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PERSONAL DATA PROCESSING POLICY
LAW 1581 OF 2012 – HABEAS DATA
TSGroup S.A.S.

TSGroup S.A.S., as the party responsible for the processing of personal data voluntarily provided by you in the course of commercial relationships and the development of our corporate purpose, and in compliance with Personal Data Protection Law 1581 of 2012 (Habeas Data), has updated its internal procedures and adopted its Personal Data Processing Policy, with the commitment to guarantee the comprehensive protection of data subjects through the principles of legality in data processing, purpose, freedom, accuracy, transparency, restricted access and circulation, confidentiality, and security.

PROCESSING OF PERSONAL DATA AT TSGROUP

TSGroup informs that the personal data provided by prospective clients, current clients, suppliers, and business partners will be processed as follows, according to our corporate purpose:

  • 1. Distribution within the TSGroup work team for consultation, verification, and use by authorized employees who require access to such information in the performance of their duties. All information is protected under confidentiality agreements signed upon employee onboarding.
  • 2. n the case of commercial relationships, the information may be shared with employees and third parties (financial institutions, government entities, credit bureaus) for validation and verification purposes.
  • 3. TSGroup’s files and databases may be made available, under legal order, for national defense and security purposes as established by law, if required.
  • 4. Carrying out and supporting marketing and advertising activities, including the dissemination of communications and/or the sending of information related to the company and our products.
  • 5.Communications intended to support sales relationships and projects with clients, suppliers, and business partners.
  • 6. All activities required for the fulfillment of TSGroup S.A.S.’s commercial operations.

In accordance with the requirements established in Law 1581 of 2012, TSGroup is committed to securely storing your data in order to protect the security, privacy, and integrity of individuals, while ensuring that the information maintained is truthful, complete, accurate, up to date, verifiable, and understandable.

RIGHTS OF THE DATA SUBJECT

As the owner of the data contained in our files and databases, Colombian legislation grants you the following rights:

  • a) To know, update, and rectify your personal data before the Data Controllers or Data Processors. This right may be exercised, among others, against partial, inaccurate, incomplete, fragmented, misleading data, or data whose processing is expressly prohibited or unauthorized.
  • b) To request proof of the authorization granted to the Data Controller, except when expressly exempted as a requirement for processing, in accordance with Article 10 of this law.
  • c) To be informed by the Data Controller or Data Processor, upon request, regarding the use given to your personal data.
  • d) To file complaints before the Superintendence of Industry and Commerce regarding violations of this law and other regulations that amend, add to, or complement it.
  • e) To revoke authorization and/or request the deletion of data when the processing does not respect constitutional and legal principles, rights, and guarantees. Revocation and/or deletion shall proceed when the Superintendence of Industry and Commerce has determined that the Controller or Processor has engaged in conduct contrary to this law and the Constitution.
  • f) To access, free of charge, your personal data that has been subject to processing.
DATA SUBJECT CONSULTATION

Requests regarding data stored in our files may be submitted by the data subjects or their authorized representatives. Such requests must be directed to TSGroup as the party responsible for the data, including identification of the data subject, a description of the facts giving rise to the claim, address information, and any supporting documents. If the request is incomplete, the interested party will be required within five (5) days following receipt of the claim to correct the deficiencies. If, after two (2) months from the date of the request for correction, the applicant has not submitted the required information, it will be understood that the claim has been withdrawn.

TSGroup will have a maximum term of fifteen (15) business days from the business day following receipt of the request to respond to the claim.

TSGroup S.A.S., located at Carrera 43A #14-109, NOVA TEMPO Building, Office 313, Medellín, Colombia, in compliance with the law, handles inquiries and claims through [email protected] or by phone at PBX +57 4 352 37 87.