Privacy Policy

Mobile Applications and Digital Services of Fibex Telecom and Conex Telecom

ESENKO

1Introduction and Data Controller

This Privacy Policy governs the processing of personal data of users (hereinafter, the "User" or "Users") of all mobile applications and digital services published by Soluciones Medianet, C.A. on behalf of Fibex Telecom and Conex Telecom and the companies of the Fibex Telecom and Conex Telecom Group (hereinafter, "Fibex", "we", or the "Data Controller"), in Venezuela, the Dominican Republic, and Peru.

By downloading, installing, registering for, or using any of our applications published on Google Play, the App Store, Samsung Galaxy Store, or other app marketplaces, the User declares that they have read, understood, and accepted the terms of this Policy.

Data Controller Information:

Corporate Name:Soluciones Medianet, C.A. / Fibex Telecom, C.A. / Conex Telecom LLC
Legal Address:5685 NW 84th Ave. Doral Florida, 33166
Official Websites:
conextelecom.com—fibextelecom.net—fibex.do—cxt.pe
Privacy Contact Email:desarrollos@grupoconex.net

2Scope of Application

This Policy applies to all mobile applications and associated digital platforms of the Group, including but not limited to:

ApplicationMain Purpose
Fibex Oficina MóvilSelf-management of telecommunications services (Venezuela)
FibexPlayLive TV streaming and audiovisual on-demand content (Venezuela)
Club FibexSubscriber benefits and customer loyalty rewards program
Fibex DominicanaSelf-management of telecommunications services (Dominican Republic)
FibexPlay RDLive TV streaming and audiovisual on-demand content (Dominican Republic)
Wave TVLive TV streaming and audiovisual on-demand content (Wave)
ConexPlayLive TV streaming and audiovisual on-demand content (Peru)
Conex PerúSelf-management of telecommunications services (Peru)

Likewise, it applies to any other application or digital service developed, published, or acquired by the Group that directly links to this Policy.

3Personal Data We Collect

We collect only the personal data strictly necessary to provide our services, maintain continuous improvement, and comply with applicable laws. The categories of collected data include:

aIdentification and Contact Data

Full legal names, identification document numbers (national ID, tax ID, passport), subscriber or contract numbers, physical mailing address, email address, and telephone numbers.

bAccount Credentials Data

Username, securely encrypted password, user preferences, authentication session logs, and profile avatar.

cFinancial Data

Banking information, associated payment cards (tokenized via certified processors), transaction history, credit capacity assessments, and billing records. Under no circumstances do we store the full CVV of credit or debit cards.

dDevice Data

Hardware model, operating system and build version, advertising identifiers (AAID/IDFA), unique installation identifiers, system language, mobile carrier, IP address, and network connection type.

eUsage and Diagnostic Data

In-app interaction events, visited screens and tabs, session duration metrics, technical error logs, and crash analytics reports.

fLocation Data

Approximate or precise geographical location only when expressly authorized by the User (necessary, for example, for physical installation dispatch, network coverage validation, on-site technical inspection, or localized regional promotions).

gContent and Multimedia

Photographs, documents, or files voluntarily uploaded by the User (e.g., payment vouchers, identity verification photos, technical inspection evidence, or insurance documentation).

hCommunications Data

Transcripts of technical support inquiries, customer service chat conversations, satisfaction surveys, and feedback ratings.

4Device Permissions Requested by Our Apps

Our mobile applications may request access to specific device capabilities. These permissions are never used to access data without your explicit consent and can be revoked at any time through your operating system settings:

Location (approximate/precise)

Network coverage validation, technician dispatch, nearest branch office locator, and regional offers.

Camera

Capturing payment receipts, uploading profile avatars, QR code scanning, and technical service evidence.

Microphone

Voice-over-IP (VoIP) calling and interactive customer care video assistance (where applicable).

Storage / Photos

Attaching image vouchers, identity documents, or claims documentation from local storage.

Push Notifications

Billing reminders, service maintenance updates, critical security alerts, and promotional announcements.

Contacts

Only when the User voluntarily chooses to select and share a contact (e.g., beneficiary or referral referral programs).

Phone

Direct dialing of customer assistance phone numbers straight from within the app interface.

Network State / Internet

Ensuring normal operation, verifying active network connection status, and streaming video buffer monitoring.

Biometrics (Fingerprint / Face ID)

Fast, secure local authentication when explicitly enabled by the User on compatible devices.

5Purposes of Processing

We process your personal data for the following legitimate purposes:

Provide contracted telecommunications, financial, insurance, audiovisual streaming entertainment, and subscriber loyalty services.
Authenticate the User and safeguard account and system security.
Process transactions, invoicing, payment verification, and collection management.
Deliver customer support, handle inquiries, and resolve technical issues.
Send operational communications (service notices, plan adjustments, scheduled maintenance, and security alerts).
Send, subject to prior consent, commercial offers, news, and promotional communications from the Group.
Personalize user experience (recommended streaming titles on FibexPlay, tailored benefits in Club Fibex, etc.).
Comply with legal, regulatory, and contractual obligations applicable in Venezuela, the Dominican Republic, and Peru.
Prevent, detect, and mitigate fraud, unauthorized account access, and illegal activities.
Perform statistical analytics, product improvements, and service quality benchmarks using aggregated or pseudonymized data.

6Legal Basis for Processing

We process personal data based on the following legal grounds:

  • (i) Performance of the service agreement and contractual obligations;
  • (ii) The User's free, specific, and informed consent where required (commercial marketing, precise geolocation, optional push notifications);
  • (iii) Compliance with legal and regulatory obligations in telecommunications, tax, financial, and anti-money laundering matters; and
  • (iv) The Data Controller's legitimate interests in maintaining network security, continuous service improvement, and fraud prevention, balanced against the User's fundamental privacy rights.

7Data Sharing with Third Parties

We do not sell personal data. We may share personal data only with:

  • Companies of the Conex Group (Fibex Telecom, Conex Telecom, Credix, La Internacional, and affiliates) for integrated service delivery.
  • Authorized technological service providers acting as data processors under binding contract: cloud hosting, push notifications (Firebase Cloud Messaging), analytics (Google Analytics for Firebase or similar), payment gateways, transaction messaging, email delivery, customer support desks, content delivery networks (CDN), and anti-fraud tools.
  • Competent administrative or judicial authorities upon receipt of a valid and lawful requirement (SUDEBAN, SUDESEG, CONATEL, INDOTEL, OSIPTEL, SBS, among others depending on the jurisdiction).
  • Third parties in corporate restructuring transactions (merger, acquisition, asset transfer), preserving equivalent levels of protection.

All third-party processors are contractually bound to maintain strict confidentiality and use personal data solely for the instructions authorized by the Data Controller.

8International Data Transfers

Because we operate across Venezuela, the Dominican Republic, and Peru and leverage global cloud infrastructure, certain data may be stored or processed on servers situated outside the User's home country. In such instances, we implement appropriate safeguards — standard contractual clauses, transport and at-rest encryption, strict access controls, and vendors certified under recognized international security standards (ISO/IEC 27001, SOC 2, GDPR compliance) — to ensure ongoing protection.

9Data Retention

We retain personal data for the duration of the contractual relationship with the User and subsequently for the statutory limitation periods prescribed by applicable local laws (tax, accounting, financial, telecommunications, and consumer regulations). Data that is no longer required is securely deleted or irreversibly anonymized.

10Information Security

We implement robust technical and organizational security measures to protect personal data: encryption in transit (TLS 1.2/1.3) and at rest where applicable, role-based access controls, multi-factor authentication for authorized staff, continuous infrastructure monitoring, vulnerability assessments, incident response protocols, and privacy awareness training. While no digital platform is 100% invulnerable, in the event of a significant security breach, we will notify affected Users and relevant authorities in accordance with applicable laws.

11User Rights

Users may at any time exercise their statutory rights of Access, Rectification, Cancellation (Erasure), Opposition, Limitation of Processing, and Data Portability, as well as withdraw previously granted consent.

To exercise your rights, please email desarrollos@grupoconex.net specifying: your full name, official identification document number, the relevant application or service, the specific right you wish to exercise, and your contact address for response. We will address your request within statutory deadlines established by applicable law.

Access and Rectification

Inquire what personal data we retain and request the immediate correction of inaccurate or incomplete data.

Cancellation (Erasure)

Request the deletion or suppression of personal data when it is no longer needed for the contracted purposes.

Opposition and Limitation

Object to processing for specific purposes (such as direct commercial marketing) or request restrictions on its scope.

Portability and Consent Withdrawal

Obtain a structured, machine-readable copy of personal data or revoke consent without retroactive detriment.

Applicable Legal Frameworks:

  • Venezuela: Constitution of the Bolivarian Republic of Venezuela (Art. 28 — Habeas Data), Organic Telecommunications Law, Banking Sector Law, and Special Law Against Computer Crimes.
  • Dominican Republic: Law 172-13 on the Comprehensive Protection of Personal Data.
  • Peru: Law No. 29733 (Personal Data Protection Law) and Supreme Decree No. 003-2013-JUS.

Users have the right to lodge a complaint with the competent supervisory data protection authority in their country of residence if they consider that their rights have been infringed.

12Protection of Minors

Our applications are intended for adult individuals or, in the case of entertainment streaming services, for minors under the guidance, supervision, and consent of their parents or legal guardians. We do not intentionally collect personal data from children under 13 without verifiable parental authorization. If we discover that unauthorized personal data of a minor has been collected, we will take prompt steps to delete it.

13Cookies and Similar Technologies

Our websites and certain application components employ cookies, software development kits (SDKs), and similar tracking technologies for authentication, audience measurement, fraud mitigation, and user interface preferences. Users can manage or disable cookie preferences through their web browser or mobile operating system settings.

14Advertising Identifiers and Analytics

Certain apps utilize diagnostic and telemetry analytics services (such as Google Analytics for Firebase and Firebase Crashlytics) to understand feature engagement and optimize service stability. These tools may process pseudonymized device identifiers. Users can reset or opt out of advertising tracking at any time via operating system settings ("Limit Ad Tracking" on iOS, "Reset Advertising ID / Delete Advertising ID" on Android).

15Third-Party Links

Our applications may contain hyperlinks leading to third-party websites or third-party digital media content (for example, external broadcast channels hosted on FibexPlay). The Data Controller does not control and accepts no responsibility for the independent privacy practices of such third parties. We encourage Users to review their separate privacy statements.

16Limitation of Liability

To the maximum extent permitted by applicable law, the Data Controller shall not be liable for unauthorized access or breach resulting from sophisticated cyberattacks exceeding reasonable state-of-the-art security measures, nor for device misconfigurations or compromises caused by the User's negligence in sharing credentials or granting device access to third parties.

17Modifications to this Privacy Policy

We reserve the right to revise or update this Policy to reflect statutory updates, technological innovations, or operational changes. The latest version will always remain accessible on our official web portals and within the app marketplace listing. Substantial modifications will be notified to the User through the app or by email with at least 15 days notice prior to taking effect.

18Applicable Law and Jurisdiction

This Policy is governed by and construed in accordance with the laws of the country in which the User resides and contracts services (Venezuela, the Dominican Republic, or Peru). Any disputes arising from or relating to this Policy shall be submitted to the competent courts of said jurisdiction, without prejudice to consensual alternative dispute resolution mechanisms.

19Official Contact Information

For any inquiries, feedback, or statutory privacy requests regarding this Privacy Policy or personal data processing, you may reach out to our team through the following official channels:

  • Dedicated privacy email: desarrollos@grupoconex.net
  • Corporate address: 5685 NW 84th Ave. Doral Florida, 33166
  • Official web portals: conextelecom.com | fibextelecom.net | fibex.do | cxt.pe
Email:desarrollos@grupoconex.net
Web:
conextelecom.com—fibextelecom.net—fibex.do—cxt.pe