PRIVACY POLICY

Note: Effective April 1, 2016 UTSI is no longer a participant in the US-EU Safe Harbor Program

Dear Customer and/or Employee of UTSI International Corporation

As you will see by the following, it is the policy of UTSI not to disclose personal and/or confidential information of any type. Due to the consistent exposure of our personnel to confidential information belonging to clients, we are very careful not to disclose any information concerning them. Most, if not all, of our contracts contain confidentiality clauses. We also strictly limit the release of any information concerning our employees. Our employees are aware of this policy, and sign an agreement so stating. Following are the details of our privacy policy, which is contained in our Employee Manual as Addendum No. 7, and applies to all of our offices and personnel.

If you have any questions, do not hesitate to contact us.

Addendum to the Manual No. 7 (Effective June 8, 2016)
For UTSI International Corporation, including its Spanish Branch Office (Madrid).

This is the seventh addendum to the Employee Manual. Place it in the front of the manual. These changes are effective June 8, 2016.
Daniel W. Nagala, President, UTSI International Corporation
(NEW MANUAL SECTION 7.0)

7.0 PRIVACY POLICY AND PROCEDURES

7.1 Introduction

7.2 Controlling Legislation

UTSI’s operations are worldwide and involve the frequent exchange of paper and electronic data between offices and with customers. These procedures apply to all UTSI operations anywhere to bring the privacy protections of our operations into compliance with applicable data protection and privacy directives in the jurisdictions where we work. However, it should be noted that the nature of UTSI’s business and its ongoing operations does not involve the collection and/or use of any personal information, apart from employment related details required by applicable law. Of course, as branch offices of a U.S. based entity, these branch offices must also follow U.S. law as it may be applied overseas, including but not limited to the Export Administration Act, Section 999 of the Internal Revenue Code, the Trading with the Enemy Act, the International Emergency Economic Powers Act, the Arms Export Control Act and the Foreign Corrupt Practices Act, and any amendments thereto. If you have any doubts about the legality of any action or transfer of data, do not hesitate to contact our Houston headquarters anytime.

7.3 No Unauthorized Disclosure

It is not the policy of UTSI to release personal data to any third party for the purposes of commercial gain. Corporate data is only released in the context of our business dealings, and in accordance with the confidentiality agreements of our contracts. Most, if not all, of our business contracts have confidentiality clauses that survive the contracts themselves for a period of five years, to wit:

“Confidential Information

For the purpose of this Agreement, confidential information shall refer to any and all information disclosed to UTSI, and its staff assigned to the contract, which relates to [Client]’s past, present, and future business activities. UTSI shall hold all such confidential information in trust and confidence for [Client] for the term of the contract and a period of five (5) years, or such other period as defined by contract with Client, afterwards, and agrees that it will not, either during or after the termination of this Agreement, disclose to any person, firm, corporation, or entity, nor use for its own business purpose or benefit, any of said information obtained by it during the execution of this Agreement. Additionally, confidential information shall refer to any and all information disclosed to [Client], and its staff working with UTSI, which relates to UTSI’s past, present, and future business activities. [Client] agrees that it shall hold all such confidential information in trust and confidence for UTSI for the term of the contract and for a period of five (5) years, or such other period as defined by contract with Client, afterwards, and agrees that it will not, either during or after the termination of this Agreement, disclose to any person, firm, corporation, or entity, nor use for its own business purpose or benefit, any of said information obtained by it during the execution of this Agreement.”

Upon employment, new employees sign in writing a confidentiality agreement, to wit:

“Confidential Information

I am aware that during the course of my employment confidential information will be made available to me, for instance, product designs, marketing strategies, customer lists, pricing policies and other related UTSI information, as well as information provided as part of my responsibilities to fulfill a specific customer’s requirements. I understand this information is proprietary and critical to the success of UTSI and its customers and must not be given out or used outside of UTSI’s premises, or with non-UTSI employees, except for legitimate business purposes of UTSI. In the event of termination of employment, whether voluntary or involuntary, I hereby agree not to utilize or exploit this information with any other individual or company. ”

In addition to the above, all employees are ordered not to release any personal data to any third party without the express written authorization of the person in question.

However, from time to time UTSI may need to release some employee data for the purposes of securing insurance, health insurance, or other benefits for the company. The company will release such information only with the written consent of the employees, although this release may be general and not specific to each occasion.

Furthermore, UTSI is required by law to release certain personal and statistical data to pertinent governmental authorities. UTSI will comply with the law in all cases.

7.4 Viewing and Monitoring the Policy; Contact Office for Initial Claims

These procedures may be viewed on the website. Also, and at any time, a printed copy of these procedures may be requested from the Executive Vice President of UTSI International Corporation, 1560 West Bay Area Blvd., 2nd floor, Suite 300, Friendswood, Texas 77546, by contacting him by telephone at 713-480-8786, x-101, or by e-mail at drossmann@utsi.com. The monitoring of these policies will be done in house under the direction of the Executive Vice President (EVP), along with General Counsel. Any complaints, access requests, or any other issues arising from his safe harbor policy should also be initially directed in writing to the EVP at the foregoing address, phone number or e-mail. The complainant should include his or her name, address, contact number and/or email, nature of the complaint and the time, date and place where the privacy violation occurred and the redress sought. The EVP will receive calls concerning these matters, but in order to give such a complaint a formal investigation, he or she will need a complaint in writing. Said writing need not be elaborate but must give the EVP fair notice of the nature, contents and type of the complaint. The complainant and the EVP, along with General Counsel, will try to come to some sort of agreement to remedy the unauthorized disclosure if indeed it has occurred.

7.5 Forum for Claims

If the matter is not resolved at the corporate level, any claims may be submitted to the U.S. Federal Trade Commission (FTC) pursuant to Section 5 of the Federal Trade Commission Act.