Effective: September 15, 2005

Protecting the Privacy and Security of Your Personal Information is Very Important to Us

Pacific Monarch Resorts, Inc. (“PMR”) strives to provide an excellent array of vacation-related products and services, including the Monarch Grand Vacations ("MGV") program – a points-based vacation resort ownership program featuring a variety of beautiful resort locations. PMR collects information about customers and prospective customers both offline and online in order to provide a vacation resort ownership experience that is tailored to your interests. PMR's Privacy and Security Policy is intended to protect your privacy and ensure that your personal information is handled in a safe and responsible manner.

This Privacy and Security Policy applies to PMR and the following PMR-affiliated entities:

Vacation Marketing Group, Inc.
Vacation Interval Realty, Inc.
Monarch Owner Services, Inc.

This Privacy and Security Policy also applies to the websites found at the following Internet addresses: www.pacificmonarch.com, www.pmonarch.com, www.monarchgrandvacations.com, www.rivierabeachandspa.org, www.rivieraoaks.org, www.palmcanyonresort.org, www.rivierashores.org, and www.cancunresort.org, www.caboazulresort.com and any other websites that may be directly affiliated with PMR or those resorts that are a part of the MGV program.

PMR's Privacy and Security Policy Will Change Over Time

By registering on and/or using PMR's websites, you consent to the collection and use of your personal information by us. Because we continue to develop and improve the vacation resort products and services we offer, our policies will change over time. We encourage you to review this Internet Privacy and Security Policy from time to time to stay abreast of our most current privacy and security policies and practices. Your continued access and use of PMR's websites will constitute your acceptance of any changes or revisions to our Privacy and Security Policy.

Summary of PMR's Privacy and Security Policy

This Privacy and Security Policy explains and summarizes how we collect, use, share and protect your personal information as you interact with our sales, marketing, and customer service personnel both online and offline. This Privacy and Security Policy explains:

• What types of information PMR gathers from consumers who inquire about PMR's products or services, apply to purchase such products or services, apply to us for the financing of their vacation resort ownership purchase, and who use our websites.
• How PMR uses the personal information that you share with us and the information we learn about you as a result of our relationship.
• How PMR uses log files, “cookies” and other Internet-related tools.
• What personal information, if any, PMR may share about you with others and the conditions that protect your information if it must be shared.
• What kind of security measures PMR takes to protect your information from loss or disclosure and how PMR will inform you in the event of a security breach.
• The circumstances under which you can access the personal information you have shared with PMR in order to have that information corrected, restrict PMR’s use of that information, and/or have it removed from our records.
• Other things you should know about privacy and your relationship with PMR.

The Types of Information PMR Collects About You

PMR collects information you provide to us or that we learn about you through a variety of ways, including through your use of our websites, your inquiries regarding PMR's products or services, or your application for the purchase of PMR's products or services. For example, you may provide information to PMR when you register with, sign into, or search any of our websites. You may also provide information to PMR whenever you participate in a survey, request our marketing brochures, or communicate with PMR’s customer service personnel. As a result of those actions, you might provide us with information such as your name, address, phone number, email address, and product or service preferences. We also automatically gather and store certain types of information whenever you visit one of our websites. We might also receive information about you from other sources, and we may add that information to our database in order to, for example, provide you with special offers that we think will be of interest to you.

If you apply through us for the financing of your MGV vacation resort ownership purchase, we may also collect personal information about you from the following sources: applications or other forms (including collecting of information such as name, address, social security number, assets, and income); your financial transactions with us and other financial organizations; consumer reporting agencies (to obtain information regarding credit worthiness and credit history); information from outside sources regarding your employment, credit and other relationships; data from public records; and as may be required by the USA PATRIOT Act to verify your identity.

How PMR Uses Information About You

PMR collects and uses personal information from you in several key ways:

• Website usage. PMR or PMR’s authorized service providers may observe activities, preferences and transactional data (such as your IP address, browser type and operating system) relating to your use of our websites. We may use this collected or logged information in order to provide better service, to facilitate improved use of our websites, to track usage of the website, to address security hazards, and to track aggregate traffic patterns throughout our websites. We may use aggregated, statistical information to describe our customer audience, products and services, and to develop partnerships with third parties to offer products and services in which we believe our customers will be interested. For example, if 30% of our customers are interested in air flights to Mexico, we may share that statistic with travel service companies in order to explore the possibility of offering our customers access to such air travel directly through our website.

• Online Transactions. We collect information about you whenever you use our websites and we may use the information for PMR's marketing purposes. Our customers are given the option to access their account online. In order to access such online services and protect your account information, you will be asked to choose a password, and you may be required to provide your name, account number, email address and other basic personal information. If you choose not to provide the information, your ability to access certain online features may be denied. For example, if you should forget your password and you have not provided us with your email address, we will be unable to email your password to you.

• Account Information. We collect information from you, about you from credit reporting agencies, and from other sources when you apply through us to obtain financing of your MGV vacation resort ownership purchase. We use this information to provide you with financing. We also use this information to service and collect on your account.

Disclosures to Unaffiliated Third Parties for Marketing Purposes.

We do not sell your personal information to third parties for any reason. We do not disclose your personal information to unaffiliated third parties who may want to offer you their own products and services unless you have requested or expressly authorized us to do so. We may, however, send directly to you information about these unaffiliated third parties’ products and services if we believe they may be of interest to you.

We may disclose personal information regarding our customers to third parties for certain non-marketing purposes, such as disclosures that are required or permitted by law. We may make disclosures if required by law, such as in connection with a subpoena or similar legal process. We may also disclose personal information as permitted by law, such as when we believe that action is necessary to investigate or protect against harmful activities to PMR guests, visitors, employees, or property (including our websites), or to others.

We may also disclose personal information in connection with a merger, acquisition or bankruptcy. We may also disclose personal information about our customers to credit bureaus and similar organizations in connection with our financing or collection activities.

We do not disclose personal information about former customers, except as permitted or required by law.

No Disclosures to Affiliates for Marketing Purposes.

We do not share your personal information with PMR affiliates for the purpose of those affiliates offering their own products and services to you. Your personal information is shared with PMR affiliates only so that our affiliates may market PMR's products or services or otherwise provide services on PMR’s behalf.

Disclosures to Affiliated or Third Party Service Providers.

We may share your personal information with third parties or affiliates of PMR, which may include both financial service entities and non-financial companies, where it is necessary for us to complete a transaction or do something you have asked us to do. For example, we might need to provide your personal information to a third party or an affiliate to assist you with obtaining financing for your MGV ownership or so they can process and fulfill your request for information about special guest services at a PMR resort.

We may share your personal information to third parties or affiliates of PMR with whom we have contracted to perform services on our behalf. Our affiliates perform sales, marketing and customer service activities on our behalf. All companies that act on our behalf are contractually obligated to keep the personal information we provide to them confidential and to use such information only to provide the services we ask them to perform. For example, we may use an outside company to deliver promotional materials regarding our resorts. We may also use a credit card processing company to bill customers for their purchase of certain PMR products and services. These companies are not authorized to retain, share, store or use personal information for any secondary purposes.

You Have Choices When It Comes to How PMR Uses Your Personal Information for Direct Marketing

All customers who register to access their account information online will receive a welcome email immediately after completing the online registration form. Registered customers will occasionally receive information regarding products, services, or special promotions. We do not want to send promotional materials you do not want to receive, nor do we want to contact you via email or telephone regarding PMR's products, services, or special promotions if you do not wish to receive such emails or telephone calls. As such, you may choose not to receive marketing offers from us by direct mail, telephone and/or email. Please note that, even if you elect to not receive marketing information from us by direct mail, telephone or email, you will continue to:

• Be contacted as necessary to service your account.