TOWBIN ROLLS ROYCE PRIVACY POLICY

Privacy Policy
Privacy is a cornerstone of our customer relationship. In operating our business, we strive to find methods to guard personal identity and information by promoting the use of fair information practices. We have created this privacy policy to demonstrate our firm commitment to privacy and to inform you of our practices concerning the collection and use of the information that you provide to us. Towbin Automotive Enterprises may amend this policy from time to time. If we make any substantial changes in the way we use your personal information, we will post an announcement on our web site.

Collection of Information
Towbin Automotive Enterprises may collect and use personal information to respond to requests for our services or to provide information about our services that may be of value. Certain personal information Towbin Autmotive Enterprises collects may be publicly available via government records, telephone books, or other widely available media however we treat all information provided as non-public. Towbin Automotive Enterprises collects personal information from a variety of sources, including:

1. Application Information (Information provided from loan applications and other forms such as names, addresses, telephone numbers, birthday, social security numbers, level of family income, employer's name, and employer's address);
2. Credit Reports (Information from consumer reporting agencies);
3. Correspondence (Information provided when communicating in writing, online or by phone with our customer service representatives); and
4. Marketing partners and publicly available databases (we receive information from our marketing partners, e.g. financial institutions, auto dealerships and other business and public databases which we use to help us serve our customers).

We use information that we obtain to evaluate auto loan applications, locate an appropriate auto lender for you, in order to provide high quality service, prevent fraud and, with the customer's consent, inform customers of offers by third parties. We may also use this information to confirm a customer's identity when they call us to inquire about their account.

Security Safeguard Procedures
Towbin Automotive Enterprises uses a variety of security safeguards to protect information from loss, misuse, alteration or destruction. We provide access to personal information to Towbin Automotive Enterprises employees and other authorized parties on a need to know basis. In addition, we require that all employees attend a privacy training program and sign a Confidentiality Agreement that indicates that they are aware of Towbin Automotive Enterprises privacy policy regarding the use and disclosure of information.

Sharing of Information with Third Parties
Towbin Automotive Enterprises may disclose personal information to the following types of third parties:

Credit Bureaus and Service Companies (companies that provide services to Towbin Automotive Enterprises in order to process auto loan applications). Personal information is disclosed to the foregoing entities solely for the purpose of obtaining credit for the purchase of a vehicle. Outlined below is the information we share with each type of third party.

Credit Reporting Agencies - Companies involved in the loan process are a necessary part of the auto loan process. When a customer applies for credit, he/she agrees that we may request consumer credit reports from one or more credit reporting agencies in connection with their application and administration of the application. The Customer may also authorize us to exchange credit information concerning their account with (and answer questions and requests from) others, such as merchants, other lenders and credit reporting agencies.

Merchants - Towbin Automotive Enterprises does not share any information with external merchants for the purpose of extending offers of goods and services without the customer's consent. Towbin Automotive Enterprises does NOT use third party advertising companies to provide advertisements or allow third party advertisers to track web browsing activities on its web sites.

In addition, Towbin Automotive Enterprises does not knowingly offer its services to minors. Similarly, Towbin Automotive Enterprises does not collect information from children. Our application approval process is designed to identify applications submitted by children and to prevent their use of our websites.

Exercising the Right to Opt-Put of Information Sharing
Towbin Automotive Enterprises provides its customers with the opportunity to opt-out of information sharing with affiliates and partners. A customer must make their opt-out decision before completing the auto loan application process. Customers can opt-out by clicking on the link at the bottom of the auto loan application screen.

Storing of Information
We maintain electronic loan application information and hardcopy data. We also protect all personal information by storing the information on tapes at an offsite facility in our Data Warehouse. The Data Warehouse is disconnected from the production environment and the information is used internally for reporting purposes.

Privacy Related Issues
Towbin Automotive Enterprises is committed to customer service and privacy. If you have any questions, comments or concerns regarding our Privacy Policy and its implementation, or you would like to report any known or suspected privacy or security breaches, please do not hesitate to contact our Security Compliance Officer.

Gramm-Leach-Bliley Act
Towbin Automotive Enterprises complies with the requirements of Title V of the Gramm-Leach-Bliley Act, 15 U.S.C. '6801 through '6810 (AGLB Act@), and the Federal Trade Commission=s implementing regulation. Regulation P. 16 C.F.R. Part 313 (ARegulation P@) in particular, as both related to the disclosure and protection of Non-Public Personal Information (ANPI@) for customers with regard to the authorized distribution and intended use of customers= financial information to other parties. Towbin Automotive Enterprises will substantially comply with the GLB Act and Regulation P for all customer NPI received, transferred or obtained from the use of this site or from a party.