Effective: May 2021
This Policy describes how we collect, use, share, and protect (“process”) Personal Information, as well as your rights regarding this processing. Additional State specific privacy disclosures may be found at the end of this Policy.
Who Is this Policy Applicable to?
Additionally, clients, plan participants, and other individuals who, by virtue of the financial services we provide, have their Personal Information protected by the Gramm Leach Bliley Act (“GLBA”), can find details on how Morgan Stanley processes your information in the GLBA privacy notices below, which supersedes this Policy. The GLBA notices further detail any opt-out rights that are available to you:
- Morgan Stanley Wealth Management (except Financial Wellness participants)
- Morgan Stanley Institutional Securities
- Morgan Stanley Investment Management
- Morgan Stanley Financial Wellness Participants
Morgan Stanley’s Privacy Pledge includes processing information for non-U.S. residents about how and why we process Personal Information, as well as links to the privacy statements or policies of some Morgan Stanley affiliates.
What Are the Sources of Personal Information?
We may obtain Personal Information from the following sources:
- our clients, their agents or representatives, applications, forms, surveys, or other documents or images, or from your dealings and transactions with us and other sources;
- our Affiliates;
- third parties, including consumer reporting agencies, service providers, joint marketing vendors, demographic firms, and other financial institutions;
- websites or mobile applications owned or operated by us;
- your use of our products and services; and
- sources that are publicly available.
What Personal Information Do We Process?
The type of Personal Information we process may vary depending on whether you deal with us as an individual or in connection with one of our corporate or institutional clients, your use of particular services, as well as the jurisdiction where you reside. We may process the following categories of information, among others (collectively defined as “Personal Information”):
- Identifiers, including the following:
- contact information, such as your name, phone numbers, address, email address, device or browser identifiers, usernames and passwords, voiceprint, security questions and answers;
- government-issued identifiers, such as your Social Security number, passport number, or other similar identifiers as required and permitted by applicable laws.
- Characteristics of classifications, such as your age, gender, marital status, nationality, or citizenship;
- Commercial and financial information, such as account balances, statements, transactions, your source of wealth/income, investable assets, loans, investment experience and objectives, creditworthiness and credit history, and risk tolerance;
- Professional or employment related information, such as your current employer and job history; and
- Internet, mobile application, or other electronic network activity information, to the extent you access one of our websites or mobile apps, including your usage of the website or application and your location.
Why Do We Process Personal Information?
We use Personal Information to better tailor and personalize our services and communications to you and for any other purpose permitted by applicable law, including the following purposes:
- to administer and operate services, including, without limitation, validating your identity, fulfilling online requests, maintaining or servicing accounts, verifying customer information, authorizing or confirming transactions, retaining records of transactions, for billing and/or tax purposes, and provide other services that you may request;
- to provide operational and technical support and development of our businesses, including to improve or enhance our services, evaluate customer service, efficiency and cost, as well as for risk management purposes;
- to carry out credit checks (where applicable), money laundering, conflict checks, for fraud and financial crime prevention purposes, or other activity required under applicable laws;
- to detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity;
- in order to comply with legal and regulatory requests made to us or any Affiliates anywhere in the world, and to assist with law enforcement, investigations, complaints, regulatory requests, litigation, arbitration, mediation, and other legal processes;
- for auditing or monitoring purposes, such as to establish the existence of facts (e.g., keeping records of transactions), to maintain compliance with regulatory or self-regulatory practices, to comply with applicable laws, and for other purposes permissible under applicable law; and
- to conduct research and analytics, and for marketing purposes such as offering products and services to you in accordance with applicable law.
With Whom Do We Share Personal Information?
We may share Personal Information at your request or to complete a transaction for which the Personal Information was collected, provide a service to you, assist you in exercising your rights with respect to your information, detect security incidents or illegal activity, conduct our regular business activity including quality assurance and marketing to you, and as required by law (for instance with regulators and law enforcement agencies).
We may share Personal Information for the purposes listed within this Policy to the following categories of recipients:
- our Affiliates;
- your agents, representatives, and other persons acting on your behalf or to whom you instruct or authorize us to disclose your Personal Information;
- if you are a representative of an entity or institution, to the entity or institution you represent;
- our service providers, including cloud service providers;
- third parties that are necessary to administer services to you or the client you represent or are associated with, such as general partners of funds we advise or manage;
- your employer or former employer, if you are or were a participant in a service for which your employer or former employer is a client of Morgan Stanley
- our agents and representatives, such as attorneys, auditors, and other professionals;
- government, legal regulatory, supervisory, or other authorities under applicable laws;
- prospective purchasers and assignees in the event our business, or a portion thereof, is sold or assigned; and
- other third parties as may be required for the purposes set forth within this notice, or where we have obtained the appropriate authorization if required.
We may also use and share Personal Information on an aggregate or deidentified basis (such that it does not identify individuals) for various business purposes, where permissible under applicable laws.
We do not sell Personal Information, and we have not done so for at least the past twelve (12) months prior to the effective date of this Policy.
What Additional Privacy Rights May You Have?
For California residents, the California Consumer Privacy Act (“CCPA”) provides certain rights regarding the information that we collect. In particular, you may have the following rights:
Notification of Personal Information Collection
We collect, use, and process your Personal Information, as described within this Policy, for expected internal reasons, legal obligations, and servicing a transaction or providing a service. In addition, we may use your information to detect security and fraud as well as technical support functions.
Further detail on categories of and Personal Information collected about you, sources of Personal Information, purposes for collecting Personal Information, as well as Third Parties to whom we disclose Personal Information, are described within this Policy.
Access to Specific Pieces of Information
You may request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months.
Upon your valid request, we will provide a report outlining specific pieces of Personal Information collected about you the consumer that you have requested. You may make this request a maximum of two times within a twelve-month period.
Deletion of Personal Information
You may request that we and our service providers delete any Personal Information that we collect from you. If you do so, please note we may have a legal reason to retain your information, as permitted by the CCPA, in accordance with the original reason provided for collecting and processing Personal Information as described within this document.
We retain Personal Information in accordance with our information management policies, which establishes general standards and procedures regarding the retention, handling, and disposition of our records, including Personal Information. Personal Information is retained as long as necessary to meet legal and regulatory requirements. Retention may be extended if we are required to preserve Personal Information in connection with litigation, investigations, and proceedings.
Opt Out of Sale
For the purposes of CCPA, we do not sell your Personal Information.
We will not discriminate against you for exercising your CCPA rights.
In order to provide a response, Morgan Stanley may ask that you provide clarifying or identifying information to verify your request. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity and confirm that the Personal Information relates to you.
You may designate an authorized agent to submit a request on your behalf by providing that agent with your written permission. If an agent makes a request on your behalf, we may still ask that you verify your identity directly with us before we can honor the request.
Agents who make requests on behalf of individuals will be required to verify their authority to make the request by submitting written authorization from the individual. We will not honor any requests from agents until authorization is verified.
To allow us to process your CCPA request, please submit your request via the channels below:
Morgan Stanley Wealth Management (including Shareworks shareplan participants) and Private Bank (including Residential Mortgage)
- Telephone: + 1 (866) 227-2256
- Web Form: Wealth Management web form
Morgan Stanley Institutional Securities Group and Investment Management
- Telephone: +1 (844) 846 9408
- Web Form: morganstanleydsr.ethicspoint.com
- See CCPA contact information on: https://www.eatonvance.com/privacy-and-security.php?
We reserve the right to modify or supplement this Policy at any time. Therefore, we recommend that you review this Policy, updated and posted on this Site, regularly for changes. The Effective Date of this Policy, as stated above, indicates the last time this Policy was revised.