Privacy CODE

Privacy Notice / Consent

At Odyssey Trust Company and Odyssey Transfer and Trust Company (herein “Odyssey”), we take your privacy seriously. When providing services to you, we receive non-public, personally identifiable information about you. We receive this information through transactions we perform for you or through an issuer in which you hold securities, enrollment forms, and through other communications with you. We may also receive information about you by virtue of your transactions with affiliates of Odyssey or other parties (e.g., brokers). This information may include your name, social insurance/security number (or other identification number), securities ownership information and other financial information. With respect to both current and former customers, Odyssey does not share non-public personally identifiable information with any non-affiliated third party except as necessary to process a transaction, service your account, or as permitted by law. Our affiliates and outside service providers with whom we share information are legally bound not to disclose the information in any manner, unless permitted by law or other governmental process. We strive to restrict access to your personally identifiable information to those employees who need to know the information to provide our services to you and we maintain physical, electronic, and procedural/administrative safeguards to protect your personal information. Odyssey realizes that you entrust us with confidential personal and financial information, and we take that trust very seriously. By providing your personally identifiable information to us we will assume, unless we hear from you to the contrary, that you have consented and are consenting to this use and disclosure. Withdrawal of this consent may be requested where such withdrawals are permitted by law. A complete copy of our Privacy Code may be accessed at www.odysseytrust.com, or you may request a copy in writing Attn: Chief Privacy Officer, Odyssey Transfer and Trust Company at 2155 Woodlane Dr., Suite 100, Woodbury Minnesota 55125, or Odyssey Trust Company at 1230 – 300 5th Ave SW, Calgary AB, T2P 3C4.