ADV & Privacy Policy

Privacy Notice

Regulation S-P | Privacy of Consumer Financial Information

June 2026 | Shoker Investment Counsel, Inc. (dba Shoker Investments)

Shoker Investment Counsel, Inc. (dba Shoker Investments) is registered with the SEC as an investment adviser. Your privacy is important to us. This notice describes how we collect, use, and protect your nonpublic personal information (“NPI”) and is provided in accordance with Regulation S-P (17 C.F.R. Part 248), adopted pursuant to the Gramm-Leach-Bliley Act. Please read this notice carefully and retain it for your records.

What Information Do We Collect?

In the course of providing investment advisory services, we may collect the following categories of NPI:

Identifying information: name, address, date of birth, Social Security number, government-issued identification
Financial information: income, net worth, assets, liabilities, investment accounts, and tax information
Account information: brokerage and bank account numbers, holdings, transaction history, and performance data
Employment and professional information where relevant to financial planning
Information provided in conversations, questionnaires, financial plans, and client communications
Information received from custodians, account aggregators, or other third parties in connection with your accounts

What Information Do We Not Share?

We do not sell your personal information. We do not share your NPI with non-affiliated third parties for their own marketing purposes. All information sharing described in this notice is limited to what is necessary to provide, administer, and service your account, or as required or permitted by law.

Service Providers — How We Share Your Information

To operate our business and provide services to you, we share NPI with certain non-affiliated third-party service providers. These vendors are engaged to perform services on our behalf and are contractually or otherwise required to protect your NPI and use it only to perform those services. Sharing with service providers of this type is permitted under Regulation S-P (17 C.F.R. § 248.14) without the need for an opt-out election.

Vendor / Service Provider	Category	Purpose / NPI Use
Salesforce	CRM Platform	Client contact data, account records, communication history
Tamarac / Envestnet	Portfolio Mgmt & Billing	Portfolio reporting, performance data, fee billing; accesses holdings and values, sharing of documents via client portal
Redtail / Orion	CRM & Portfolio Reporting	Redtail: client relationship management and contact data; Orion: portfolio performance reporting and account data. Both access client personal and account information
XLR8 (Concenter Svc.)	CRM Platform (Salesforce-based)	Salesforce-based CRM overlay built for RIAs; manages client data, workflows, and communications. Runs on the same Salesforce infrastructure as the firm’s standalone Salesforce instance
ByAllAccounts / Morningstar	Account Aggregation	Aggregates client account data across custodians for consolidated reporting
Holistiplan	Tax Planning Software	OCR-based tax return analysis and planning scenario modeling; accesses client tax returns and related income and financial data
Smartsheet	Workflow Management	Internal workflow tracking; may contain client-related task information
ShareFile (Citrix)	Secure Document Sharing	Secure transmission and storage of client documents containing NPI
Adobe	Document Processing	PDF creation, e-signature, and document management
Microsoft Office / OneDrive	Productivity & Cloud Storage	Document creation and cloud storage; files may contain client NPI
RingCentral	Business Communications	VoIP and messaging; communications may reference client NPI
Zoom	Video Conferencing	Virtual client meetings; meeting content may include discussion of NPI
ChatGPT / OpenAI	AI Assistant	Internal analytical and drafting assistance
Claude / Anthropic	AI Assistant	Internal analytical and drafting assistance

Custodians — Independent Regulatory Relationship

The following firms serve as qualified custodians of client assets. Custodians are not “service providers” to the Firm under Regulation S-P — they have independent regulatory relationships with clients and maintain their own Reg S-P privacy notice obligations. We share client information with custodians only as necessary to open, maintain, and service advisory accounts.

Custodian	Role & Regulatory Note
Charles Schwab & Co., Inc.	Qualified custodian holding client assets. Schwab has an independent regulatory relationship with clients and its own Reg S-P notice obligations. Information is shared only as necessary to execute and service advisory accounts.
Interactive Brokers LLC	Qualified custodian holding client assets. Interactive Brokers has an independent regulatory relationship with clients and its own Reg S-P notice obligations. Information is shared only as necessary to execute and service advisory accounts.

Other Permitted Disclosures

We may also disclose your NPI as permitted or required by law, including:

To comply with a court order, subpoena, or other legal process
To respond to requests from government regulators or law enforcement agencies
To protect against fraud, unauthorized transactions, or legal liability
To legal, compliance, or accounting advisors acting in a professional capacity on our behalf

How Do We Protect Your Information?

We maintain physical, electronic, and procedural safeguards designed to protect the security and confidentiality of your NPI, including:

Written information security policies and a formal incident response program
Access controls limiting NPI access to personnel with a legitimate business need
Vendor oversight procedures, including review of service provider security practices
Secure document transmission and storage via ShareFile and/or Tamarac client portal for client document exchange
Regular personnel training on privacy and data security obligations

In the event of a data breach or unauthorized access to your sensitive personal information, we will notify you in writing as soon as practicable and no later than 30 days after discovery, as required by the SEC’s 2024 amendments to Regulation S-P.

Former Clients

If you are a former client of Shoker Investment Counsel, Inc., we continue to protect the confidentiality of your NPI in accordance with this notice and applicable law.

Annual Notice / Changes to This Policy

We will provide you with a privacy notice annually as required by Regulation S-P. Under the 2024 amendments to Regulation S-P, firms that share NPI only under service provider or other exceptions to opt-out, and whose privacy practices have not changed since the last notice, may qualify for an exemption from the annual delivery requirement. If we qualify for this exemption in a given year, we will not send a separate annual notice. If we make a material change to our privacy practices that requires sharing your NPI in a manner not previously disclosed, we will provide a revised notice prior to implementing that change.

Questions & Contact Information

If you have questions about this notice or our privacy practices, please contact us:

Shoker Investment Counsel, Inc. (Shoker Investments)
3642 Kehr Rd, Oxford, OH 45056
Phone: (513) 524-1776
Email: info@shoker.com
Web: shoker.com/adv-privacy-policy/

To report a concern about your investment adviser or to access investor education resources, contact the SEC at investor.gov/CRS or call 1-800-SEC-0330 (1-800-732-0330).

This notice is issued pursuant to SEC Regulation S-P (17 C.F.R. Part 248). Shoker Investment Counsel, Inc. is registered with the U.S. Securities and Exchange Commission as an investment adviser. Registration does not imply a certain level of skill or training.