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Privacy Policy

Revised October 24, 2008

About this privacy statement

HOEM Asset Disposition Management LLC, has created this Privacy Statement in order to demonstrate our firm commitment to your privacy. This Privacy Statement describes the information we collect and our procedures regarding use and disclosure of this information. Note: You may not provide information to us unless you are at least 13 years of age and a resident of the United States. By providing information you consent to the policies and practices described in this privacy statement. The following definitions are important.

Cookies

A cookie is a randomly generated unique number placed on your computer. It allows us to identify your computer without requiring your disclosure of any non-public personal information (see definition below). Cookies make it possible to both store and retrieve information through your Internet browser. A cookie itself cannot read information off a hard drive or read cookie files from other sites. General information is information that does not itself reveal your identity. General information may include, without limitation: generic business type; SIC code; information derived from publicly available databases (such as Dun and Bradstreet); user behavior on our Web site; and aggregated generic information. Non-public personal information is any non-public information you provide to us or our partners that is proprietary or identifies or can be used to identify, contact, or locate you or someone at your business. Non-public personal information may include, without limitation: name, address, phone number, e-mail address, credit card number, account information, voting behavior, spending patterns and individual tastes and preferences. Partners are individuals or entities we engage to help us carry out our mission.

What information is collected?

We collect the non-public personal information you provide to our partners or us. We also collect your general information.

How do we use and disclose your non-public personal information?

Unless otherwise required by law, we use and disclose your nonpublic personal information only as necessary to carry out our mission. This may include, without limitation: selectively sharing your non-public personal information with our partners; alerting you of relevant legislative and political initiatives; notifying you of any benefits offered by our partners; and updating you about our objectives. We will not sell or otherwise disclose your non-public personal information to any third party unless such third party is performing services for or on our behalf and is bound by an obligation of confidentiality.

Who are some of our partners?

We have negotiated agreements with vendor partners who will offer you access and discounts on products and services. We periodically engage call centers, mailing houses, printers, research firms and other third-party representatives to assist us in servicing our clients.

How do we use and disclose your general information?

General information collected on our Web site (such as user behaviors) may be used to internally help administer the Web site and detect server problems.

How do we protect the confidentiality of your non-public personal information?

We have taken reasonable steps to assign passwords, encrypt sensitive data and protect our databases, servers and other information storage locations from unauthorized access. Our employees are subject to written policies regarding the use and disclosure of your non-public personal information. These precautions are not an absolute guarantee of security from unauthorized access and you submit all non-public personal information at your own risk.

How can you opt-out of receiving e-mails, mail, phone calls and/or faxes from us?

We may periodically contact you via e-mail, phone, mail and/or fax regarding various topics. Should you wish to suspend this service, you may "opt-out" by contacting us at info@hoem.com, or at 2888 Loker Avenue, East, Ste. 112, Carlsbad, CA 92010 and we will promptly remove your contact information from the appropriate distribution list. In addition, each e-mail or fax you receive will contain instructions on how to unsubscribe from a particular e-mail or fax service.

Will this Privacy Statement change?

We periodically review our privacy practices. This Privacy Statement may be revised at any time. Notice of a revision to the Privacy Statement will be prominently displayed on our Web site at HOEM.com/privacy_policy.php.

How do we use cookies?

A primary purpose of cookies is convenience. For example, a cookie informs our server that you have returned to our Web site. Because the cookie allows our server to recall your unique information on subsequent visits, you will not be required to enter your user name and password if you have one.

What are the privacy practices for forums, chat rooms and message boards on our Web site?

We may make chat rooms, forums, message boards and news groups available to our registered clients through our Web site. We make reasonable efforts to moderate and supervise the discussion in such areas. All information that is disclosed in these areas becomes public information and you should exercise caution before disclosing non-public personal information.

What is our linking policy?

Our Web site may contain links to other destinations on the Internet. We are not responsible for the privacy practices of any other party. We strongly encourage you to read the privacy policies of each and every Web site that collects non-public personal information.

How can you change or remove your non-public personal information?

You may remove or revise your non-public personal information through our Web site by contacting us at info@hoem.com, or at 2888 Loker Avenue, East, Ste. 112, Carlsbad, CA 92010 and we will immediately revise or remove your non-public personal information. Unless you instruct us otherwise, we will archive your non-public personal information indefinitely.