Legal & Privacy Statement

PRIVACY POLICY NOTICE - Sept 2016

This Privacy Policy sets forth the manner in which Odeon Capital Group LLC may collect, utilize and maintain nonpublic information about customers, as required under federal and other applicable law. Odeon is committed to protecting privacy and maintaining the confidentiality and security of a customer’s personal information. As noted above, this Privacy Policy only applies to products and services provided by Odeon to individuals which are used for personal, family or household purposes (not business purposes).

 

Collection of Customer Information

Odeon may collect personal information about customers from the following sources:

·         Customer questionnaires and other information provided by the customer in writing, in person, by telephone, electronically or by any other means. This information may include name, address, employment information and financial and investment qualifications as applicable;

·         Information about customers from financial institutions and service providers with whom a customer may have authorized to provide such information to Odeon;

·         Transactions in a customer’s account, including account balances, investments, contributions and withdrawals; and

·         Verification services and consumer reporting agencies, including a customer’s creditworthiness or credit history, as applicable.

 

Disclosure of Nonpublic Personal Information

Odeon does not disclose nonpublic personal information about customers or potential customer to affiliates or nonaffiliated third parties except as permitted by law. For example, Odeon may share nonpublic personal information about customers, without the customer’s consent, with affiliated and nonaffiliated parties in the following situations, among others:

·         In connection  with the administration and operations of Odeon and other of Odeon’s products and services, with Odeon’s brokers, attorneys, accountants, auditors, administrators or other service providers;

·         To respond to a subpoena or court order, judicial process or regulatory inquiry;

·         In connection with a proposed or actual sale, merger or transfer of all or a portion of its business;

·         To protect or defend against fraud, unauthorized transactions (such as money laundering), law suits, claims or other liabilities;

·         To respond to requests for information regarding compliance with anti-money laundering laws;

·         Upon consent of a customer to release such information, including authorization to disclose such information to person acting in a fiduciary or representative capacity on behalf of the customer; and

·         To assist Odeon in offering affiliated products and services to customers.

As indicated above, the foregoing may include responses to inquires for purposes of compliance with anti-money laundering and ant-terrorist due diligence, disclosure or reporting requirements. Odeon also may share nonpublic personal information about customers at customer direction or with customer consent.

 

Former and Prospective Customers

This same Privacy Policy applies to former and prospective customers.

 

Protection of Subscriber Information

Odeon maintains physical, electronic and procedural safeguards that comply with federal standards to protect customer information. Odeon restricts access to the personal and account information of customers to those registrants and employees who need to know that information in the course of their job responsibilities. When disposing of records containing customer information our registrants and employees are training to use an electronic shredder.

 

Further Information

Odeon reserves the right to change its Privacy Policy at any time. The examples contained within this Policy are illustrations and are not intended to be exclusive. Odeon’s Privacy Policy complies with federal law regarding privacy. Customers may have additional rights under other domestic or foreign laws that may apply.

 (revised 9/16)

Analyst Certifications

Odeon Capital Group requires Research Analysts to certify the views expressed in research reports accurately reflect their personal views about subject companies and their securities. They also certify that they have not, will not, nor are they presently receiving direct and/or indirect compensation in exchange for any specific recommendation in a report. In addition, analysts will certify that they have not received compensation from any subject company in the last 12 months.

Rating Definitions

RatingDefinition
BuyAnticipated total return of 10%+ over the next 12 months including dividend payments and/or the ability to perform better than the leading stock market averages or stocks within its particular industry sector.
HoldAnticipated trading levels at or near the current price and generally in line with the leading market averages and/or will perform less well than higher rated companies within its peer group.
SellAnticipated depreciation of 10% or more in price within the next 12 months, due to fundamental weakness perceived in the company or for valuation reasons and/or are expected to perform significantly worse than equities within the peer group.
No RatingThe security is not rated at this time.
HedgeA combination of being long one security and short another.

*Definitions of Ratings Revised as of May 7th, 2013.

Financial Interests

An equity analyst or a member of its household may not purchase the securities of a subject company 30 days before or 5 days after the issuance of the research analyst’s report or a change in ratings or price targets, trade inconsistent with the views expressed by the research analyst, and all transactions in a research analyst's personal trading account must be pre-approved. Neither the research analyst nor any member of his/her household may own any of the securities of the subject company including any options, rights, warrants, futures or long or short positions. An equity analyst may not trade contrary to his/her own recommendation in a research report. Neither a research analyst nor any member of his/her household may own 1% or more of any of the securities of the subject company based upon the same standards used to compute beneficial ownership for the purpose of reporting requirements under Section 13(d) of the Securities Act of 1934, as amended. Neither a research analyst or household member may be an officer, director, or advisory board member of the subject company. A research analyst may not make a public appearance in front of more than 15 persons to discuss the subject company and may not know or have reason to know at the time of this publication of any other material conflict of interest.

Receipt of Compensation

Receipt of Compensation: The research analysts at the firm do not receive any compensation based on investment banking revenues and may be paid a bonus based upon the overall profitability of the firm.

Techncial Analysis

This research report contains technical analysis which only takes into account historical price performance and it is not an analysis of fundamental factors or other price/risk indicators. When making an investment decision technical analysis alone should not be the only factor to take into consideration. Any price target or recommendation contained in this report based soley on technical analysis is valid as of the date of this publication only and the analyst’s “coverage” of the securities referenced begins and ends the same day. The research analyst welcomes and encourages any comments or questions with regard to this research report.

Other Additional Disclosures

The firm does not make markets in any securities whatsoever. The firm buys or sells securities for its own account. The firm buys or sells securities on a principal basis with customers. The firm’s employees who are not equity research analysts may buy or sell securities. Although the statements of fact in this report have been obtained from and are based upon outside sources that the firm believes to be reliable, the firm does not guarantee the accuracy or completeness of material contained in this report. Any such estimates or forecasts contained in this report may not be met. Past performance is not an indication of future results. Calculations of price targets are based on a combination of one or more methodologies generally accepted among financial analysts, including but not limited to, analysis of multiples and/or discounted cash flows (whether whole or in part), or any other method which may be applied. Rating, target price and price history information on the subject company (ies) in this report is available upon request. To receive any additional information upon which this report is based this information please contact 212-257-6970, or write to Research Production Department, Odeon Capital Group LLC, 750 Lexington Avenue, 27th fl. New York, New York 10022.

Odeon Capital Group LLC is a U.S. registered broker-dealer and member of FINRA, SIPC and MSRB. This report is prepared for general circulation. The information herein does not constitute a solicitation of an offer to buy or an offer to sell any security nor is it intended to be a complete summary or statement of all available data. This report is not produced based on any individual persons or entities investment objectives or financial situation and opinions expressed by the analyst are subject to change without notice. This report is not provided to any particular individual with a view toward their individual circumstances. Investors should consider this report as only a single factor in making an investment decision. As with any transaction having tax implications, investors should consult with their tax advisor before making investment decisions designed to generate tax benefits. As a matter of policy the firm does not offer tax advice and nothing herein should be construed as offering such advice. The securities mentioned in this report are highly speculative and involve a high degree of risk. Securities prices fluctuate and investors may receive back less than originally invested and are not guaranteed. International securities involve additional risks such as currency fluctuations, differing financial accounting standards, and possible political and economic instability. Small-cap stocks generally involve greater risks. Dividends are not guaranteed and will fluctuate. The securities recommended, offered, or sold by the firm, are not insured by the Federal Deposit Insurance Corporation, are not deposits or other obligations of any insured depository institution, and are subject to risks, including the possible loss of principal amount invested. Any opinions, estimates or projections expressed in this report may assume some economic industry and political considerations and constitute current opinions, at the time of issuance, and are subject to change. No part of this document may be copied, photocopied, or duplicated in any form or other means redistributed or quoted without the prior written consent of the firm. This report and its contents are the property Odeon Capital Group LLC and are protected by applicable copyright, trade secret or other intellectual property laws (of the United States and other countries). United States law, 17 U.S.C. Sec.501 et seq, provides for civil and criminal penalties for copyright infringement.