Barratt American, Inc. Privacy Policy

General Information Barratt American, Inc. respects the privacy of our customers, business partners and employees. We recognize the need for appropriate protections and management of your personal information that you provide to us. Barratt American has therefore established this Privacy Statement to assist you to understand what information we collect and how that information is used. This Privacy Statement applies to Barratt American, Inc. and its subsidiaries.

What personal information does Barratt American collect?
Personal Information is information that can be used to identify or contact a specific individual, such as a name, address, and telephone number or email address. Barratt American may collect certain personal information from customers, business partners, employees and candidates for employment. Barratt American does not collect personal information when you visit Barratt American 's web sites unless you choose to provide such personal information.

On Barratt American web sites you can order products or services, request information, subscribe to marketing or support materials, register to a secure extranet site to obtain access to product information, support, services and training, or apply for jobs at Barratt American . The types of personal information you provide to us on these pages may include name, address, phone number, e-mail address, user IDs and passwords, contact preferences, educational and employment background, job interest data and benefit choices.

How does Barratt American use personal information?
Barratt American will use personal information to provide customers and business partners with information and services and to help us better understand your needs and interests. Specifically, we use your information to help you complete a transaction or order, to communicate with you, to deliver products/services to you, to bill you for products/services you purchased, and to provide ongoing service and support. Occasionally we may use your information to contact you to complete surveys that we use for marketing and quality assurance purposes. Personal information collected online may be combined with information you provide to Barratt American through other sources such as events or seminars. Barratt American may share your personal information with third parties in responding to your requests for products or services or product evaluations. Also, we may on occasion allow selected partners to send you special offers in blind mailings. If you request information on any of our products/services, Barratt American may provide your information to third party distributors and resellers who may subsequently contact you directly to purchase such products/services.

To the extent that Barratt American uses personal information to email you about our product and services, Barratt American 's email practices are in compliance with the U.S. and E.U. SPAM laws. Information about the U.S. and E.U. SPAM laws can be found at http://www.spamlaws.com/.

Except as provided in this Statement, Barratt American does not use your personal information for a purpose other than the stated purpose for which such information is collected.

Personal information given to Barratt American may be transferred across state and country borders for data consolidation, storage and simplified information management.

With whom does Barratt American share personal information?
Barratt American contracts with third party service providers and suppliers to deliver complete products, services and customer solutions. Barratt American may share personal information with its service providers and suppliers for the sole purpose and only to the extent needed to support the customers' business needs. Service providers and suppliers are required to keep confidential the personal information received from Barratt American and may not use it for any purpose other than as originally intended. Third parties receiving personal information are expected to apply the same level of privacy protection as contained in this Privacy Statement. Except as provided above, Barratt American will not share personal information with any other third parties without your permission, unless required by, or in connection with, law enforcement action, subpoena or other litigation, or applicable law.

Barratt American will not sell or lease your personal information to others.

Choice & Consent
Barratt American does not require that you provide Barratt American with personal information. The decision to provide personal information is voluntary. If you do not wish to provide the personal information requested, however, you may not be able to proceed with the activity or receive the benefit for which the personal information is being requested.

Except as expressly stated otherwise in this Privacy Statement, you may opt out of having Barratt American share personal information with third parties as described in this Privacy Statement by notifying Barratt American in writing of your desire to do so.

Access to and accuracy of your information
Barratt American strives to keep your personal information accurate. We have implemented technology, management processes and policies to maintain data accuracy. We will provide you with access to your information, including making reasonable effort to provide you with online access and the opportunity to change your information. To protect your privacy and security, we will also take reasonable steps to verify your identity, such as a password and user ID, before granting access to your data.

Barratt American will not process personal information in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the individual, as required by applicable law.

Security of Personal Information
Barratt American is committed to taking reasonable efforts to secure the personal data you choose to provide us. To protect the privacy of any personal information you may have provided, Barratt American employs industry-standard controls including physical access controls, Internet firewalls, intrusion detection, and network monitoring. In addition, access to sensitive data as defined in this Statement is limited to those individuals and agents having a need to know.

Other Information/Logging and Cookies
Barratt American collects and/or logs Internet Protocol addresses, Internet domain names, the web browser and operating system used to access the Barratt American web site, the files visited, the time spent in each file, and the time and date of each visit.

Barratt American also uses cookies on some of its web sites. Cookies are identifiers that can be sent from a web site via your browser to be placed on your computers hard drive. Thereafter when you visit a web site, a message is sent back to the web server by the browser accessing the web site. You may elect not to accept cookies by changing the designated settings on your web browser. However, not utilizing cookies may prevent you from using certain functions and features of web sites. The information collected from the use of cookies is used and analyzed to improve Barratt American 's web sites.

You can set your browser to notify you when you are sent a cookie, giving you the chance to decide whether or not to accept it. The information we collect and analyze is used to improve our service to you and personalize your web-browsing experience.

Links to Non-Barratt American Web Sites and Third Parties
The Barratt American web sites may provide links to third-party web sites for your convenience and information. If you access those links, you will leave the Barratt American web site. Barratt American does not control those sites or their privacy practices, which may differ from Barratt American's. We do not endorse or make any representations about third party web sites. The personal data you choose to give to unrelated third parties is not covered by the Barratt American Privacy Statement. We encourage you to review the privacy policy of any company before submitting your personal information. Some third party companies may choose to share their personal data with Barratt American ; that sharing is governed by that third party company's privacy policy.

Verification
Barratt American will engage in periodic self-assessment to verify that it continues to be in compliance with this Privacy Statement.

Contact Information
If you have any questions regarding the Privacy Statement or believe that the privacy of your personal information has not been respected, you may submit a complaint in writing to the attention of Barratt American 's corporate headquarters at 5950 Priestly Drive, Suite 101 Carlsbad Ca 92008

Dispute Resolution
Except as provided above, dispute resolution for all other individuals shall be in accordance with applicable law.

Changes to this Statement
Barratt American will review and update this Statement periodically.

June / 2005