Terms and Conditions of Use

Use of the PRIMECAP Odyssey Funds' web site, owned and operated by PRIMECAP Management Company and PRIMECAP Odyssey Funds ("Funds") (collectively, "PRIMECAP"), signifies that you accept the following Terms and Conditions of Use. If you do not agree to these terms, do not use this site.

PRIMECAP reserves the right, at its discretion, to change, modify, add, or remove portions of these terms at any time. We suggest that you check these terms periodically for changes. The terms can be accessed from the link at the bottom of our web site pages. If you use this web site after we post changes to the terms, you accept the changed terms. PRIMECAP expressly reserves the right to monitor any and all use of this web site.

NOTE: ACCESSING OR REQUESTING ACCOUNT INFORMATION OR TRANSACTIONS THROUGH THIS SITE CONSTITUTES AND SHALL BE DEEMED TO BE AN ACCEPTANCE OF THE FOLLOWING TERMS AND CONDITIONS.

The accuracy, completeness and timeliness of the Funds' account information provided is the sole responsibility of the transfer agent, which provides the information. No party which provides a connection between this web site and the Funds or its transfer agency system can verify or ensure the receipt of any information transmitted to or from the Funds or its transfer agent, or the acceptance by, or completion of any transaction with, the Funds.

The on-line acknowledgments or other messages which appear on your screen for transactions entered do not mean that the transactions have been received, accepted or rejected by the Funds. These acknowledgments are only an indication that the transactional information entered by you has either been transmitted to the Funds, or that it cannot be transmitted. It is the responsibility of the Funds to confirm to you that it has received the information and accepted or rejected a transaction. It is the responsibility of the Funds to deliver to you a current prospectus, confirmation statement and any other documents or information required by applicable law.

NO TRANSACTION SHALL BE DEEMED ACCEPTED UNTIL YOU RECEIVE A WRITTEN CONFIRMATION FROM PRIMECAP ODYSSEY FUNDS.

You are responsible for reviewing the Funds account statements received by you in the mail to verify the accuracy of all the Funds' account information provided in the statement and all transactions entered through this site. You are also responsible for promptly notifying the Funds of any errors or inaccuracies relating to information contained in, or omitted from your Funds account statements, including errors or inaccuracies arising from the transactions conducted through this site.

TRANSACTIONS ARE SUBJECT TO ALL REQUIREMENTS, RESTRICTIONS AND FEES AS SET FORTH IN THE PROSPECTUS OF THE FUNDS.

Persons Resident Outside the United States

Shares of the Funds are offered only for sale in the United States. While you may obtain prospectuses and other information about our Funds at this web site, our Funds are not registered for sale in any other country. Nothing on this web site should be considered a solicitation to buy or an offer to sell shares of the Funds in any jurisdiction where the offer or solicitation would be unlawful under the securities laws of such foreign jurisdiction or the United States.

Privacy Policy

PRIMECAP expressly reserves the right to monitor any and all use of this web site, but will not release information about this use to any other company, individual, or group.

PRIMECAP is committed to maintaining the confidentiality, integrity and security of your personal and financial data and consider this information to be privileged and held in confidence between you and PRIMECAP. We believe that you should be aware of our policies to protect the confidentiality of this information.

We collect nonpublic personal information about you from the information we receive from you on applications and other forms and from transactions you initiate with us. As is common in the investment management industry, we use a third-party transfer agent and a third-party provider of back-end systems for our business who only use your information to process transactions you have requested. Our contracts with these organizations contain a confidentiality clause that prohibits the sale or any other use or dissemination of any of your personal information, except as may be required by law. Only when we have permission from you, do we disclose nonpublic personal information to third parties, such as consultants or accountants. We do not disclose any nonpublic personal information about you, as a current or former shareholder, to anyone, except when we have permission from you or as required by law.

We restrict access to nonpublic personal information about you to those employees and service providers involved in administering and servicing your account(s). We maintain physical, electronic and procedural safeguards that comply with federal standards to guard your nonpublic personal information.

Copyright Policy

PRIMECAP owns and operates this site. All trademarks, service marks, and trade names displayed on this site are proprietary to PRIMECAP Management Company, except as noted below.

Users and other web sites may not copy, reproduce, republish, upload, post, transmit, or distribute in any way material from PRIMECAP Odyssey Funds' web site, except as specifically stated below. Users and other web sites may not copy, modify, or display PRIMECAP Odyssey Funds' name, text, or graphic images in any way without PRIMECAP Odyssey Funds' express written permission except as set forth below. Users and other web sites may not redeliver any of the pages, text, images, or other content of PRIMECAP Odyssey Funds' web site using "framing" technology without PRIMECAP's express written permission.

Modification or use of the pages, text, images, or other content from PRIMECAP Odyssey Funds' web site for any other purpose is a violation of PRIMECAP's copyrights and other proprietary rights.

This limited authorization entitles other users and sites to link to PRIMECAP Odyssey Funds' homepage (http://www.odysseyfunds.com) only. Linking to other content within PRIMECAP Odyssey Funds' web site is prohibited without PRIMECAP Odyssey Funds' express written permission. The Terms and Conditions of Use expressly prohibit the framing of PRIMECAP Odyssey Funds' content in any way or any other activity that may create a misimpression or confusion among users with respect to sponsorship or affiliation. Any site offering a link to PRIMECAP Odyssey Funds' web site must deliver PRIMECAP Odyssey Funds' homepage address (http://www.odysseyfunds.com).

Ownership of Other Materials

Trademarks

Third-Party Content

PRIMECAP and its agents are in no way responsible for the content of any site owned by a third party that may be linked to PRIMECAP Odyssey Funds' web site via hyperlink, whether such hyperlink is provided by PRIMECAP or by a third party.

DISCLAIMERS

THERE ARE NO IMPLIED OR EXPRESSED WARRANTIES ON THE MATERIALS IN THIS SITE; THE MATERIALS ARE PROVIDED "AS IS." PRIMECAP AND ITS AGENTS DISCLAIM, TO THE FULLEST EXTENT UNDER APPLICABLE LAW, ANY WARRANTY OF ANY KIND, WHETHER EXPRESS OR IMPLIED, AS TO ANY MATTER WHATSOEVER RELATING TO THIS SERVICE, INCLUDING WITHOUT LIMITATION THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NONINFRINGEMENT. USE OF THIS SERVICE IS AT YOUR OWN RISK. PRIMECAP ODYSSEY FUNDS AND ITS AGENTS INTEND THAT THE INFORMATION CONTAINED IN THIS SERVICE BE ACCURATE AND RELIABLE; HOWEVER, ERRORS SOMETIMES OCCUR. PRIMECAP ODYSSEY FUNDS AND ITS AGENTS DO NOT WARRANT THAT THE FUNCTIONS CONTAINED IN THE MATERIALS WILL BE UNINTERRUPTED OR ERROR-FREE, THAT DEFECTS WILL BE CORRECTED, OR THAT THIS SITE OR THE SERVERS THAT MAKE IT AVAILABLE ARE FREE FROM VIRUSES OR OTHER HARMFUL COMPONENTS. PRIMECAP ODYSSEY FUNDS AND ITS AGENTS DO NOT WARRANT OR REPRESENT THAT THE MATERIALS IN THIS SITE ARE CORRECT, ACCURATE, OR RELIABLE. YOU (AND NOT PRIMECAP ODYSSEY FUNDS AND ITS AGENTS) ASSUME THE ENTIRE COST OF ALL NECESSARY SERVICING, REPAIR, OR CORRECTION OF YOUR PROPERTY OR OPERATIONS AS A RESULT OF USING THIS WEB SITE. BY USING, YOU ACCEPT AT YOUR OWN RISK THAT THE INTERNET AND ONLINE COMMUNICATIONS MEDIUM MAY NOT PERFORM AS INTENDED DESPITE THE EFFORTS OF PRIMECAP ODYSSEY FUNDS, YOUR INTERNET SERVICE PROVIDER, AND YOU. REFERENCE TO A FUND OR SECURITY ANYWHERE ON THIS WEB SITE IS NOT A RECOMMENDATION TO BUY, SELL, OR HOLD THAT OR ANY OTHER SECURITY. IF YOU LIVE IN A STATE THAT DOES NOT ALLOW DISCLAIMERS OF IMPLIED WARRANTIES, OUR DISCLAIMER MAY NOT APPLY TO YOU.

Limitation of Liability

PRIMECAP Odyssey Funds and its agents are not liable under any circumstances--including, but not limited to, negligence--for any special or consequential damages that may result from the use of, or the inability to use, the materials on this site, even if PRIMECAP Odyssey Funds and its agents have been advised of the possibility of such damages. PRIMECAP Odyssey Funds and its agents are not liable for damages or injury, including, but not limited to, damages or injury caused by any performance, failure of performance, error, omission, interruption, deletion, defect, delay in operation or transmission, computer virus, communications line failure, theft or destruction or unauthorized access to, alteration of, or use of information, whether resulting, in whole or in part, from breach of contract, tortious behavior, negligence, or otherwise. If you live in a state that does not allow the limitation or exclusion of liability or incidental or consequential damages, the above limitation or exclusion may not apply to you.

In no event shall PRIMECAP Odyssey Funds' and its agents' total liability to you for damages, losses, and causes of action--whether in contract, tort (including, but not limited to, negligence), or otherwise--exceed the amount paid by you, if any, for accessing PRIMECAP Odyssey Funds' web site.

Jurisdictional Issues and Applicable Law

Unless otherwise specified, PRIMECAP Odyssey Funds controls and operates this site from its offices in San Francisco, California, United States of America. PRIMECAP Odyssey and its representatives may only transact business in states where they are registered, excluded or exempted from state registration requirements.

PRIMECAP Odyssey Funds does not claim that materials in this site are appropriate or available for use in locations other than California. If you choose to access this site from other locations, you do so on your own initiative, and you are responsible for compliance with any applicable local laws.

The laws of the State of California govern these terms. If you take legal action relating to these terms, you agree to file such action only in the Superior Court--Unlimited Jurisdiction, County of San Francisco, or the United States District Court for the Northern District of California, and you consent and submit to the personal jurisdiction of those courts for the purposes of litigating any such action.

Termination

Either party may terminate this agreement at any time by destroying:

PRIMECAP Odyssey Funds will terminate this agreement immediately without notice if, in PRIMECAP Odyssey Funds' sole discretion, you fail to comply with any term or provision of this agreement. Upon termination, you must destroy all materials obtained from this site and all copies of those materials, whether or not they were made under these terms.

Integration and Severability

If any provision of these terms is deemed unlawful, void, or for any reason unenforceable, then that provision will be deemed severable from these terms and will not affect the validity and enforceability of the remaining provisions. The preceding terms and conditions of use represent the entire agreement between PRIMECAP Odyssey Funds and the user relating to the subject matter herein.

Terms and Conditions as of: January 31, 2011