Last Updated: July 2007

What Personal Information do we collect?

We obtain Personal Information from and about you including:

• Personal Information. Information that identifies you (“ Personal Information ”) is gathered when you register with this Site, including your demographic information. When you register with this Site, you will be asked for certain Personal Information, such as your name, your street mailing address, your e-mail address, your telephone number and other information. In addition to such contact information, we may ask you to enter an ID, password or similar data when you access this Site, so we can verify your right to access certain portions of the Site. We also collect Personal Information about you to the extent that you otherwise provide it to us online. You provide your Personal Information voluntarily.
• Demographic and Personal Data. When you register with or access this Site, we may request Personal Information about your business demographics.

How do we use the Personal Information we collect?

Our goal in collecting Personal Information from you is to support business purposes we believe are reasonable and consistent with fair business practices. You may, at any time, choose to not receive communications from us by “opting out” of specific mailing lists and services by sending an e-mail requesting removal to our Customer Service Department at: outreachprogram@newlandcommunities.com, or by writing us at the mailing address listed below.

How do we share Personal Information?

We may disclose your Personal Information to our affiliates (i.e., companies that we own, we are owned by, or we are under common ownership with), investors, partners and other third parties in order to support business purposes we believe are reasonable and consistent with fair business practices. We may also disclose your Personal Information as we believe is reasonably necessary to comply with law, regulation or other governmental authority. Finally, we may disclose your Personal Information upon a transfer or sale to another entity of all or a portion of our stock or assets to which this Policy relates, or upon any other corporate reorganization.

Retention and Protection of Personal Information

Generally, we retain your Personal Information that we collect electronically on our server or in our archives for as long as we reasonably need it. We may alter this practice according to legal and business requirements. For example, we may shorten the retention period for certain Personal Information if needed to free up storage space, and we may lengthen the retention period for other Personal Information if needed to comply with privacy standards or applicable law. We establish and maintain certain practices to help protect the confidentiality, security and integrity of electronic Personal Information stored on our system. Notwithstanding the foregoing, no computer system is completely secure, and while the measures we implement are intended to reduce the likelihood of security problems, there is no warranty or guarantee that our standard security measures will prevent access to your Personal Information.

How can you modify your Personal Information?

You may modify or update your Personal Information by logging onto the site, http://www.newlandoutreach.com/ and choosing the “contractor detail” option.

Other Limits to Your Privacy and Confidentiality

We may disclose Personal Information in special cases when we have reason to believe that disclosing the Personal Information is necessary for us to protect or enforce our legal rights, or when we believe that the law requires it, and for administrative and other purposes we deem necessary to maintain, service and improve our products and services. We operate this Site (including without limitation its registration system) and provide our services in good faith, but on an AS-IS, AS-AVAILABLE basis. ANY WARRANTIES OF ACCURACY, QUALITY, TITLE, FITNESS, MERCHANTABILITY OR NON-INFRINGEMENT ARE DISCLAIMED. WE ARE NOT LIABLE FOR DIRECT, INDIRECT, INCIDENTAL OR CONSEQUENTIAL DAMAGES. UNDER NO CIRCUMSTANCES WILL WE BE LIABLE FOR EVENTS BEYOND OUR DIRECT CONTROL. This Policy is governed by California law, excluding conflicts of law principles. Any provision of this Policy that is illegal or unenforceable shall be deemed automatically conformed to the minimum requirements of law. Any legal actions against us must be commenced in California within one year after the claim arose, or be barred.

Consent and Revisions

By using or accessing our services or this Site, you agree to this Policy. This document supersedes any prior communication on this topic and reflects the entire and exclusive Policy. We reserve the right to revise this Policy from time to time, and will post any revisions on this Site. Additionally, if you provide an e-mail address as part of your registration, we may send an e-mail to such address to inform you of changes to this Policy. Upon publication, the updated Policy will be deemed to replace the prior version of this Policy. We encourage you to review our website regularly for changes. If at any time, you do not agree with the terms in the updated Policy or if you want to be removed from our database, please let us know using the contact information below and we will remove your name and other Personal Information from the database.

Your Questions and Comments.

If you have questions about this Policy or would like to be removed from our database, please send an e-mail to: outreachprogram@newlandcommunities.com, or contact us by mail at: Marketing Manager-Outreach Program Newland Communities 9820 Towne Centre Drive San Diego, California 92121