Privacy Policy
Last updated: January 13, 2026
TOF Manager LLC, d/b/a The O.H.I.O. Fund (the “Company”), is committed to protecting the confidentiality and security of nonpublic personal information (“NPI”) entrusted to it by clients, investors, prospective investors, portfolio companies, and other individuals with whom the Company conducts business.
This Privacy Policy describes how the Company collects, uses, shares, safeguards, and retains such information in accordance with applicable federal securities laws, including Regulation S-P under the Investment Advisers Act of 1940.
Scope
For purposes of applicable privacy laws and this Privacy Policy, the Company’s investment advisory clients are the private investment funds it advises. However, in the course of providing advisory services to such funds, the Company may receive, maintain, or process nonpublic personal information relating to investors in those funds.
Accordingly, the privacy principles and protections described herein apply to nonpublic personal information of both the Company’s fund clients and the investors in those funds, to the extent such information is obtained by the Firm in connection with its advisory services.
Specifically, this Privacy Policy applies to:
- Private funds or other investment vehicles managed by the Company
- Investors and prospective/former investors in private funds advised by the Company
- Representatives of portfolio companies
- Individuals who obtain financial products or services from the Company
This Policy applies regardless of whether the individual relationship is ongoing or has terminated.
Information We Collect
The Company may collect nonpublic personal information about individuals from the following sources:
- Subscription agreements, investor questionnaires, and offering documents
- Direct communications with investors or their representatives
- Custodians, administrators, transfer agents, auditors, legal counsel, and other service providers
- Background checks, AML/KYC documentation, and identity verification processes
Examples of nonpublic personal information collected may include:
- Name, address, date of birth, and contact information
- Tax identification numbers and government-issued identification
- Financial information, investment history, and ownership interests
- Banking information and wire instructions
Use of Information
The Company uses nonpublic personal information solely for legitimate business purposes, including:
- Evaluating investor eligibility and suitability
- Administering private funds and related accounts
- Complying with legal, regulatory, tax, and reporting obligations
- Preventing fraud and safeguarding assets
- Communicating with investors and service providers
Information Sharing and Disclosure
The Company does not sell or rent nonpublic personal information; however, the Company may disclose nonpublic personal information only as permitted by law, including:
- To fund administrators, custodians, auditors, legal counsel, tax advisors, and other service providers who require such information to perform services on the Company’s behalf
- To regulatory authorities, law enforcement, or governmental agencies as required by applicable law or regulation
- To third parties in connection with a merger, acquisition, restructuring, or sale of assets, subject to confidentiality protections
All third parties receiving nonpublic personal information are required to maintain the confidentiality of such information and use it solely for the purposes for which it was disclosed.
Confidentiality and Data Safeguards
The Company maintains administrative, technical, and physical safeguards reasonably designed to protect nonpublic personal information against unauthorized access, disclosure, misuse, alteration, or destruction.
These safeguards include, as appropriate:
- Access controls and role-based permissions
- Encryption and secure data transmission
- Cybersecurity policies and monitoring
- Vendor due diligence and oversight
- Employee training and confidentiality obligations
Access to nonpublic personal information is limited to personnel who require such access to perform their job functions.
Former Investors and Former Clients
The Company treats nonpublic personal information of former investors and former clients with the same degree of care as that of current investors. Such information is retained only as long as necessary for business, legal, or regulatory purposes and is disposed of securely when no longer required.
Privacy Notices and Opt-Out Rights
In accordance with Regulation S-P, the Company provides this Privacy Policy to investors at the time of establishing a client relationship and annually thereafter, as required.
The Company does not share nonpublic personal information in a manner that would require an opt-out under Regulation S-P.
Data Retention
Nonpublic personal information is retained in accordance with the Company’s record retention policies and applicable regulatory requirements. Records are securely destroyed when retention is no longer required.
Changes to This Policy
The Company reserves the right to amend this Privacy Policy at any time to reflect changes in legal or regulatory requirements or business practices. Any material changes will be communicated to investors as required by law.
Contact Information
Questions regarding this Privacy Policy or the Firm’s privacy practices can be submitted via the Company’s website: https://theohiofund.com/contact/