Your privacy is very important to Phase 2 Solutions, Inc. ("we" or "us"), which owns the website located at www.winmyvacation.com ( "Site"). This privacy policy ("Policy") describes the practices that apply to our Site, including, specifically, the information we collect about you, when and how we collect that information and what may happen to that information. We have prepared a detailed policy because we believe you should know as much as possible about our practices so that you can make an informed decision about the extent of your use of our Site. By visiting the Site, you are accepting the practices described in this Policy and the Terms and Conditions of Use located at http://www.winmyvacation.com/terms.asp (the "Terms").

Changes to the Privacy Policy

We reserve the right to change the terms of this Policy. Since any changes will be posted on this page, we encourage you to check this page regularly. Your continued use of the Site following any changes to this Policy will constitute your acceptance of such changes. This privacy policy was last amended on the date listed at the end of this Policy.

Your IP Address

Each time you visit the Site, our web server automatically recognizes your IP address and the Web page from which you came. Your IP address is used to help identify you and to gather broad demographic information about you. We also use your IP address to help diagnose problems with our servers, to administer the Site, and to better serve you in using the services and features of the Site.

Cookies and Action Tags

The first time a user provides an e-mail address in connection with their activities on the Site, we assign an identification number to that e-mail address and deploy a cookie to the user's PC. Whenever that user comes back to the Site using the same PC, the cookie allows the Site to identify the user and to recall the user's e-mail address. If, at any time, a user provides other information in connection with their activities on the Site (such as name, address, birth date, gender, etc.), we may store that information, along with the user's e-mail address, in our user database. We may use the information stored in our database (i) for the purpose for which the information was originally provided by a user; (ii) to pre-populate information fields in the event a user wishes to sign up for and/or subscribe to services, promotions or offers in the future; (iii) to ensure that a user will not be repeatedly exposed to the same ads, offers and promotions while visiting the Site; and (iv) to, in connection with regular communication with a user, include offers, promotions or advertisements historically, or likely to be, of interest to that user.

An action tag or a web-beacon (also known as a clear gif or a pixel tag) is a method used to track responses or actions by visitors who view certain advertisements or other information on a site. Action tags are images embedded in a website page that are used to transparently collect information. We may use action tags to count the number of times that visitors click on a particular banner ad or visit the pages of the Site and to provide information about what products are viewed or purchased.

Personal Information We Collect From You

By registering with, or providing personal information to on the Site, as well as providing permission to receive marketing offers, users allow us and our affiliates to make their personally identifiable information available to third parties in accordance with the terms of this Policy and the privacy policy of the respective affiliated sites. While on the Site, we may collect "Personal Information" from you. For the purposes of this Policy, Personal Information shall mean individually identifiable information from or about an individual including, but not limited to: (a) a first and last name; (b) a home or other physical address, including street name and name of city or town; (c) an e-mail address or other online contact information, such as an instant messaging user identifier or a screen name that reveals an individual's e-mail address; (d) a telephone number; (e) a Social Security number; (f) a persistent identifier, such as a customer number held in a cookie or processor serial number, that is combined with other available data that identifies an individual; (g) age; (h) income level; (i) hobbies, buying patterns or preferences; or (j) any other information from or about an individual that is combined with any of (a) through (i) above.

How We Use Personal Information

Your Personal Information will be transmitted to our advertising and marketing partners, our affiliated companies, or other third parties interested in providing you information or services. Requested information may be provided by e-mail at the address that you provide on the Site or by any other means you provide. We will also use your Personal Information for customer service, to provide you with information that you may request, to customize your experience on the Site, and to contact you when necessary in connection with transactions entered into by you on the Site. We may also use your Personal Information for internal business purposes, such as analyzing and managing our business. We may also combine the information we have gathered about you with information from other sources. We may use third parties to help us operate our business and the Site or administer activities on our behalf.

We and/or our marketing partners and affiliated companies enhance and/or merge Personal Information about users with data collected from other sources to use in direct and/or online marketing.

We reserve the right, in connection with a transfer of any of our assets to any affiliated company, to provide Personal Information and data to the affiliate subject to the terms of this Policy. Similarly, we reserve the right, in connection with a sale of any of our assets or businesses to a third party, to sell our database containing Personal Information, or relevant portion thereof. We may release Personal Information if required by law, to enforce the Terms, or to protect the rights, property or safety of our Site, its registered users, or others. Please note that our Policy does not apply to websites or web pages that link to our Site.

You may, at any time, notify us that you do not wish to have your Personal Information disclosed to third parties for offers and promotions by sending an e-mail to unsubscribe@phase2-solutions.com.

In addition, by registering on the Site and/or agreeing to receive e-mail marketing from us and our affiliates and advertisers, you agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule, 16 CFR §310 et seq. (the "Rule"). Notwithstanding that your telephone number may be listed on the Federal Trade Commission's Do-Not-Call List, we retain the right to contact you via telemarketing in accordance with the Rule. Moreover, by registering with, or requesting information from, a third-party advertiser at or through the Site, such action shall constitute an inquiry and/or application with the respect to such third-party advertiser for purposes of the Rule and you may be contacted via e-mail, direct mail and/or telephone by such third-party advertiser in accordance with the Rule.

How We Use Demographic Information

We use demographic information to tailor the Site to the interests of our users. Demographic information is shared with advertisers so that they can tailor their advertisements to the appropriate audience. Demographic information may also be shared with other third parties.

Other Sites

Other sites accessible through our Site have their own privacy policies and data collection, use and disclosure practices. Please consult each site's privacy policy. We are not responsible for the policies or practices of third parties. Please be aware that our Site may contain links to other sites on the Internet that are owned and operated by third parties. The information practices of those websites linked to our Site are not covered by this Policy. These other sites may send their own cookies to users, collect data, or solicit Personal Information. Additionally, other companies that place advertising on our Site may collect information about you when you view or click on their advertising through the use of cookies. We cannot control this collection of information. You should contact these advertisers directly if you have any questions about their use of the information that they collect.

On behalf of various sponsors, we may provide sponsored links to third-party websites. If you click on a sponsored link or banner ad, a "window" or "frame" containing a third-party's web site may appear in the foreground with a Site in the background. Unless you are on our Site, any time that you have moved to a window, you should assume that your Personal Information is being collected, used and disclosed in accordance with the windowed site's privacy policy (if any).

Our Security Precautions

The Site has security measures in place to protect against the loss, misuse and alteration of the information under our control. We use our best efforts to prevent such information from being read or intercepted as the information travels over the Internet. While we are committed to protecting your information, we cannot ensure or warrant the security of any information you transmit to us.

Removal of Your Information/Opting Out

At your request, we will remove Personal Information that you have provided to us. You may do so by e-mailing us at unsubscribe@phase2-solutions.com. However, deleting your Personal Information or otherwise opting-out of receipt of communications from us or third parties will only change or delete the data in our database for purposes of transacting future business on the Site and for managing future communications from us and not third parties. These deletions will not change or delete Personal Information already collected as part of a particular transaction in our database, which may have already been shared with third parties, all as provided above in this Policy. You will need to contact third parties who may contact you directly to change your preferences or your personal information that they may be using to contact you.

We provide users the option to opt-out from receiving information sent via electronic mailings on behalf of third party advertisers. Users may unsubscribe from receiving e-mails at any time by following the instructions contained at http://www.winmyvacation.com/email-remove.asp. Unsubscribe requests can only be processed if you have registered with us in the first instance. If you have not registered with us and wish to opt out of receiving e-mails from a particular sender, please consult that sender's opt out policies or contact that sender.

Information sent on behalf of third party advertisers is prepared several days in advance, so users may continue to receive e-mail from us for up to 5 days after following the unsubscribe procedures detailed above. If after that point a user is still receiving email from us, the user should contact us at admin@phase2-solutions.com.

Children's Online Privacy Protection Act (COPPA) Compliance

You must be at least 18 years old to have our permission to use our Site. Our policy is that we do not knowingly collect, use or disclose Personal Information about visitors under 18 years of age. If you are the parent or guardian of a minor under 18 years of age and believe that they have disclosed Personal Information to us, please contact us at admin@phase2-solutions.com so that we may delete the minor's information.

Contacting us about privacy questions or concerns

If you have any questions about this Policy, the practices of this Site, or your dealings with this Site, please email us at admin@phase2-solutions.com, or by sending a letter to:

Phase 2 Solutions, Inc.
9301 Ryden Rd. Ste 120
Grand Portage, MN 55605

Effective Date of this Privacy Policy
This Policy is effective as of January 1, 2005