PRIVACY POLICY

At Sunterra Beach Group, we treat personal information - nonpublic information that identifies you - with respect, and strictly in accordance with this Privacy Policy.
We've prepared this policy statement to explain what types of information we collect, how we use it, how we protect it, and under what circumstances we may share it with others. It covers all of the members of the Sunterra family, including Sunterra Corporation, Resort Marketing International, Inc., Sunterra Europe, and all other subsidiaries and affiliates of Sunterra (all collectively referred to herein as "SBG").

We hope that you will read through all of the details of how SBG safeguards and uses your nonpublic personal information. At the very least, however, we want you to know that SBG uses nonpublic information about you responsibly to:
" provide you with the services that you've requested
" offer you other products and services
" alert you to services and products made available by our carefully-selected marketing partners

This policy statement takes precedence over any previous privacy policies issued by Sunterra or any of its subsidiaries.
The kinds of information we collect.
We collect and maintain the following types of nonpublic personal information about you:
" Information that we receive from you, including your name, mailing address, e-mail address, and telephone number.
" Information about your transactions with SBG.
" Information you provide when you register to use SBG's web services, when you use SBG's products or services, and when you visit SBG web pages. This information may include but is not limited to your name, email address, birth date, gender, zip code, occupation, industry, and personal interests, as provided by you. SBG may combine information about you that we have with information we obtain from business partners or other companies.
" When you access a SBG website, SBG automatically receives and records information on our server logs from your browser, including your IP address, SBG cookie information, and the page you request.
How we use this information.
" Most of the information that we collect is used for only one purpose: to help us deliver the services you've requested easily and efficiently. It may also permit us to design and offer specific products and services that we believe will be beneficial to you. SBG uses information provided by your use of the website for the following general purposes: to customize the advertising and content you see, fulfill your requests for prod-ucts and services, improve our services, contact you, conduct research, and provide anonymous reporting for internal and external clients.

Who has access to this information.
Within SBG:
" SBG employees are permitted access to the information which they need to perform their jobs. We maintain strict internal policies against unauthorized disclosure or use of information regarding our purchasers.
" As permitted by law, information held by any SBG affiliate is available to other members of the Sunterra family of companies for au-thorized purposes, including, but not limited to Sunterra Europe, Sunterra Financial Services, Inc. and Sunterra Resort Manage-ment, Inc., and Resort Marketing International, Inc.
Outside service providers:
" At times, we enter into arrangements with companies whose expertise is essential for our own services to function properly. As permitted by law, we disclose to these service providers only such nonpublic personal information of the type described above as is reasonably necessary to perform these functions. As with all of our business partners, these companies are required to safeguard your information and use it only for authorized purposes.
Joint marketing partners:
" From time to time, we carefully select nonaffiliated business partners with whom we have joint marketing agreements to provide our owners with specialized products and services. Although these partners are not owned by or affiliated with SBG, they work closely with us to help us meet your needs. If appropriate, we may disclose to these marketing partners the nonpublic personal information about you described above; however, we do not share any data other than contact information. Our partners must agree to safe-guard fully the confidentiality of owner information, and they are not allowed to disclose such information to anyone else without our permission.

Other nonaffiliated third party companies:
" We may share your nonpublic personal information with nonaffiliated third party companies other than those described above. You may choose not to have your information disclosed to these companies as discussed in the Section titled "How to opt out of having nonpublic personal information disclosed."

Consumer reporting agencies:
" As applicable, in accordance with standard industry practice, and as allowed under federal and state law, SBG routinely provides data about transactions to credit reporting agencies and other creditors.

Courts and government entities:
" Certain federal and state statutes may require us to disclose certain information about you. For example, if you are involved in litiga-tion with a third party, we may be ordered to provide information to a court or the other litigant. In these circumstances, only the spe-cific information required by law, subpoena, or court order will be disclosed.

What This Privacy Policy Covers.
" This policy covers how SBG treats personal information that SBG collects and receives, including information related to your past use of SBG products and services.

Personal information is information about you that is personally identifiable like your name, address, email address, or phone number, and that is not otherwise publicly available.
" This policy does not apply to the practices of companies that SBG does not own or control, or to people that SBG does not employ or manage.
Cookies.
" SBG may set and access SBG cookies on your computer.
" SBG lets other companies that show advertisements on some of our pages set and access their cookies on your computer. Other companies' use of their cookies is subject to their own privacy policies, not this one. Advertisers or other companies do not have access to SBG cookies.
" SBG uses web beacons to access SBG cookies inside and outside our network of web sites and in connection with SBG products and ser-vices.
Confidentiality and Security.
" We have physical, electronic, and procedural safeguards that comply with federal regulations to protect personal information about you.
Minors.

SBG does not seek to obtain nor does it wish to receive personally identifiable information directly from minors; however, we cannot always determine the age of persons who access and use our web sites. If a minor (as defined by applicable law) provides us with his/her data without parental or guardian consent, we encourage the parent or guardian to contact us to have this information removed and to unsubscribe the minor from future SBG marketing communications.

Fair Credit Reporting Act:
You should also know that even if you opt out of information disclosure, the Fair Credit Reporting Act and other laws nevertheless allow us to share with our affiliates and other companies specific details about your transactions and experience with us, including information about your account balances and payment history.