MCCULLOUGH-AMES DEVELOPMENT, INC. PRIVACY POLICY

PLEASE READ THE FOLLOWING PRIVACY POLICY CAREFULLY BEFORE ACCESSING ANY PART OF THE WEBSITE

1. Overview. McCullough-Ames Development, Inc. (the “Company”) recognizes and respects the privacy of users of the Website. The following privacy policy, as modified from time to time by us as described below (the “Policy”), tells you about the information that the Company collects through the Website, how we use that information and how you can opt out of certain uses of information we may collect. If you access the Website, you are consenting to the information collection and use practices described in this Policy, as modified from time to time by us.

2. Information The Company May Collect About You.

We collect the following types of information on the Website:

• "Personal Information" is information that is used by the Company to identify you individually, such as your name, address, phone number or e-mail.
• "Aggregate Information" is information that does not contain Personal Information or from which Personal Information has been removed. An example of Aggregate Information is information about use of the Website, such as pages visited on the Website.
• "Financial Information" means financial information collected during the online mortgage or loan application process. Financial Information is collected and used in accordance with the policies outlined by the privacy policy of our mortgage joint venture, if the mortgage joint venture is collecting the information.

The actual information we collect from you depends on the services you use on the Website. The following is a more detailed explanation of some of the types and uses of information we collect.

• Information Request Form. The Website contains a request form that allows you to request information regarding the Company and its communities. For instance, we may collect information such as your communities of interest. When we collect such information, we may share it with third parties as is necessary to respond to your request.
• E-mail Services. If you provide us with your e-mail address and opt in to any e-mail notification features that the Company may now have or may develop in the future, you may receive e-mail from time to time from the Company. Each e-mail you receive from the Company will contain an “unsubscribe” disclaimer at the bottom of the e-mail message which will provide you the opportunity to opt out of receiving future communications from the Company by replying with “unsubscribe” in the subject line.
• Administrative Purposes. We may collect and use information that identifies you personally when you submit comments, questions or requests through the Website. For example, if you submit comments, questions or requests, we will use the information you provide to respond to you. We also may collect and use your information to contact you when necessary for other administrative purposes. If you do submit comments, questions or requests through the Website, please do not include confidential personal or financial information in such requests. Such e-mail will be maintained in accordance with our corporate e-mail and document retention policies.

3. Disclosure of Your Personal and Aggregate Information.

Personal Information. The Company will not sell or disclose your Personal Information without your consent except as set forth below.

• Transaction Processing. When you complete an information request form or otherwise indicate to us you want us to provide you with a product or service (such as a request to be included in mailings about our future projects), we share and maintain the data needed for you to receive the products or services you have requested.
• Consultants. From time to time the Company engages consultants that may need access to the information we collect to perform their services for us, such as administering our mailing lists. We require that our consultants keep Personal Information confidential and use it only in accordance with the service agreement between the Company and such consultant.
• Legal Requirements. We may disclose your Personal Information if required to do so by law or if we believe that such action is reasonably necessary to: (a) conform with the law, respond to claims or comply with legal process served on the Company or the Website; or (b) protect and defend our rights or property, including the Website, our employees, guests or the public.
• Company Sale. Because information collected through the Website is a trade secret and asset of the Company, we may disclose or sell such information in the event we entertain the sale of the Company or some or all of its assets.

Aggregate Information: The Company collects "Aggregate Information" about you and your use of the Website whenever you visit the Company online. For instance, the Company may collect various forms of "click stream" information such as entry and exit points for our Website (i.e., referring URLs or domains), site traffic statistics, page views, impressions, and operating system and browser type. In addition, when users request pages on the Website, the Company’s servers automatically log the users IP address. An IP address is a number that is automatically assigned to your computer whenever you are surfing the Web. The Company may collect, compile, store, publish, promote, report, sell, or otherwise disclose or use any and all Aggregate Information. However, if the Company correlates any Aggregate Information to you, such information will be treated like Personal Information under this Policy.

4. Opting Out, Removal of Personal Information and Contacting Us. To opt out of receiving marketing information or to unsubscribe from any specific e-mail service, e-mail a request to brett@mccullough-ames.com. If you have questions or concerns about this Policy, or the accuracy of any Personal Information we hold about you, please contact us at brett@mccullough-ames.com. You may request removal of your Personal Information from our system(s) by contacting brett@mccullough-ames.com. We will comply with your request except to the extent we are required to maintain your information in accordance with our document retention policies or applicable laws or regulations. If at any time you feel the Company has not adhered to this policy, email us at brett@mccullough-ames.com. We will do our best to respond promptly to your concerns.

5. Outside Links. While on the Website, you may be referred to web sites other than the Company’s Website. A link from the Website to such a third party website does not imply endorsement of that site nor any ability to control that site's privacy practices. Be aware that third party websites may collect data and personal information and operate according to their own privacy practices. Therefore, you should carefully review the privacy policies of third party websites before submitting any Personal Information to them.

6. Security. The Company uses reasonable efforts to store and maintain personal information to protect it from loss, misuse, alteration or destruction by any unauthorized party. We store no financial information or social security information on the Website. We make reasonable efforts to attempt to prevent the unauthorized access of our systems containing personal data.

7. Cookies. The Company may make use of "cookies" on the Website. Cookies are small text files that are stored on a user's computer by a web server based on the permissions set in a user's browser software. A cookie itself is not designed or intended to read any information from a user's computer (other than the contents of the cookie); rather, it is an identifier used by the website that originally placed it on your hard drive. The actual contents of the cookie information can be retrieved by the same server to identify the computer and subsequently to customize, monitor, or regulate the use of a site based on information stored in the cookie and the host server. Therefore, cookies only identify the user's computer to the website that may correlate other information, including personal information, with the cookie. Cookies allow the Company to automate access and data entry functions of the Website such as tailor the Website to your preferences or interests or customize promotions or marketing. In addition, cookies allow us to track usage of the Website to determine which areas are useful or popular and which are not, thereby enabling us to improve and update the Website effectively.

8. Effective Date and Updates. This Privacy Policy is effective at 10:00 a.m. on March 12, 2007. The Company reserves the right to make changes to this Policy at any time, and will post any revised Policy on this page. You will know we have changed the Policy when you see a new effective date in the first sentence of this paragraph. The Company will not notify its Website visitors or customers of any such changes by e-mail or other personal contact. We encourage you to check the date of this Policy whenever you visit this Website so that you will know when you need to review the Policy for modifications. Please note that this Policy applies to all information collected online by the Company, but does not apply to personal financial information that may be collected by any of our mortgage banking or title joint ventures, each of whom have their own privacy policies.