Effective: January 2020
Morgan Stanley (“us”, “our”, or “we”) appreciates that you have trusted us with your Personal Information; protecting that information is an important part of how we conduct our business. We believe it is important for you to know how we treat Personal Information that we may have about you. This policy is a U.S. Privacy Notice (“Notice”) provided on behalf of our entities, as well as other persons or entities acting on our behalf.
This Notice describes how we collect, use, share, and protect (“process”) information.
The Notice should be read in conjunction with any other policy or notice you receive from other companies controlled by, or under common control with, Morgan Stanley, including companies sharing common Morgan Stanley branding (“Affiliates”).
Who Is this Notice Applicable to?
This Notice describes the rights you have concerning the Personal Information we collect about you. This Notice is applicable to U.S. residents about whom we have Personal Information, except:
- 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”). Please see the privacy notices below to understand how GLBA protects your privacy:
- Employees and contingent workers, and job applicants.
If you are not a U.S. resident, please refer to www.morganstanley.com/privacy-pledge for more information about how and why we process Personal Information.
What Are the Sources of Personal Information We May Have About You?
We may obtain Personal Information from the following sources:
- our clients, their agents or representatives, applications, forms, or other documents, or from your dealings and transactions with us and other sources;
- our Affiliates;
- consumer reporting agencies;
- service providers;
- joint marketing vendors;
- websites or mobile applications owned or operated by us; 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, as well as the jurisdiction where you reside. We may process the following categories of information, among others:
- Identifiers, including the following:
- contact information, such as your name, phone number, postal address, email address, and your personal and/or work-related contact information;
- 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 your source of wealth/income, investment experience and objectives, creditworthiness and credit history, and risk tolerance;
- Professional or employment related information, such as current or past job history; and
- Internet or other electronic network activity information, to the extent you access one of our websites.
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, maintaining or servicing accounts, verifying customer information, authorizing or confirming transactions, retaining records of transactions, and for billing purposes;
- 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 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 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 Notice 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;
- 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;
- 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 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 Notice, 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 Notice.
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. Our obligation to comply with this request is subject to exemptions. If you are interested in requesting deletion of your Personal Information, 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
While, under the CCPA, you may request that we do not sell your Personal Information, because we do not sell any Personal Information, there is no need to opt out of sales.Anti-Discrimination
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:
- Wealth Management
- Telephone: + 1 (866) 227-2256
- Web Form: https://www.morganstanley.com/wealth-general/privacy-inquiries
- Institutional Securities Group and Investment Management
- Telephone: +1 (844) 846 9408
- Web Form: morganstanleydsr.ethicspoint.com
We reserve the right to modify or supplement this Notice at any time. Therefore, we recommend that you review this Notice, updated and posted on this Site, regularly for changes. The Effective Date of this Notice, as stated above, indicates the last time this Notice was revised.