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H.G. Fenton Company Prior Web Privacy Policy

Effective: May 1, 2010

SUMMARY

H.G. Fenton Company ("Fenton," "we" or "us") operates the hgfenton.com, hgfentonhomes.com, scrippslanding.com, tierrasantaridge.com, solanahighlands.com, seagatecondorentals.com, eldoradohillsapts.com, belladelmarapts.com, riverfrontrentals.com, clubriverrun.com, portofinoapthomes.com, creekview.info, eveningcreek.info, aquateraliving.com websites (collectively, the "Site"), which are hosted in the United States. We want you, our customer, to understand how we collect and use data about your Site visit, specifically the portions of the Site that require you to register and/or log in to gain access, such as when you are submitting an application online or posting to our community classifieds pages. The privacy policy below identifies what information the Site collects, and what it is used for. We use cookies, which gather certain forms of information from your computer to help us monitor and improve Site usage and performance. Certain web pages may allow you to voluntarily submit personal information about yourself and any potential property in which you express an interest. For online recruiting purposes, the Site collects "personally identifiable information", which is information that identifies you. This may include your name, address, email address, telephone or fax number, IP address, any content you post in your resume or CV, and certain other information, which we explain in more detail below. You can choose not to provide us with this information, but certain portions of the Site may not be available to you.

We do not disclose this information to third parties for their marketing purposes without your prior consent, but we do use third party software and services to assist us with collecting and analyzing information regarding use of the Site. We may also disclose your information to others for other purposes, particularly if required to do so by law. The privacy policy for the Site is set forth below and you should contact milton@hgfenton.com if you have questions or concerns about this policy or the use of your information.

INFORMATION COLLECTION

This is our online privacy policy ("Web Privacy Policy"). This Web Privacy Policy applies only to activities we engage in on the Site and does not apply to activities that are "offline" or unrelated to the Site.

Anonymous Information. We may collect two types of information through this Site: anonymous information and personally identifiable information ("PII"). We collect certain anonymous data regarding the usage of the website. This information does not personally identify users, by itself or in combination with other information. We gather it to improve the performance of the Site. The anonymous data we collect can include information such as the type of browser you are using, IP address, the pages you view, and the length of your visit to the Site.

Personally Identifiable Information. We may also ask you to provide personally identifiable information on the Site, which may include your name, address, telephone number, fax number, company name, e-mail address and relevant details about the property that interests you. These details may include whether the location is a business or residence, the location, and the square footage, to give some examples. This information can be gathered when you send us an e-mail or when you complete the specific web page request form. In all such cases you choose whether to provide us with the personally identifiable information, but certain portions of the Site may not be available to you or we may not be able to respond to your inquiry effectively if you do not provide the PII requested.

My Account. In order to provide some of the services on the Site, we ask you to provide additional personal information regarding your account with Fenton. This additional information may include existing account numbers, application details, service preferences and so forth. We will use this information only to support your relationship with Fenton. This includes responding to your requests, customizing your experience on the Site, and communicating with you about your account.

Surveys and Contests. We may occasionally request information from you via surveys or contests. Your participation in these surveys or contests is completely voluntary. The information that we request typically includes your contact details. If you choose to participate, the information that you provide will be shared with the contest/survey sponsors to notify winners and award prizes. Survey information may also be used to monitor and improve the content and performance of the Site.

Career Pages. If you choose to review our job listings and to submit an application from our career web pages, then you will have choices as to how you contact us and how much information you provide online. Any information that you provide within your resume or CV will be considered Personally Identifiable Information and will be used only in the context of assessing your suitability for one or more roles with us. We will maintain any resume information on file after submission in case subsequent job openings may interest you. We will use your contact details to alert you if we see a potential fit. You may contact us at milton@hgfenton.com to have your resume information removed from our database.

Community Classifieds. Each of our properties will typically have a portion of the web site designated as Residents Corner, where you can post and respond to community classifieds for example. Posting and responding to classifieds is entirely voluntary but you should know that information posted is publicly available, even to those Site visitors who are not members of your residential community. Therefore, you should always be aware of any personal information that you post, as we can take no responsibility for how this information may be used outside of Fenton.

COOKIES AND WEB BEACONS

Cookies are small bits of data cached or stored on your computer based on Internet activity. We use cookies to monitor individual activity in aggregate to improve the Site. The information we gather may include IP address, user language, the operating system, browser type, the presence/absence of "flash" plug-ins, screen resolution, connection type, and information that identifies the cookie. However, no other user information is generally collected. On most web browsers you will find a "help" section on the toolbar. This will tell you how to stop accepting cookies, how to be notified when you receive a browser cookie, and how to disable existing browser cookies. Remember though that without browser cookies you may not be able to take advantage of all our Site features.

We also use web beacons (also known as clear gifs), which are tiny graphics embedded on a web page to help us measure the effectiveness of particular content. Unlike cookies, web beacons are not stored on your computer's hard drive.

USE AND DISCLOSURE OF INFORMATION

Uses by H.G. Fenton Company

Fenton uses the personal information you provide through the Site in a manner that is consistent with this Web Privacy Policy. If you provide personal information for a certain reason, we may use it in connection with the reason for which it was provided. For instance, if you contact us by email, we may use the personal information you provide to answer your question or resolve your problem. We use the information collected through the Site for statistical purposes and for improving the Site, as well as for our marketing purposes and potentially sending commercial emails to you. We often engage a third party's software or services to assist us with these collections and analyses. As a practical matter, we must release your mailing address to a postal or courier service to deliver information you requested. We use third-parties to assist us with our marketing efforts, including assisting us with sending emails to you. This may include sending you free electronic newsletters and marketing-related emails for services described on our Site. However, you will have the choice to opt out of receiving newsletters and marketing emails for our services by either contacting us directly at milton@hgfenton.com or through the "unsubscribe" link found at the bottom of our newsletters and emails.

On certain of our Site pages where you have submitted detailed information concerning potential properties or services or job postings, we will use this information only for the purposes of contacting you and determining which job, property or service and so forth may be most relevant to you. We will not share this information with any third party for their own marketing purposes without your prior consent.

We may also disclose personally identifiable information in order to respond to a subpoena, court order or other such request. We may also provide such personally identifiable information in response to a law enforcement agency's request or as otherwise required by law.

We may provide your personally identifiable information to a third party if we file for bankruptcy, or there is a transfer of the assets or ownership in connection with proposed or consummated corporate reorganizations, such as mergers, acquisitions, or sales of business units.

Uses by Third-Parties

We do not provide your personally identifiable information to any third party for their own marketing purposes without your prior request or consent. Fenton works closely with certain businesses to provide you with property information and services. Sometimes these businesses make special offers available to Site visitors. If you request to receive information about these offers, we will share your personal information with these companies so that they can send you details about their special offers. You should know in advance that each of these companies has its own policies with respect to the collection and use of personal information and that we are not responsible for their use of your information.

INFORMATION SECURITY AND SECURE TRANSACTIONS

We have implemented various security measures for the purpose of protecting your personal information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access and against any other unlawful forms of processing. When you create a user profile and log in to a secure portion of our Site, your personal information benefits from the protections of Secure Sockets Layer ("SSL") technology. Our web servers have been enabled with SSL technology to automatically encrypt your information and help prevent unauthorized parties from viewing your account or application information during a secure session. This is why you must enter your unique user name and password each time you access your account information through the Site.

You are responsible for maintaining the confidentiality of your user name and password. You are responsible for all uses of your password, whether or not authorized by you. You must inform us immediately of any unauthorized use or your user name or password.

However, the transmission of data over the Internet by its nature entails the use of systems under the control of third parties, and as a result Fenton will work to prevent any violation of the security systems but cannot ensure a total control of the security of such systems.

OTHER WEBSITES

Please be aware that our Site may contain links to other sites on the Internet that are owned and operated by third parties. These links include, but are not limited to, individual websites for H.G. Fenton Company apartment properties and the careers section of www.hgfenton.com. The information practices of those websites linked to our Site are not covered by this Policy. We are not responsible for the privacy H.G. Fenton Company Page 4 of 4 Privacy Policy policies of websites to which the Site links. If you provide any information to such third parties, different rules regarding the collection and use of your PII may apply. We strongly suggest you review such third party's privacy policies before providing any data to them. These other sites may send their own cookies or web beacons to users, collect data or solicit personally identifiable information. We cannot control this collection of information. You should contact these entities directly if you have any questions about their use of the information that they collect.

CHILDREN

Fenton understands the importance of protecting children's privacy in the interactive online world. The Site covered by this policy is not designed for or intentionally targeted at children 13 years of age or younger. It is not our policy to intentionally collect or maintain information about anyone under the age of 13.

INQUIRIES, CORRECTIONS AND COMPLAINTS

Data is submitted to H.G. Fenton Company ("Fenton") and is hosted and stored in a database on servers situated in the United States by Fenton and by third parties on our behalf.

You are responsible for ensuring that the personal information you have submitted or access through the Site is accurate and complete. You may change the information we have on file for you by accessing My Account and entering any new or different details. If you have included personal details such as address or email information, you may alter these via the appropriate link on your My Account page. Please contact us immediately if you notice changes to your profile that you did not request or if you notice any suspicious activity concerning your account.

If you have questions or concerns regarding this Web Privacy Policy or about privacy at our Site, please contact us by sending an email to milton@hgfenton.com or calling H.G. Fenton Company at (619) 400 - 0120 and we will try to resolve it.

H.G. Fenton Company
7577 Mission Valley Road, Suite 200
San Diego, California 92108

If you wish to modify or update any information we have received, please contact milton@hgfenton.com.

MODIFICATIONS OF THE WEB PRIVACY POLICY

We reserve the right to modify this Web Privacy Policy at any time. We will notify you by posting an amendment to the privacy policy on the Site and highlighting the changes in an appropriate notice. Such modifications will become effective thirty (30) days after they are posted. We encourage you to frequently review the Web Privacy Policy for any modifications.