Privacy Policy

1. Who are we?

Subachoque & interOS — Servicio de Internet S.A.S (NIT 901213197-5), located at Cra 3 No. 3-77 Brr Centro, Subachoque, Cundinamarca, Colombia. It is the controller of the personal data collected through the interOS mobile app and its related services.

2. What data do we collect?

• Identification data: name, national ID number (cédula), email address, phone number, installation address.
• Service data: plan, account status, bills, payments, usage history.
• Technical data: IP address, device identifier (a device ID generated by the app), operating system version, device model.
• App usage data: actions taken, TV channels watched, services viewed, technical errors (to improve the app).
• Data from your network equipment: the serial number of your router or ONU, your Wi-Fi network name and password, and the connected devices, so we can show them to you and let you change them from the app.
• If you're not a customer yet: the data you give us when checking coverage (section 4).
• Location (GPS): only if you allow it, to check coverage and to locate your home in a request (section 6).
• Photos in a request: the ones you take or pick in the app to show us a case (for example, your equipment or some damage), only if you attach them (section 6).
• Autopay: if you turn it on, a token for your card, not the card itself (section 7).

3. What do we use your data for?

• To sign you in to the app and protect your account.
• To show you information about your service and bills, and to let you make payments.
• To play live TV and movies only for active customers on the interOS network (to comply with content licenses).
• To handle technical support and contact you when needed.
• To check whether our network reaches your home and handle your service request, if you're not a customer yet.
• To comply with legal and regulatory obligations (CRC, DIAN, Superintendencia de Industria y Comercio, Mintic).

4. If you're not a customer yet

From the app you can check whether our network reaches your home without having an account. If you decide to leave us your details so we can contact you, and only with your express authorization, we store:

• Your name, your ID number (cédula) and a contact phone number.
• The address you enter (required if you don't share your location).
• Your GPS location, only if you give us permission (section 6): the point, how accurate it was, and whether you moved it by hand on the map.
• What our network map returned (whether there's coverage and how far away the network is).
• The result of your identity verification (section 5).
• The date you gave us your authorization and the IP address you sent the request from (to prevent abuse).

We use them only to:

• Check coverage: find out whether we can install the service for you.
• Verify your identity: prevent someone from requesting service in another person's name.
• Contact you: call or message you to schedule the installation or confirm your address.
• Waiting list: if we don't reach you today, let you know when the network gets to your area. Requests without coverage also show us where it makes sense to extend the network.

How long: if you become a customer, your data becomes part of your account and is governed by the rest of this policy. If not, we keep it while your request is open and, if you're on the waiting list, for up to 2 years from the day you gave it to us. After that we delete it; at most we keep how many requests there were in each area, with nothing that identifies you. You can ask us to delete it sooner at any time (section 12).

We never show you in the app the result of the identity verification or anything that comes from an external record: if someone enters another person's ID number, they can't see that person's data.

5. Identity verification and optional health check

Identity verification. When you leave us your details to request service, we check your ID number with an external identity verification provider, CoreSoft, which compares it with official records. From that check we keep only the minimum: the name on record for that ID number, whether it matches the one you entered, and the city of the record. We do not keep the address, phone numbers, or date of birth the record may return.

Health insurance enrollment check (optional). Only if you tick the separate box that authorizes it, we may check, also through CoreSoft, the status of your enrollment in the health system (ADRES) as an additional validation that the ID number belongs to a real person. Because this is health-related information (sensitive data under Law 1581 of 2012), you are not required to authorize it: if you don't tick that box, your request continues the same and this check is not done. If you authorize it, we keep only the status on record (for example, "active") and the date of the check. We do not check or store diagnoses, medical records, or any other medical data. You can withdraw this authorization at any time without withdrawing the one for the rest of your data.

6. Your location (GPS) and the photos in your requests

The app asks for your location only at two moments: when you check whether we reach your home, and when you make a request that needs to know where your home is (a technician visit, a move, a problem with your service or another request). It only uses it if you give it permission on your phone. With that point we check our network map to see whether there's coverage and how far away the network is, and we save it with your request so the technician knows where to go.

• We do not track your location in the background or ask for it for any other feature of the app.
• If you don't give permission, you can enter your address: we'll call you to confirm whether we reach you.
• You can remove the permission whenever you want from your phone's settings.

The photos you attach to a request are used only by our support team to handle it. They are stored on our servers (not in the billing system) and are deleted automatically after 180 days; the ones you took but never sent, after 30. The app only opens the camera or your photos when you ask for it with a button.

7. Autopay

If you turn on autopay, you register your card directly with the payment gateway PlaceToPay. The card is stored by the gateway: we never see or store the full number or the security code (CVV). The only things kept on our side are a token (a code with which the gateway lets us charge your bill), the card brand (Visa, Mastercard…), the last 4 digits so you can recognize it, and the expiration date reported by the gateway. You can turn off autopay or remove the card whenever you want from the app.

8. Face ID / Touch ID

If you turn on biometric sign-in, your fingerprint or face NEVER leaves your device. Apple (or Google on Android) does the comparison locally on a secure chip. The app only receives a "yes/no" from the operating system; we have no access to your biometric information.

9. Who do we share data with?

Only with these providers, and only what each one needs to do its part:

• PlaceToPay payment gateway: to process your payments and, if you turn it on, autopay, under its own policies (placetopay.com/web/politicas).
• CoreSoft (identity verification): your ID number and the name you entered, to verify your identity and, only if you authorize it separately, check your health insurance enrollment (section 5).
• Firebase Cloud Messaging, by Google: to deliver notifications to your phone. It receives your device's notification identifier and the text of each notification.
• Support chat system (Órbita): the messages you write in the chat and the contact details needed to help you, including requests to cancel the service.
• Network equipment manufacturers (C-Data, Ruijie and Ubiquiti): their cloud platforms manage the router or ONU in your home. They hold the device's technical data (serial number, your Wi-Fi name and password, connected devices), which we use to show them to you and let you change them from the app.
• Mapbox and OpenStreetMap: to draw the maps in the app (the coverage screen and the location of a technician visit or a move), your phone downloads the map images (satellite or streets) from Mapbox's servers and, if they don't load, from OpenStreetMap; as with any website, they receive your IP address and the area of the map you're looking at. We don't send them your name, your ID number or your phone number.
• Transactional email providers (Brevo/Sendgrid): to send you one-time codes (OTP) and payment confirmations.
• Authorities: when there is a valid legal request from a competent authority.

We are committed to making sure these providers protect your data with the same care we do: that they use it only for the purpose we shared it for, with appropriate security measures, and never to sell it or for advertising. Some of them store information on servers outside Colombia; even so, this policy and your rights remain the same.

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

10. Where do we store the data?

On our own servers under our direct control (except what we share with the providers in section 9). We use encryption in transit (HTTPS/TLS) and at rest where appropriate. Customer data is kept for as long as the business relationship lasts and up to 5 years afterwards, to meet Colombian tax and accounting obligations. Data from people who are not customers yet is kept for the period in section 4.

11. Your rights

As the owner of your personal data, you can at any time:

• Access the data we have about you.
• Correct inaccurate or incomplete information.
• Update your contact details.
• Delete your information or ask us to forget it (subject to applicable legal obligations).
• Revoke authorizations you have given before.
• File complaints with the Superintendencia de Industria y Comercio (Colombia's data protection authority).

To exercise any of these rights, email us at soporte@interos.com.co. You can also request the deletion of your account directly in the app under Profile → About interOS → Delete my account.

12. If you're not a customer: how to ask us to delete your data

If you left us your details to check coverage but you're not a customer, you don't have an account in the app to delete. To have us delete your data, email us at soporte@interos.com.co with the subject «Borrar mis datos» (Delete my data), your name and your ID number (or the phone number you left). We delete your request and everything associated with it, including the identity verification and, if there was one, the health check.

So that no one can delete another person's data, we may ask you to confirm that you are the owner of the data (for example, by calling the phone number you left). We reply within the legal deadlines: at most 15 business days.

13. Cookies and trackers

The mobile app does not use third-party cookies or external analytics tools. The only persistent identifier is the local device ID (a UUID generated on your phone), which we use to manage the limit of devices watching TV at the same time. We use Firebase (by Google) only to deliver notifications to you, not to measure how you use the app.

14. Minors

Our service is intended for people over 18 who hold an internet contract with interOS, or who want to sign up for one. We do not knowingly collect data from minors.

15. Changes to this policy

We may update this policy. We will notify you of any significant change in the app and by email before it takes effect. The date of the last update is at the top, below the title.

16. Contact

To exercise your rights or for any privacy question:

• Email: soporte@interos.com.co
• Address: Cra 3 No. 3-77 Brr Centro, Subachoque, Cundinamarca