Private Client Resources Security Policy.

As a matter of sound business practices, PCR is committed to meeting or exceeding the security requirements of applicable laws, regulations and guidelines. PCR complies with the Federal Trade Commission's Safeguards Rule promulgated under the Gramm-Leach-Bliley Act ("GLBA").

Compliance with the Safeguards Rule requires a written Information Security Plan (the "Plan") that describes PCR's program to protect customer information. The Plan also includes an ongoing protocol to monitor and evaluate the effectiveness of safeguards and to recommend changes when required. The Plan has been reviewed and formally adopted by PCR's Management who place the highest priority on protecting the confidentiality of all financial information on the PCR system. A copy of the Plan is available upon request.

Since its founding, PCR has invested significant resources to integrate security into every aspect and layer of the PCR system. These pervasive safeguards flow through all the services PCR provides to customers. A few of these measures are summarized below to demonstrate the level of PCR's management commitment to provide a secure web environment for customers and their clients.

When you visit PCR's website, technical and navigational information may be collected, such as computer browser type, Internet protocol address, pages visited (site specific) and average time spent on the website. This information may helpful for PCR to alert you to software compatibility issues. It may also be used to improve our website design and functionality.

Transmission. PCR uses a secured socket layer (SSL) certificate with 128-bit encryption from Verisign, for all communications, post login-in to PCRInsight.

Database. Sensitive personal information is encrypted within the PCR database. This means that customer data remains private under all circumstances.

Internet Protection. The PCR website is protected by a firewall barrier that protects the network. Additional firewalls are used to protect PCR internal systems. Customers and clients have a personalized password to protect their accounts from unauthorized access.

Paper Documents. While most PCR customer files are electronic, the limited personal financial information PCR retains on paper is stored in locked, fireproof file cabinets, which are located in a secured, limited access room within the main PCR controlled entry perimeter of its headquarters.


	INSIGHT^SM Security Policy As a matter of sound business practices, PCR is committed to meeting or exceeding the security requirements of applicable laws, regulations and guidelines. PCR complies with the Federal Trade Commission's Safeguards Rule promulgated under the Gramm-Leach-Bliley Act ("GLBA"). Compliance with the Safeguards Rule requires a written Information Security Plan (the "Plan") that describes PCR's program to protect customer information. The Plan also includes an ongoing protocol to monitor and evaluate the effectiveness of safeguards and to recommend changes when required. The Plan has been reviewed and formally adopted by PCR's Management who place the highest priority on protecting the confidentiality of all financial information on the PCR system. A copy of the Plan is available upon request. Since its founding, PCR has invested significant resources to integrate security into every aspect and layer of the PCR system. These pervasive safeguards flow through all the services PCR provides to customers. A few of these measures are summarized below to demonstrate the level of PCR's management commitment to provide a secure web environment for customers and their clients. When you visit PCR's website, technical and navigational information may be collected, such as computer browser type, Internet protocol address, pages visited (site specific) and average time spent on the website. This information may helpful for PCR to alert you to software compatibility issues. It may also be used to improve our website design and functionality. Transmission. PCR uses a secured socket layer (SSL) certificate with 128-bit encryption from Verisign, for all communications, post login-in to PCRInsight. Database. Sensitive personal information is encrypted within the PCR database. This means that customer data remains private under all circumstances. Internet Protection. The PCR website is protected by a firewall barrier that protects the network. Additional firewalls are used to protect PCR internal systems. Customers and clients have a personalized password to protect their accounts from unauthorized access. Paper Documents. While most PCR customer files are electronic, the limited personal financial information PCR retains on paper is stored in locked, fireproof file cabinets, which are located in a secured, limited access room within the main PCR controlled entry perimeter of its headquarters.