SAVANNAH QUARTERS® PRIVACY POLICY

Savannah Quarters® Development Company, LLC (the “Company”) has a strong commitment to providing excellent service to all of our customers and visitors of the SavannahQuarters.com web site (the “Web Site”), including respecting concerns about privacy. The Company is committed to respecting your online privacy and we recognize your need for appropriate protection and management of any personally identifiable information (“Personal Information”) you share with us.

The Company has established this online privacy policy (this “Policy”) so that you can understand the care with which we intend to treat your Personal Information. Personal Information means any information that may be used to identify an individual, including, but not limited to, a first and last name, a home or other physical address, an email address or other contact information, whether at work or at home. In general, you can visit the Web Site without telling us who you are or revealing any Personal Information about yourself. Unless you voluntarily and knowingly provide us with Personal Information, we will not know your identity, your email address or any other information identifiable to you.

This Web Site is not intended for children, and we do not knowingly solicit or collect personally identifiable information from children.

Links to Other Web Sites

The Company provides links to other web sites for your convenience and information. The Company is not responsible or liable for any content presented by or contained on any independent web site, including, but not limited to, any advertising claims or marketing practices. Please note that while the Company will protect your Personal Information on Company-owned and -operated web sites, we cannot control and will not be responsible for the privacy policies of third-party web sites. Third-party web sites that are accessed through links on our web sites have separate privacy and data collection practices, and security measures. We have no responsibility or liability for the practices, policies and security measures implemented by third parties on their web sites. We encourage you to contact them to ask questions about their privacy practices, policies and security measures before disclosing any personally identifiable information. We recommend that you review the privacy statements and policies of linked web sites to understand how those web sites collect, use and store information.

QUESTIONS AND ANSWERS REGARDING THE POLICY

How does the Company collect Personal Information?

  1. Information Voluntarily Provided

When we need to collect personally identifiable information from you to provide you with a particular service, we will ask you to voluntarily supply us with the information we need. For example, if you would like to register as a VIP Member of Savannah Quarters®, book a round of golf or purchase products offered by the Company, we will ask you for information such as name, address, telephone number, email address and credit card number. In addition, if you are a member of certain clubs operated by the Company, you will have the ability to access the members-only portion of the Web Site, which may contain or request, among other things, selected Personal Information.

We may also ask you to fill out an online customer survey, to obtain your suggestions or comments about your use of our services or for similar purposes. Providing this information is solely at your choice.

  1. Upon Initial Contact with the Web Site

When you visit the Web Site, you are initially given a “cookie,” and your computer is assigned an ID number. A cookie is a small text file that may be used to collect information about web site activity. Cookies allow us to provide a customized experience without the visitor having to remind us of his or her preferences each time she or he visits our site. Our cookies do not contain any Personal Information. The Company’s cookies also do not follow visitors when traveling on the Internet after leaving the Web Site.

We also use cookies to collect and maintain data for the Web Site, such as the number of visitors. Among other things, this helps us improve and update the Web Site. If you do not wish to receive these cookies, you may set your browser to reject the cookies, although doing so may affect your ability to perform certain transactions on the Web Site.

What Personal Information may be shared with third parties?

Agents, contractors or third-party service providers of the Company may receive your Personal Information in the course of providing services to the Company to better serve the needs of our customers. Using contractual or other arrangements, the Company ensures these parties protect your Personal Information in a manner consistent with the principles articulated in this Policy.

We will only share Personal Information about you outside the Company without your consent, where: (i) it is required or authorized by law; (ii) it is required to provide you with products or services you have requested, in which case you will be considered to have implied your consent; (iii) if your products or services have been paid for by a third party, we will provide billing information to the paying party; (iv) if you have failed to pay amounts owed for a product or service.

If the Company suspects any unlawful activity is taking place, it may investigate and/or report its findings or suspicions to the police or other relevant law enforcement agency.

Information may be shared across and among entities affiliated with Savannah Quarters®, including, without limitation, Savannah Quarters® Realty and LStar Ventures.

Are email communications secure?

It is important to note that any email communication is not secure. This is a risk inherent in the use of email. Please be aware of this when requesting information or sending forms to us by email (for example, from the Contact Us section of our Web Site). We recommend that you do not include any confidential information, such as credit card information, when using email. For your protection, our email responses to you will not include any confidential information.

What security features protect information on the Web Site?

Although “guaranteed security” does not exist either on or off the Internet, the Company safeguards information used in connection with financial transactions on the Web Site by using the following information security techniques and procedures:

Information is exchanged via Secured Socket Layer (SSL) that uses 128-bit encryption.

Information requests must pass through multiple hardware and software security firewalls.

The Company utilizes Verisign’s Secure Site services for applications that process financial transactions.

The Company is subject to internal audits and continually strives to improve its systems and procedures based on audit recommendations.

Why does the Company collect Personal Information?

  1. Customer Service

Personal Information is collected to assist us in providing the products or services you request. By keeping Personal Information on file, customers have the ability to confirm prior transactions and reconcile statements or invoices.

  1. Informative Purposes

We may also use Personal Information to advise you of promotions or to inform you of offers or other information that may be of interest to you. In order to do this, your information may be shared with a third party, including a customer relationship management company and/or a marketing and communications company. These companies will be under contract with the Company and must agree that guest information will never be sold, rented, exchanged or in any way transferred. If you do not wish to receive information from the Company you may advise us by contacting us in accordance with this Policy.

  1. Marketing Research

Finally, we may wish to contact customers to conduct surveys or focus groups to receive your views of our service delivery. Such information may be collected by a third party under contract with us, and they will be required to protect your Personal Information. Occasionally, we will combine information from a number of customers to better understand trends and expectations of our customers. When this occurs, all identifiers are removed so that the aggregate information cannot be linked to specific guests.

How do I access my Personal Information?

Upon inquiry, the Company will inform you of what Personal Information we hold about you. To protect your Personal Information, however, we require that you prove your identity to us at the time your request is made. You may make a request to the Company as set forth below.

When you make a request in person, we will require you to produce some form of photo identification, such as a passport or a driver’s license, and you will be asked to sign a request form.

Where you make a request by other means, we require the request be made in writing via fax or letter, including a copy of a government-issued identification and signature. We also require home and business addresses and phone numbers so we can check them with our files and satisfy ourselves as to your identity.

The above information is required to create an audit trail of how the request has been handled. Where a request is made, any correspondence or application may be kept and added to your Personal Information.

The Company reserves the right to decline access to your Personal Information under certain circumstances.

How long does the Company retain my Personal Information?

Your Personal Information will be stored for the period of time required by applicable law, and it may be stored indefinitely by the Company as long as there is a business purpose for doing so. We may delete your Personal Information from time to time.

Will I know if there are changes to this Policy?

If we decide to change our Policy, we will post those changes on the Web Site. Changes will not apply retroactively to Personal Information for which you have given explicit consent, which was acquired before the change to the Policy, except as may be required by law.

Who do I contact if I have questions or concerns regarding this Policy?

If you have questions or concerns regarding this Policy or if you would like to review or update your Personal Information in accordance with the other provisions of this Policy, you can contact us: 200 Blue Moon Crossing, Pooler, GA 31322, Phone: (912) 450-2300.