PRIVACY POLICY
www.17thstsurfshop.com & www.17thst.com
last updated 1 May 2008

Thank you for visiting the websites: www.17thstsurfshop.com and www.17thst.com (or the “Websites”). Haylon Corporation ("we," "us," and “our”) is the owner of the Websites.  We recognize that you care how information about you may be collected by the Websites, used, shared, or disclosed. We have created this Privacy Policy to inform you of our information practices for the Websites.

Please be advised that the practices described in this Privacy Policy apply only to information gathered through the Websites, and do not reflect practices with respect to information gathered through other websites, third parties, or through off-line means.

If you have any questions regarding this Privacy Policy, you should contact the Customer Service Department by email at customersupport@17thst.com.

Changes to this Privacy Policy are discussed at the end of this document.  Each time you use the Websites, the then current version of this Privacy Policy will apply.  Accordingly, you should check the date listed above for the Privacy Policy and review any changes from the last time you used the Websites. 

The Information Collected
We collect information from you because it helps us to provide a better level of customer service.  We collect both personally identifiable and non-personally identifiable information. We also collect information from you when you request support or make inquiries about our products or services.
At the Websites, you may be able to order products, enter contests, submit comments to us, or subscribe to one of our services, such as our online newsletters.  The types of personally identifiable information that may be collected include: name, address, e-mail address, telephone number, fax number, credit card information, and information about your interests in and use of various products, programs, and services.  

You also may be able to submit information about other people. For example, if you order a gift online and want it sent directly to the recipient, you might submit the recipient's name and address. The types of personally identifiable information that may be collected about other people at the Websites include: recipient's name, address, e-mail address and telephone number.
In some cases, only persons who provide the requested personally identifiable information will be able to order products and services, or otherwise participate in the Websites programs, activities, or offerings. 

In general, personally identifiable information is provided by you for a particular product or service that we provide.  That is, we may ask you to provide some personally identifiable information for specific transactions or to enhance your online experience.  When you place an order at the Websites, we may ask for information such as your name, e-mail address, and zip code. We also may ask you for this sort of information at other times, such as registration with the Websites, when you enter a contest, participate in a promotion, or order other products or services from us.  We will indicate what types of personally identifiable information we may require of you so that you may receive the products or services that you requested.  Without this personally identifiable information, we cannot provide you with the requested products or services.  Please note that we do not provide financial services and are not a financial institution.

Certain non-personally identifiable information may also be collected when you visit the Websites, such as the type of browser you are using (e.g., Netscape, Internet Explorer), the type of operating system you are using, (e.g., Windows '95 or Mac OS), the date and time of your visit, the pages you hit or browse on the Website, and the domain name of your Internet service provider (e.g., America Online, EarthLink).

How the Information Is Used
As noted above, we may use collected information you provide about yourself to provide the products and services that you have ordered, to process and ship orders, to send order and shipping confirmations, to process payments, and to provide customer service. This information also may be used to offer you other products, advertisements, programs, or services of ours that we believe may be of interest to you.  There are also times when we may disclose non-public personally identifiable information to our service providers or related legal entities/affiliates for the foregoing reasons or to operate the Websites.  Our policy is that our service providers and affiliates will be obligated by agreement to protect information in accordance with this Privacy Policy.  We may also share information under such an agreement in the event of a merger, acquisition, or liquidation of Haylon Corporation.  Except as described herein, we will endeavor not to disclose non-public personally identifiable information to third parties.  If you want to avoid any of these uses of your personally identifiable information, please do not submit the information to the Websites. 

In processing payment, we may disclose your personally identifiable information to third party financial institutions you have identified and with which you may have an account or other relationship, such as your bank or credit card company.  Such information in the custody of your third party financial institution will be governed by the privacy policy of that party. Your name, telephone number, and shipping information must also be provided to third party shippers in order to deliver your purchase.
We sometimes use information to communicate with you, such as to notify you when you have won one of our contests you have entered, to fulfill a request by you for an online newsletter, or to contact you about your account with us.

We use the information that you provide about others to enable us to send them your gifts or cards. From time to time, we also may use this information to offer our products, programs, or services to them.

We sometimes use the non-personally identifiable information that we collect to improve the design and content of the Websites and to enable us to personalize your internet experience. We also may use this information in the aggregate to analyze site usage, as well as to offer you products, programs or services.

We and/or our service providers may disclose information, including non-public personally identifiable information, when we are obligated by law - for example, in response to a court order or subpoena. We also may disclose such information in response to a law enforcement agency or other government agency's request.

We may on occasion combine information we receive via the Websites with other information to enhance the Websites or our ability to market to you those products or services that may be of interest to you.

Finally, we will not use or transfer personally identifiable information provided by you in ways unrelated to the ones described above without also providing you with an opportunity to opt out of these unrelated uses.

BY REGISTERING WITH THE WEBSITES, ENTERING CONTESTS, ORDERING PRODUCTS, OR BY OTHERWISE SUBMITTING INFORMATION TO THE WEBSITES, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.

Collection of Information by Third-Party Sites and Sponsors
The Websites may contain links to other sites whose information practices may be different than those described in this Privacy Policy. You should consult the other sites' privacy policies for those sites prio to submitting information there.  We have no control over information that is submitted to, or collected by, third parties.  We seek to host only responsible third party advertisers on the Websites.  However, such advertisers are third parties and this privacy policy does not cover any information you may provide to third parties, or to their third party web sites.

From time to time, we may announce promotions (e.g., contests, sweepstakes, or other promotions) that are sponsored by or cobranded with identified third parties. In the course of participating in these promotions, you may voluntarily submit personally identifiable information to such third parties.  We do not have control over these third parties' use of this information.  Such information is governed by any privacy policy of the third party. 

If you do not want such third parties to receive your information, please do not participate in such promotions.  We will make reasonable efforts to notify you of the identity of these third party sponsors.

Cookies
We use cookies and similar technologies to understand how customers may be using the Websites, study traffic patterns, and to customize the Websites to uses.

To enhance your experience with the Websites, we use "cookies." Cookies are text files placed in your computer's browser to store your preferences. Cookies, by themselves, do not contain your e-mail address or other personally identifiable information unless you choose to provide this information by, for example, registering at one of our sites. However, once you choose to furnish a site with personally identifiable information, this information may be linked to the data stored in the cookie.

Cookies are used to understand site usage and to improve the content and offerings on the Websites. For example, cookies may be used to personalize your experience at our Websites (e.g., to recognize you by name when you return to the 17thstsurfshop.com and 17thst.com), save your password in password-protected areas, and enable you to use shopping carts on the Websites. Cookies may also be used to identify your potential interest in our products, programs, or services.

If you prefer not to use cookies, you may generally disable or limit the use of cookies on most browsers.  However, portions or aspects of the Websites may not be available if cookies are disabled.

Commitment to Security
We believe that we have undertaken commercially reasonable physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information collected online.  The Websites use Secure Sockets Layer (SSL) encryption where personally identifiable information is collected.  You must use a SSL capable browser in order to take advantage of this protection.

Special Note Regarding Minors
The Websites are not intended to be used by unsupervised children.  However, we recognize that the Websites may include content that may appeal to teens and children.  We also recognize that parents or guardians may purchase our products or services for the use of minors. 

We do not knowingly collect personal information from children under 13 on our Websites to ensure compliance with this Privacy Policy and the Children's Online Privacy Protection Act of 1998 (COPPA).  If you are under the age of 13, your parent or guardian should use the Websites on your behalf and you should not submit any personal information to us.  If a child under 13 submits personally identifiable information and we learn that the information is the information of a child under 13, we will attempt to delete the information as soon as possible.  We encourage all parents to monitor their child's use of the internet and to discuss online safety with their child.

Promotional Communications
There are several ways in which you can tell us whether or not you want to receive marketing information from the Websites. When you set up an account, or click on "My Account" within the Help Center area, or place an order, you will have an opportunity to make or change your selections in this regard. If you have signed up to receive our emails and prefer not to receive marketing information from the Websites, follow the "unsubscribe" instructions provided on any marketing e-mail you receive from the Websites.

Access to Personal Information
If you created a password-protected account within the Websites, go to "My Account" within the Help Center area of the Websites to review the information you provided. You may send an e-mail to the following address requesting access to or correction of your personally identifiable information: customersupport@17thst.com. For verification purposes please include your first name, last name, e-mail address, and your password, if applicable.

Use of the Websites Restricted to United States Residents
The Websites are hosted on servers located within the United States of America and are intended for use by United States residents.  You may not use the Websites if you are not a United States Resident.

Changes
We may revise, amend, or otherwise change this Privacy Policy from time to time. When we change the policy in a material way, we will post a notice on the Websites along with the new Privacy Policy.

Contact
customersupport
Haylon Corporation
Customer Service Department
508 Viking Drive
Virginia Beach, Virginia  23452

1259819v2