PRIVACY POLICY

The Pacific Club IMPACT Foundation® and The Lott Trophy® network of web sites including thelotttrophy.com (collectively referred to as the "Network Sites") are committed to safeguarding your privacy. This privacy policy ("Policy") describes the information we may collect, how we may collect and use it, with whom we may share it, and certain other privacy issues, including the precautions we take to protect your privacy.

BEFORE USING OR SUBMITTING INFORMATION TO ANY OF THE NETWORK SITES, PLEASE READ THIS POLICY.

Use of any part of the Network Sites including but not limited to thelotttrophy.com indicates your acceptance of this Policy and agreement to the collection and use of your personal information in accordance with this Policy. Please note that this Policy applies only to personally identifiable information collected on the Network Sites.

TYPES OF INFORMATION THAT MAY BE COLLECTED

The following are the types of information we may collect:

Information You Provide Us
Personal information you provide us, such as a user ID and password, name, e-mail address, telephone number, physical address, birth date, gender, zip code or other information may be collected via the Network Sites.

Network Sites Usage Information
We may receive and store certain types of information whenever you visit the Network Sites. For example, we may collect click-stream data and your IP address.

E-mail Communications
When you open e-mails from the Network Sites, we may receive a confirmation noting you opened the e-mail, if your computer supports such capabilities. We also may keep track of which e-mails we send you and which e-mails you may receive from our partners, subsidiaries and affiliates. Additionally, we keep a record of what types of e-mails you have opted to and not to receive.

Information from Other Sources
We may add information from other sources to your personal information.

HOW INFORMATION MAY BE COLLECTED

We may collect information from you in different areas on the Network Sites, including but not limited to those described below:

Registration
You may be asked to complete a registration form and provide personally identifiable information, including a user ID and password, to access certain features on the Network Sites, including, but not limited to, Newsletters, Contests, Forums, store purchases, or other subscription-based or free services.

Newsletters and Network Sites E-mails
We may offer free newsletters to share information with you about the Network Sites, school, The Pacific Club IMPACT Foundation® and The Lott Trophy®, our partners, affiliates and subsidiaries, or our advertisers and sponsors. You may receive a newsletter either by registering for a specific newsletter or in conjunction with a special feature or membership for which you have registered on the Network Sites. You may cancel your free e-mail subscription by following the instructions provided on the Network Sites or, in some instances, in the designated area of certain newsletters or e-mails.

Contests or Sweepstakes
We may operate contests and sweepstakes through the Network Sites, which may require registration. Your personally identifiable information may be used to contact you for winner notification, prize delivery confirmation or other related purposes. We may ask your permission to allow us to post publicly some of your information on the Network Sites, such as on a winner's page, in the event you win a contest or sweepstakes. We will not post your information without your permission. In some instances, a third party advertiser or sponsor may operate or host a contest or sweepstakes on the Network Sites, and collect your information. In those cases, when we are not the operator or host of the contest or sweepstakes, we have no control over the information collected and accordingly urge you to review the advertiser's or sponsor's privacy policy applicable to the contest or sweepstakes before participating.

Surveys or Voting
From time-to-time we may request personally identifiable information from you via surveys or voting polls. Participation is voluntary and you will have the opportunity to decide whether or not to disclose information. At times, you may have to register to vote or to take part in a survey.

Cookies and Web Beacons
As with many Web sites, the Network Sites use standard technology called "cookies," which are small data files transferred to your computer when you allow your browser to accept cookies. Cookies automatically identify your Web browser to the Network Sites whenever you visit the Network Sites, and make the Network Sites easier to use by saving your passwords, purchases, and/or preferences. By tracking how and when you use the Network Sites, cookies help us determine which areas are popular and which are not. Many improvements and updates to the Network Sites are based on data obtained from cookies.

Accepting cookies may allow you, among other things, to personalize your experience on the Network Sites. Cookies may also allow the Network Sites to present to you advertising which may be of interest to you. If you do not want information collected through the use of cookies, you generally can opt out of providing this information by turning the cookies off in your browser; however, some areas of the Network Sites may not provide you with a personalized experience if you disable the use of cookies. Furthermore disabling cookies may prevent access to some Network Sites and/or may prevent portions of the Network Sites from being displayed or functioning.

We may also use technologies such as Web beacons that allow us to track general user-traffic patterns. Unless you have registered for one of our products or services, the information we gather through the use of tracking technologies cannot be matched with any personally identifiable information about you.

We may also allow other companies that are presenting advertisements on the Network Sites to use cookies, Web beacons, and/or other tracking technologies on your computer. We do not give any personally identifiable information to them as part of this relationship. Unless you visit the Web site of these companies and provide them with personally identifiable information about yourself, these tracking technologies tell those advertisers nothing about who you are. Our advertisers' use of tracking technology is subject to their own privacy policies.

IP Addresses and Click-stream Data
We may collect IP addresses and/or click-stream data for purposes of system administration and to report aggregate information to our advertisers and sponsors. An IP address is a number automatically assigned to your computer whenever you access the Internet. Our computers identify your computer by its IP address. When you request Web pages from the Network Sites, our computers log your IP address.

Click-stream data is information collected by our computers when you request Web pages from the Site. Click-stream data may include such information as the page served, the time, the source of the request, the type of browser making the request, the preceding page view and other such non-personal information. This data helps us understand how visitors arrive at the Network Sites, what type of content is most popular, what type of visitors in the aggregate are interested in particular kinds of content and advertising, and the like.

Transaction Information
If you order any information, buy any products, or subscribe to any services offered on our Network Sites, including but not limited to the Official Store, we will ask you to complete an order form that requires certain information, including payment information such as a credit card number and expiration date as well as general contact, billing and shipping information. We will use this information to complete the transaction, i.e., to deliver the information, products or other services you ordered, and to collect payment. For your protection, all such information is collected and stored through encrypted means. However, the encrypted means cannot be guaranteed to be 100% secure and we are not liable if the encrypted means is breached by a third party. By ordering any information, buying any products, and/or subscribing to any services offered on our Network Sties, including but not limited to the Official Store, you assume the risk that such a breach may occur.

HOW WE USE THE COLLECTED INFORMATION

Personally identifiable information will not be sold or otherwise transferred on an individual basis to unaffiliated third parties without the approval of the user at the time of collection. As a user, you will have the opportunity to indicate whether you would like to "opt out" of receiving promotional and/or marketing information about other products, services and offerings from the school, The Pacific Club IMPACT Foundation® and The Lott Trophy® and/or any third parties. The Network Sites reserve the right to perform statistical analyses of user behavior and characteristics in order to measure interest in and use of the various areas of the site and to inform advertisers of such information as well as the number of users that have been exposed to or clicked on their advertising banners. We do this to offer more targeted products and services to you and to customize and enhance your online experience on the Network Sites. We will not provide individual data but will provide only aggregated data from these analyses to third parties, unless you consent to such use. In addition, the Network Sites reserve the right to contact a subscriber regarding account status, changes to the subscriber agreement and other matters that relate to the underlying service and/or the information collected, regardless of whether the user has opted out of promotional activities on the site.

WITH WHOM THE INFORMATION MAY BE SHARED

At times, we may share your personally identifiable information with others for various purposes. The following outlines the ways in which your information may be shared with others:

Agents: We employ other businesses, certain services and individuals to perform functions on our behalf. Examples include order fulfillment, e-mail deployment, removing repetitive information from customer lists, Network Sites and data analysis, marketing assistance, credit card payments, and customer service. These entities only access the personally identifiable information to perform their functions, but may not use the information for other purposes.

Promotional Offers: We may e-mail you offers on behalf of other partners. When we do this, we do not give that partner your name and address. If you do not want to receive such offers, you may opt out in response to the e-mail.

Aggregate Information: We may share aggregate information such as demographics and Network Sites usage statistics with advertisers, sponsors or other organizations. When this type of information is shared, the other parties do not have access to your personally identifiable information.

Opt-in and Opt-out Programs: Throughout the Network Sites you may be presented with opportunities to receive special offers from third parties. An opt-in/opt-out message will ask you if you would like your information to be shared. If you do choose to have your information shared, all third parties who have access to personally identifiable information must abide by the current Network Sites' Policy. However, we are not responsible for the privacy practices of these other companies, and you should review the privacy practices of such Web sites prior to providing your personally identifiable information.

Partners Subsidiaries and Affiliates: We may share your information (including, without limitation, personally identifiable information) with partners, subsidiaries and affiliates of The Pacific Club IMPACT Foundation® and The Lott Trophy®.

Business Transfers: The Network Sites, the Pacific Club IMPACT Foundation®, and/or The Lott Trophy® may be sold along with its assets, or other transactions may occur in which your personally identifiable information is one of the business assets transferred. In such a case, your personally identifiable information, which we have gathered, may be one of the business assets transferred.

Legal Process: In the event we are required to respond to subpoenas, court orders or other legal process your personally identifiable information may be disclosed pursuant to such subpoena, court order or legal process, which may be without notice to you. Miscellaneous: We may also disclose personal information to protect and defend the rights of the Network Sites, the Pacific Club IMPACT Foundation®, and/or The Lott Trophy®.

Chat Rooms, Forums, and Message Boards
The Network Sites may make chat rooms, forums and message boards available to its users. While you are required to register with the site for access to these areas, you are not required to provide any personal information when using these areas but you may choose to do so. If you post personal information online, it will be publicly available and you may receive unsolicited messages from other parties. The Pacific Club IMPACT Foundation® and The Lott Trophy® cannot ensure the security of any information you choose to make public in a chat room, forum, or message board. Also, we cannot ensure that parties who have access to such publicly available information will respect your privacy. Please exercise caution when deciding to disclose personal information in these areas.

Links to Other Web Sites
This Policy applies only to the Network Sites. When you are on the Network Sites you could be directed to other Web sites beyond our control. For example, if you "click" on a banner advertisement, you may be taken to a different Website. This includes links from advertisers, sponsors and others that may use the Network Sites' logo as part of a co-branding agreement. These other Web sites may send their own cookies to you, independently collect data, or solicit personal information and may or may not have their own published privacy policies. If you visit a Web site that is linked to our Site, you should consult that site's privacy policy before providing any personal information.

SECURITY

The Network Sites incorporates reasonable safeguards to protect the security, integrity, completeness, accuracy and privacy of the personal information that we may collect and we have put into place reasonable precautions to protect such information from loss, misuse and alteration, such as Secure Sockets Layer or "SSL" and firewalls, to ensure that your information is secure and confidential. Certain personally identifiable information, such as credit card information, is transferred to our computers utilizing encryption software. Only those employees who need access to your information to carry out business functions are allowed access. Our security policies are reviewed periodically and revised as required. Many areas on the Network Sites require a password. We recommend that you do not share your password with anyone. It is important to recognize that whatever you transmit or disclose online could be collected and used by others or unlawfully intercepted by third parties. No data transmission over the Internet can be guaranteed to be 100% secure. While we strive to protect your information, we cannot warrant the security of any information you transmit to us.

CHILDREN'S PRIVACY

The Network Sites are general audience sites. We do not currently knowingly collect any personal information from children under the age of 13. If in the future, the Network Sites knowingly collects personally identifiable information from children, we will do so in compliance with the Children's Online Privacy Protection Act of 1998 (15 U.S.C. 6501 et seq.) including, without limitation, obtaining necessary parental consents. If you are under 13, you should only use the Network Sites with the involvement and consent of a parent or guardian and should not submit any personal information to us. We encourage all parents and guardians to monitor their children's use of the Internet. The Internet offers many entertaining and educational opportunities for children. Parental guidance and supervision is necessary to ensure a safe and rewarding online experience. A number of interactive features on the Site require registration to participate or will require registration in the future to participate (e.g. site registration/customization, contests, promotions). In many cases, users may be required to enter their first and last name, age, zip code and e-mail address. In some cases, users will be required to select a special user name to be used as an identifier for the feature and must also enter a password and a secret hint that will help us verify their identity if they forget their password. If the Network Sites determine that a person is under the age of 13, based on the information provided during the registration process, that person will not be permitted to register for features requiring the submission of personal information, in accordance with the Children's Online Privacy Protection Act of 1998 (15 U.S.C. 6501 et seq.). Children who indicate that they are under 13 years old will not be able to make credit card purchases or participate in interactive features on the Site that involve the collection and retention of personal information and they will not be contacted about special offers or promotions. The Network Sites work with (and may provide links to) third party sites. Such third parties may permit children under the age of 13 to register for these features on their sites in accordance with their respective privacy policies. For more information, please review the privacy policies of each respective third party site.

NOTIFICATION OF CHANGES AND YOUR ACCEPTANCE OF THE POLICY

By using the Network Sites, you agree to the terms of this Policy. All modifications or updates will be posted on the Network Sites. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify you by e-mail or some other means. Your continued use of the Site constitutes your acceptance of such revised privacy policy. If you do not agree to this privacy policy, please do not use our site.

CORRECTING/UPDATING PERSONAL INFORMATION AND OPTING OUT

If your personally identifiable information (such as your address) changes, or if you no longer desire to access our Network Sites, you may correct, update or remove the personal data you have provided to us by making changes to your profile, by using an opt out message in an e-mail, or by e-mailing the appropriate Web site of the Network Sites. For thelotttrophy.com, you may e-mail webmaster@thelotttrophy.com with your request. If you have any questions about this privacy policy or the privacy practices of the Network Sites you should contact the appropriate Web Site in the Network Sites. You can contact the Web site thelotttrophy.com at webmaster@thelotttrophy.com or at:

The Pacific Club IMPACT Foundation
4110 MacArthur Blvd
Newport Beach, CA 92660
Attention: Webmaster
Telephone Number of Designated Agent: (949) 955-1123
Facsimile Number of Designated Agent: (949) 724-8926
E-mail Address of Designated Agent: webmaster@thelotttrophy.com

If you opt-out by following the procedures described in the previous paragraph, it may take up to thirty (30) days (unless a shorter time period is required by applicable law) for the Network Sites to stop sharing your personal information for promotional purposes with the other sites within the Network Sites. In addition, it may take up to ninety (90) days (unless a shorter time period is required by applicable law) for the Network Sites to stop using your personal information for promotional purposes. Finally, please keep in mind that, if you have not consistently used the same postal and email addresses on the Network Sites, or if you have used a general change of address process (such as the change of address process offered by the U.S. Post Office) after providing address information the Network Sites, systems maintained by the Network Sites may have varying contact information for you. Accordingly, it may not always be possible to match your new opt-out choices with your personal information that you previously have provided.