Irwin Home Equity Corporation and Irwin Union Bank and Trust Company, recognize the importance of keeping your personal financial information safe and secure. We believe that protecting your privacy is an integral part of the customer service we provide to you. This document describes how we collect, use, and protect your non-public personal information (Customer Information). This policy applies to consumers who have, or have had, a mortgage loan or line of credit made, serviced or owned by Irwin Union Bank and Trust in conjunction with Irwin Home Equity and to those individuals who have submitted loan applications to us. If you have other loan or deposit accounts with Irwin Union Bank and Trust, you will receive separate notice on the bank's policy regarding the privacy of that information.

How We Collect Customer Information
When you apply for a loan or other account, it is important to ensure we have accurate information about you, so that we may provide you with the products and services that you request, and properly service your account. We collect information about you from the following sources:

• We collect information from you on applications or forms. The type of information varies, based on the product or service you have requested, and includes information such as your name, address, social security number, and other financial information.
• We also collect and maintain information about your account transactions with us, our affiliates (referred to in this document as the "Irwin companies"), and others.
• We may also collect information about you from credit agencies, such as your credit score, and your ability to manage your other credit accounts.
• We may also collect information from other 3rd parties which we use to verify the information that you have provided us.

Handling of Your Customer Information
Handling of Your Customer Information
We are committed to protecting the security and integrity of your customer information and will not disclose any of your private information, as described above, to any organization, affiliated or nonaffiliated, unless:

• We contract with another company to perform support services for us in conjunction with the service or product you have requested. These companies include, but are not limited to, specialized firms for services like check printing, executing security transactions, or providing data processing services.
• Another company is performing marketing services on our behalf.
• As permitted by law, with affiliated Irwin companies.
• To comply with reporting or other legal requirements, which may originate from governmental entities, courts or other entities (in the form of subpoenas and other legal processes).
• Or, with your consent.

How We Share Customer Information
Irwin Home Equity Corporation is a wholly owned subsidiary of Irwin Union Bank and Trust Company, one of several affiliated companies owned by Irwin Financial Corporation. These affiliates, "the Irwin companies", include Irwin Union Bank and Trust Company, Irwin Union Bank FSB, Irwin Commercial Finance, and their subsidiaries. Under the Federal Fair Credit Reporting Act, we are permitted to share your name, address, and facts about your transactions and experience with us (such as your payment history, account balance, and other transactional or experience information) among the Irwin companies for servicing and marketing purposes.*

If you do not wish us to share this information with other Irwin companies for marketing purposes, please contact the IHE Privacy Office at the address listed at the end of this policy disclosure.

We do not share your personal information with outside companies for the purpose of selling their products or services, unless we obtain your prior consent. It is not necessary for you to instruct us not to share information with these outside companies, because we automatically keep your information confidential unless instructed otherwise.

*If you are a resident of Vermont or California, IHE does not share your customer information with other Irwin companies for the purposes of marketing their products or services.

Keeping Your Information Private
Our commitment to protect your private information is documented via our policies and procedures regarding the proper physical security of our workplace and records. We maintain physical, electronic, and procedural safeguards, to guard your customer information against unauthorized access. Our employees are required to honor our Code of Business Conduct, which includes standards to protect customer confidentiality, and receive annual Privacy and Security training. We take appropriate corrective action when needed to enforce employee compliance with respect to the privacy of customer information. When you request assistance from us, we will require some personal information from you to verify your identity.

When the operation of our business requires us to share information with other non-Irwin companies, we limit access to our customer information to those who have a specific business reason to know this information. We require independent contractors and outside companies who work with us to adhere to strict privacy standards through their contracts with us.

Privacy Online
Our system safeguards include the use of encryption to protect the confidentiality of data that you transmit to us over the Internet. We participate in DigiCert's Secure Site program and utilize the Secure Socket Layer Technology (SSL).

When you visit one of our websites, we may collect and store information about your visit on an anonymous, aggregate basis. This information may include information such as the time and length of your visit, and the pages you looked at on our site. We use this information only to measure site activity and to develop ideas for improving our sites. No confidential information is collected from you online, unless you have provided it to us. Although we take all possible precautions to safeguard your information, you should never send confidential information via e-mail. The e-mails you send us are not secure. Customers always have the option of mailing or calling us to provide any information they wish to keep confidential.

Cookies are pieces of data assigned by our web server and stored on your computer's hard drive for later retrieval. This helps us recognize you the next time you visit our site, and improve the overall customer website experience. We will not use cookies to record information that will enable anyone to contact you via telephone, e-mail, or regular mail.

We may use a third party tracking service called Direct Response Technologies to track information about your visit to our site for market research. All of this information is considered confidential and is only available for our use. To learn more about the collection of information for this purpose, or to opt out of this data collection on Irwin Home Equity and Premier Equity websites, please use the following link: http://www.directresponse.com/privacy.html.

Reducing Direct Marketing From Other Companies:

Credit Reporting Industry
To have your name taken off all pre-approved credit solicitations, you may call the credit reporting industry Pre-screening Opt-Out number at 1.888.5OPTOUT (1.888.567.8688).

Identity Theft
Identity theft is a serious and growing problem. If someone has fraudulently used your identification to obtain credit, report the incident as quickly as possible to each of the credit reporting agencies listed below and ask that a fraud report be placed in your file.

Experian888-397-3742

Equifax800-525-6285

TransUnion800-680-7289

If you have questions about this privacy policy notice please write to:
IHE Privacy Office
Irwin Home Equity Corporation
P.O. Box 21589
Carson City, Nevada 89721

Or you may send an e-mail to Privacy@IHE.com

The policies and practices described in this disclosure are subject to change, and replace all previous notices or statements. Any updates to this policy will be published on this website.

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