Privacy Policy

Effective as of February 1, 2023.

HORAN and our affiliates (collectively “HORAN” or “we/our”) are committed to your privacy and to providing you with transparency in our information practices. We understand and respect the privacy of non-public personal information we receive from our clients. The following Privacy Policy Statement (“Policy”) applies to our relationship with you if you are an individual who obtains products or services from us for personal, family or household purposes. By using our website and services, you are consenting to the collection, transfer, manipulation, storage, disclosure and use of your information as described in this Policy. Accordingly, any personal information provided by you to us shall be used in accordance with this Policy. However, this Policy applies only to personal information collected by our website and does not protect information you post to public areas or third-party websites, except as set forth herein. This Policy imposes no duties on HORAN not imposed by state, federal, or other applicable law.

We may change this Policy periodically by updating our website. You should check this page from time to time to ensure that you continue to agree with the terms of this Policy. This Policy is incorporated by reference into the Terms of Use, to which you agreed to upon entering the website.

Information We Collect

In the course of doing business with you, HORAN may collect personal, non-public information about you from a variety of sources:

Information which we receive from you on contractual agreements or client information/application forms, such as your name, address, phone number, taxpayer or social security number, occupation, date of birth and income.
Information about your transactions with us, HORAN’s aﬃliated companies and others, such as account balances, investment assets and the purchase and sale of securities.
Information you submit directly through our website, or communicate with us.

Information Collected Automatically: When you use our website, we or our third-party service providers may automatically receive and record certain information. For example, this may include your device’s IP address, user-agent string, information about your use of the website during your current session and over time (including the pages you view and the files you download), the date and time of your visit, links you click, searches conducted, the website visited before navigating to our website, your software and hardware attributes (including browser and operating system type and version, website version, device type, and device identifiers), and your general location inferred from your zip code data uploaded to the website. To obtain such information, we or our third-party service providers may use the following technologies to recognize your device and collect information about your website usage:

When you use the website, we automatically receive and record certain information from your computer (or any other device) and your browser. To obtain such information, we may use server logs or applications that recognize your device and gather information about its online activity.
We also use cookies. Cookies are small files that are stored on your device by your web browser. A cookie allows us to recognize whether you have visited before and may store user preferences and other information. If you are concerned about having cookies on your device, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your device. However, if you choose to block or delete cookies, certain features of the website may not operate correctly.
The website or the emails that you receive from us may use an application known as a “web beacon” (also known as a “tag” or “pixel”) and similar technologies. Web beacons are small strings of code that provide a method for delivering a graphic image on a web page or in an email message for the purpose of transferring data. For example, it may allow an email sender to determine whether a user opens a particular email.

We may combine information collected through the website with information that we collect in other contexts, such as information from our communications, phone calls with you, or data that we collect via contracts or other agreements. We will treat such combined information in accordance with this Policy.

How We Use The Data We Collect

We use your information to:

To provide our services, our website, fulfill the terms of any agreement you have with us, respond to your requests, and for other purposes related to managing our organization.
To communicate with you regarding your agreements, accounts, and the services we provide you or any requests you may have, important updates regarding our website and other administrative issue.
To facilitate our services and to provide our service providers with accurate and timely feedback on their performance and opportunities for improvement.
To detect and prevent fraudulent or other misleading use of our services, or our website. To the extent required by law, we will provide law enforcement or other governmental bodies, any information request as necessary to comply with legal processes.
For business transfers, including to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our website users is among the assets transferred.
To provide promotional messages, marketing, advertising, and other information that may be of interest to you based upon your preferences as established by your use of our services and other sources.
Including for data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our website, products, content, marketing, and your experience.

HORAN has internal procedures designed to maintain accurate records concerning your personal information. If you ever believe that our records contain inaccurate, incomplete or non-current information about you, please notify us immediately. We will respond to requests to correct the information in a timely manner.

Information We Share

We do not disclose your information that you’ve made through our website with outside parties, except to companies that host our data services, deliver communications on our behalf, fulfill service requests, operate apps, or plug-ins on our behalf, or for a variety of reasons, including as follows:

We will share your personal information with trusted third parties who assist us in operating our website, conducting our business, or providing services to you, so long as these parties agree to keep the information confidential. We will also share any information you have submitted to the website with third-party users you specify. We may share certain de-identified information, such as chart data, with third parties for research and educational purposes.
The website may integrate certain third-party plugins (such as a Facebook “like” button and Twitter “follow” button). Even if you do not click on these plugins, they may collect information about you, such as your IP address and the pages that you view. They also may set and/or access a cookie or use similar tracking technologies. These plugins are governed by the privacy policy of the company providing them.
We may use or share your information with third parties when we believe, in our sole reasonable discretion, that doing so is necessary:
- To comply with applicable law or a court order, subpoena, or other legal process;
- To investigate, prevent, or act regarding illegal or prohibited activities, suspected fraud, violations of our rules or terms and conditions.
- To establish, protect, or exercise our legal rights or defend against legal claims.
We may share your information with third parties to facilitate the financing, securitization, insuring, merger, acquisition, sale, assignment, bankruptcy, or other disposal of all or part of our organization or assets.
We may share aggregated and de-identified information with third parties, such as by publishing or sharing reports with third parties about trends in the usage of the website.
In any situation to which you have given us your consent to disclose.

We will only disclose information in limited circumstances as permitted by law. We maintain physical, electronic and procedural safeguards that comply with applicable law to guard your nonpublic personal information.

We do not sell any of your information under any circumstances.

Opt Out Right

We do not share with our aﬃliated company’s other information you have given us in connection with an application, contract or agreement; or information we have received from other third parties. You will be notiﬁed if we intend to do so and be given the opportunity to prevent such sharing.

If you prefer that we not disclose nonpublic personal information about you to non-affiliated third parties, you may opt out of those disclosures (other than those disclosures permitted by law, to include regulatory authorities). To exercise your right to opt out of disclosure of your nonpublic personal information, please notify us at:

By Mail - HORAN Attn: Privacy Policy 8044 Montgomery Road, Suite 640, Cincinnati, OH 45236

Information Security

We have implemented appropriate data collection, storage, and processing practices designed to secure your information from accidental loss and from unauthorized access, use, alteration, and disclosure. We restrict access to non-public personal information to those employees who need to know that information in order to provide our products and services to you.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your information, we cannot guarantee the security of your information transmitted to our website. Any transmission of information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Sites.

Children's Privacy

We do not knowingly collect information from children under 13. If you are under 13, do not use or provide any information, register an account, enter any subscriptions, make any purchases or submit any applications, or use any of the interactive or public comment features of our website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at TomS@horanassoc.com.

Data Retention

Your personal information is retained for as long as necessary to comply with our legal obligations, to resolve disputes, or to enforce our agreements. However, data that is deleted from our servers may remain as residual copies on backup servers or other media.

If you end your relationship with us, we will continue to adhere to the policies and practices described in this Policy.

If you have any questions about our Privacy Policy, please contact us by any of the following ways:

By Mail - HORAN Attn: Privacy Policy 8044 Montgomery Road, Suite 640, Cincinnati, OH 45236

By Phone - 513.745.0707 or 800.544.8306

By E-Mail – TomS@horanassoc.com

Sincerely,

Thomas Shoemake, Chief Compliance Oﬃcer & Executive Representative, Registered Principal