We respect the privacy of all clients and prospective clients (collectively termed “customers” per
federal guidelines), both past and present. It is recognized that customers have entrusted our firm
with non‐public personal information and it is important that both access persons and customers
are aware of firm policy concerning what may be done with that information. Federal law gives
the customer the right to limit some but not all sharing of personal information. It also requires us
to tell you how we collect, share, and protect your personal information. The firm provides
policy is expected to change.
The firm collects personal information about customers from the following sources:
‐ Information provided to us complete their plan or investment recommendation;
‐ Information provided via engagement agreements and other documents completed in
connection with the opening and maintenance of an account;
‐ Information customers provide verbally; and
‐ Information received from service providers, such as custodians, about account
Types of Nonpublic Personal Information We Collect
We collect nonpublic personal information about you that is either provided by you or obtained
by us with your authorization. This can include but is not limited to: your Social Security Number,
Date of Birth, Banking Information, Financial Account Numbers and/or Balances, Sources of
Income, and Credit Card Numbers or Information. When you are no longer our customer, OHIS
The firm does not disclose non‐public personal information about our customers to anyone,
except in the following circumstances:
‐ When required to provide services our customers have requested
‐ When our customers have specifically authorized us to do so;
‐ When required during the course of a firm assessment (i.e., independent audit); or
‐ When permitted or required by law (i.e., periodic regulatory examination).
‐ For marketing by OHIS – to offer OHIS’s products and services to clients;
‐ For joint marketing with other financial companies;
‐ For affiliates’ everyday business purposes – information about client transactions and
‐ For non‐affiliates to market to clients (only where allowed).
If you are a new customer we may begin sharing your information on the day you sign our
agreement. If a client decides to close his or her account(s) or becomes an inactive customer,
you can contact us at any time to limit our sharing.
Federal law allows you the right to limit the sharing of your NPI by “opting out” of the following:
sharing for non-affiliates everyday business purposes – information about your creditworthiness;
or sharing with affiliates or non‐affiliates who use your information to market to you. State laws
and individual companies may give you additional rights to limit sharing. Please notify us
immediately if you choose to opt out of these types of sharing.
OHIS restricts access to clients’ personal and account information to those employees who need
to know that information to provide products or services to its clients. OHIS maintains physical,
electronic, and procedural safeguards to guard clients’ non‐public personal information.
In addition to OHIS’s listed access persons, any IT persons or other technical consultants
employed at the firm may also have access to non‐public client information at any time. An on‐
site or off‐site server that stores client information, third‐party software that generates
statements or performance reports, or third‐party client portals designed to store client files all
hold the potential for a breach of non‐public client information.
To mitigate a possible breach of private information, OHIS uses encryption software on all
computers and evaluates any third‐party providers, employees, and consultants with regard to their
security protocols, privacy policies, and/or security and privacy training.