company domiciled in Bogotá D.C., tax ID 902.101.612-3, at Carrera 11 No. 93 A 83, postcode 110211, Bogotá D.C., Colombia. Legal representative: Tulio Samuel González Jiménez. Commercial registry 04148772.
2 · Legal framework
This Policy applies under the Political Constitution of Colombia, Law 1581 of 2012, Decree 1074 of 2015, the instructions of the Superintendency of Industry and Commerce and any rules amending or replacing that regime. Its existence does not replace the authorisations, transmission agreements or confidentiality undertakings legally required for a specific processing activity.
3 · Scope
It applies to data of current and prospective clients — policyholders, insurers, reinsurers, brokers, intermediaries, loss adjusters, law firms and other market participants; legal representatives, directors, employees, beneficiaries and third parties included in loss files; suppliers and specialists; staff and candidates; and users of the website and digital channels.
4 · TSG Claims' role
TSG Claims acts as Controller in respect of commercial contact data, prospects, billing, suppliers, staff, compliance and corporate management. It acts as Processor where a client provides files, accounting records or third-party information to analyse, quantify or document a loss on that client's lawful instructions. The characterisation depends not on the name of the contract but on who determines the purposes and means of processing.
5 · Purposes
Assessing opportunities, conflicts of interest and the viability of engagements; contracting and delivering professional services; analysing policies, coverages, quantum, damage, business interruption and forensic accounting; preparing, reviewing or substantiating claims according to the role engaged; liaising with authorised participants; administering files and deliverables; billing and receivables; and complying with legal, tax, audit and fraud-prevention obligations.
6 · Sensitive data and minors
TSG Claims does not collect sensitive data or data of minors as a principal business purpose. Such data may appear within documents lawfully provided by clients, particularly in claim files, payroll or litigation. In those cases processing is limited to what is strictly necessary, with reinforced access and confidentiality measures, and requiring the applicable legal basis. Providing sensitive data is optional.
7 · Web forms
The contact form on this site collects name, email, phone, company, job title, city, industry, insurer, estimated loss range, claim stage and any description the enquirer chooses to provide. Evidence of the authorisation given is retained, with date and IP address. The form does not accept attachments: sensitive documentation is requested, where appropriate, through a controlled channel.
8 · Transmission, transfer and international operation
TSG Claims may share data, to the extent necessary for authorised purposes, with its team, insurers, brokers, loss adjusters, counsel, experts, technology providers, auditors and authorities lawfully connected to the matter. It may use storage, backup or processing platforms located inside or outside Colombia, in accordance with applicable law and the corresponding contractual safeguards. The international location of processing neither broadens the authorised purposes nor reduces the confidentiality owed.
9 · Security and retention
Administrative, human, contractual and technological measures are adopted in proportion to the type of information, volume, sensitivity and risk, including access controls, authentication, user profiles, restricted storage, backup and traceability. Data is retained while the purpose that justified its processing subsists and thereafter while legal, tax, contractual, audit or rights-defence obligations exist.
10 · Data subject rights
To access, update and rectify their data; to request proof of the Authorisation where applicable; to be informed of the use given to their data; to complain to the Superintendency of Industry and Commerce once the internal procedure is exhausted; to withdraw the Authorisation or request deletion where appropriate and no legal or contractual retention duty exists; and to access their data free of charge on the statutory terms.
11 · Enquiries and complaints
Enquiries are answered within a maximum of ten (10) business days from receipt; where that is not possible, the reason and the response date will be notified, not exceeding a further five (5) business days. Complaints must identify the data subject, describe the facts, state the specific request and attach relevant supporting material; they are answered within a maximum of fifteen (15) business days, extendable by up to eight (8) further business days with notice of the reason.
12 · Contact channels
Email: privacidad@tsgclaims.com · Address: Carrera 11 No. 93 A 83, Bogotá D.C., Colombia · Telephone: +57 313 360 8145 · Website: tsgclaims.com, Privacy section.
13 · Validity and updates
This Policy may be updated to reflect legal, regulatory, technological or operational changes. Substantial changes affecting the purposes or conditions of processing will be communicated by reasonable means before implementation where the law so requires. The current version will be available on this site.
Version 1.0 · TSG Claims S.A.S. · Tax ID 902.101.612-3 · Bogotá D.C., Colombia