SECURITY POLICY

Purpose

HUB Advanced Networks, LLC (“HUB Advanced Networks / Company”) Information Security Policy (“Policy”) aims to describe the measures implemented to protect the confidentiality and integrity of the information handled by the Company.

Scope

This Policy applies to all information handled by the Company whether in information system devices, networks, applications or any other device or facility owned or controlled by HUB Advanced Networks.

Applicability

This Policy applies to all HUB Advanced Networks’ employees, whose actions can affect the confidentiality and integrity of the business, its products and services. It also applies to all third parties that have a need to know HUB Advanced Networks’ information, including but not limited to contractors and temporary employees.

Policy

INFORMATION CLASSIFICATION

Restricted information is the data which is protected by state and federal laws as well as financial and personnel records. Confidential information is the data, which is not protected by any specific law, but the data owner deems it should be protected from unauthorized disclosure. Public information is the data available to anyone without any legal restriction.

SECURITY MEASURES AND HANDLING OF INFORMATION

In order to reduce risks, appropriate security measures have been taken from unauthorized access, damage or loss, requiring all individuals who have a need to know Company’s information to utilize the same in accordance with Company’s legitimate business needs. Individuals’ responsibilities and protection methods with the respect to Company’s information are, in accordance to its classification, set forth in agreements, personnel manual(s) and policies to assure security requirements are being implemented in an effective manner, where any breach may result in a disciplinary action or legal claim. In that sense, this Policy is not a stand-alone document, but supported by detailed procedures considered in agreements, manuals and other policies, which together define HUB Advanced Networks’ security measures.

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

POLICY UPDATES

HUB Advanced Networks may change or update this Policy at any time. If so, HUB Advanced Networks will change the effective date found at the bottom of this Policy, please visit this web page periodically to be informed regarding any changes made. If you have any questions concerning this Policy, please contact HUB Advanced Networks Law Department at PO Box 195600, San Juan PR 00919.
Rev. September 2026