PRIVACY POLICY

Irwin Commercial Finance and it's subsidiaries (Irwin Franchise Capital Corporation, Irwin Commercial Finance-Equipment Finance, and Irwin Commercial Finance-Canada, collectively "Irwin") is committed to protecting your privacy. This Policy is effective as of October 16, 2006.

Welcome to the Irwin Commercial Finance web sites (www.irwincf.com, www.irwincfcanada.com, www.irwincfequipment.com, www.irwinfc.com). Irwin recognizes the importance of keeping your personal financial information safe and secure. We are committed to a policy of privacy and the security of data in our Sites. In order to demonstrate our firm commitment to protecting your privacy, we created the following policy which describes how we collect and use your personal information and about the choices you have concerning such use. From time to time, we may modify this Privacy Policy (the "Policy") to address new issues or changes to our practices. These changes will be posted here so that you will always know our privacy policies. Please check the Sites and the Policy periodically to see if there have been any changes. We will always apply the Policy under which your information was collected, unless we obtain your prior consent.

Information Collected

You may be asked to voluntarily provide your name, billing address, shipping address, phone number, credit card number, social security number, social insurance number, email address or other personally identifiable information ("Personal Information") to receive services or to have access to some features of the Sites. By using the Sites and providing us with your Personal Information, you consent to our use of such information as described in this Policy. Anyone may visit the Sites and remain anonymous by not providing any Personal Information however, this may lead to our inability to provide you with certain products or services. Our Web servers do not collect the email addresses or other non-public information of visitors unless it is voluntarily given. When you visit one of the Sites, we or our business partners may also collect and store information that is anonymous, such as your IP number (a number used to identify your computer on the Internet), the time and length of your visit, the pages you visited on our Sites or the type of browser you are using ("Anonymous Information"), through the use of cookies or by other means. This Anonymous Information is used to analyze and improve our Sites and to provide you with a fulfilling online experience. We may also use this information to help diagnose problems with our services and to administer our Sites. We hope that, by using Anonymous Information, we can update the Sites to make them more useful to you and other users. We reserve the right to maintain, update, disclose or otherwise use Anonymous Information, without limitation.

Cookies

Like many Web sites, we use "cookies", which are pieces of data assigned by our Web server and stored on your computer's hard drive. Cookies help us to recognize returning visitors in order to optimize their online experience. For example, cookies allow us to tailor the Sites to better match your interests and preferences. With most Internet browsers or other software, you can erase cookies from your computer hard drive, block all cookies or receive a warning before a cookie is stored. Please refer to your browser instructions to learn more about these functions. If you reject cookies, functionality of the Sites may be limited, and you may not be able to take advantage of many of the Sites' features.

Use of Information

We may use your Personal Information for the following purposes: to process your applications and administer your account; to administer and improve our Sites and related services; to notify you of our products, services, promotional events or special offers that maybe of interest to you; to provide Internet security; and to meet legal requirements. We may work with our business partners who may perform certain functions on our behalf, such as sending email messages, managing data or providing customer service. These business partners have access to your Personal Information only to the extent necessary to perform these specific functions and may not use it for any other purpose. Other than for the specific purposes set forth in this Policy, we will not disclose your Personal Information unless we obtain your prior consent or are legally required to do so. Please note that our business partners may be located outside of Canada and the United States, and you acknowledge that Personal Information may be processed and stored in foreign jurisdictions and that the governments, courts of law enforcement or regulatory agencies in those jurisdictions may be able to obtain disclosures of your Personal Information through the laws of the foreign jurisdiction. We may use third party advertising companies to place ads on the Sites and to place our ads on other web sites. These companies may use Anonymous Information about your visits to this and other web sites to provide advertisements on the Sites and other sites about products and services that may be of interest to you. If Irwin is involved in the sale of a substantial portion of its business assets, Anonymous or Personal Information maybe among the transferred assets.

Client Section

If you become an Irwin client, the registration to become a client is administered separate from our Sites. All of the information collected is used to provide access to the password protected and secure client section of our Site(s) (where available), which is where all transactions take place. The secured transaction processing area of our Site(s) requires users to give us Personal Information in order to conduct business, contact the customer and process transactions. Irwin utilizes a portfolio management system that includes an Application where data is entered to initiate a business transaction. Financial information that is collected from this Application is then used to check the customer's qualifications using external credit scoring systems, credit bureaus and other credit resources. Users may opt-out of being an Irwin client and cease the processing of Applications at any time; see the "Choice/Opt-Out" section below.

Irwin has implemented certain controls to ensure the security of the Client Section of our Sites. These security measures include a range of security services that limits access to Personal Information only to authorized users, while protecting these same resources from both internal and external threats to optimize the privacy and integrity of data and communications. Despite the implementation of these security measures, there always remains some risk of unauthorized exposure of information including personal information you supply. Your use of the Client Section of the Sites and your entry of information is at your own risk and Irwin cannot accept responsibility and disclaims all liability for damage or injury that you may incur or that may result from your use of the Sites or the interception of data you provide.

The Client Section may include a password protected portion of the Sites. These portions of the Sites are intended to be for your benefit, however, please be aware that you are responsible for taking all reasonable steps to ensure that no unauthorized person shall have access to your password or account. It is your sole responsibility to (1) control the dissemination and use of your activation codes; (2) authorize, monitor, and control access to and use of your account and password; and (3) promptly inform us of any need to deactivate a password.

Transmission of Information

The Sites may contain secured and non-secured sections. Irwin has taken certain steps to protect the secured section of the Sites, such as the Client Section described above. However, inherent in the use of the Internet and Internet related technologies is some risk of unauthorized exposure of information including Personal Information you supply. Your use of the Sites and your entry of information is at your own risk and Irwin cannot accept responsibility and disclaims all liability for any damage or injury that you may incur or that may result from your use of the Sites or the interception of data you provide. Although we take precautions to protect the information gathered or submitted on our Sites, you should never send confidential information via email. Internet-based email is not generally protected or secure.

Information from Children

We are committed to protecting the privacy of children. Our activities are not intended for or designed to attract children under the age of 13. We encourage parents and guardians to be aware of and participate in their children's online activities. We strictly adhere to the Children's Online Privacy Protection Act and will not knowingly collect, use or disclose Personal Information from any child under the age of 13 in any manner that violates this law.

Online Security

We believe that protecting the security of your privacy and confidentially of your personal information is very important. Therefore, we have put strong security measures in place to attempt to protect your personal information. Our system safeguards include the use of encryption to protect the confidentiality of data that you transmit to us over the Internet. We utilize the Secure Socket Layer Technology (SSL), which is the leading security protocol for data transfer on the Internet. In addition, access to your personal information is limited to our employees and other authorized individuals.

Choice/Opt-Out

Our Sites provide users the opportunity to opt-out of receiving communications from us at the point where we request information about the visitor. This site also gives the user the following options for removing their information from our database so that future communications and/or services are no longer received. In the event you do not wish to receive communications from us or wish to be removed from our databases, please do the following:

You can send an email to (privacy@irwincf.com) or, send a letter to:
Irwin Commercial Finance
Attn: Ray Herrick, Operations Risk Manager
330 120th Avenue NE, Suite 110
Bellevue, WA 98005

Third Party Links

The Sites may contain links to other, non-Irwin sites on the Internet that are owned and operated by third parties. While we try to link to other sites that share our respect for privacy, Irwin is not responsible for the privacy practices or the collection or use of your Personal or Anonymous Information at any third party Web sites. Therefore, we disclaim any liability for any third party's use of your Personal or Anonymous Information obtained through using the third party Web sites. We encourage you to be aware of this when you leave the Sites and to review the privacy and security policies of each and every Web site that you visit.

Contacting Irwin/Modification of Information

If you have any questions or comments about this Policy or you wish to update your Personal Information provided to us, please contact us at the addresses listed below. Please provide a concise communication with complete information, including your contact information.

Irwin Commercial Finance
Attn: Ray Herrick, Operations Risk Manager
330 120th Avenue NE, Suite 110
Bellevue, WA 98005