MORGAN STANLEY GLOBAL STOCK PLAN SERVICES ("GSPS") ONLINE PRIVACY POLICY

Effective Date: September 2015

Overview

Morgan Stanley Smith Barney LLC ("MSSB", "us", "our" or "we") is in possession of certain of your personal information (as defined below) and 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 information about you that we may receive from you or your current or former employer through this website at https://www.stockplanconnect.com and any alternative, replicated and/or back up website made available by or on behalf of us (the "Website") or through a software application on a mobile device that was made available by or on behalf of us (an "App"). Please read this Privacy Policy carefully before using the Website or an App (collectively, our "online services"). This Privacy Policy is applicable only to individuals when accessing and using our online services. Our online services are not directed to or intended for individuals under 18 years of age.

This Online Privacy Policy describes how we collect, use, share and protect information when you access or use our online services and how you can update and control such information. This Online Privacy Policy does not apply to other information we collect, including information collected on other sites, such as separate sites operated by us or by our affiliates or business partners or other information that may be provided to us through other means.

By visiting or using our online services, you are consenting to the practices and procedures described in this Privacy Policy, the GSPS Website Terms and Conditions https://www.stockplanconnect.com/docs/globalTermsAndConditions.html and the GSPS Mobile Terms https://www.stockplanconnect.com/docs/mobileTermsAndConditions.html and Conditions into which this Privacy Policy is incorporated.

Information Collected

Personal information means personally identifiable information such as name, postal or email addresses, telephone, fax or mobile numbers, user name, password and account numbers. There are portions of our online services where we may collect personal information about you.

In addition, when you visit the Website, our web servers collect the IP address of the device you used to access the Internet, which pages on the Website you visited and when they were visited, your Internet browser type and platform, the link that brought you to the Website and any links clicked within the Website. This information may be used by us, our service providers, affiliates and business partners to measure the number of visits, average time spent, page views and other statistics about visitors to the Website. We also use this data to monitor the Website performance and make the Website easier and more convenient to use.

Our web servers also seek (as many websites do) to place a "cookie" (a small data file) on your computer's hard drive which allows the server to determine the computer when it visits again in order to track statistical information about navigation to and throughout certain areas of the Website. This cookie is not used to obtain your name or any personal information, and the information that is tracked is used only for internal purposes, such as to improve the Website navigation and to measure the effectiveness of the Website, and is not shared with anyone other than MSSB affiliates and contractors who assist MSSB in these efforts and who are bound to confidentiality. Many web browsers allow you to control the use of most cookies through their browser settings. To learn more about cookies, including information on what cookies have been set on your computer and how cookies can be managed and deleted, visit www.allaboutcookies.org. Unless you have adjusted your browser setting so that it will reject cookies, our system will issue cookies when you access or use the Website. In the event you refuse to accept cookies by adjusting your browser setting, some or all areas of the Website may not function properly or may not be accessible. To view our and our affiliates' full Global Cookies Policy, click here.

When you download and use our Apps, we and companies we work with may track and collect application usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your unique device identifier, and may also collect the IP address of the device on which you use the App. In addition, we may gather information such as which version of the application you are using, your screen resolution, the type of operating system you have and your device model and manufacturer. This information helps us provide a mobile experience that matches your device and also helps us calculate usage levels of the App, diagnose problems, ensure that the App functions properly and otherwise administer the App.

Some mobile applications will utilize analytic tools to help us better serve our users through improved products, services, and revisions to the mobile applications. This collected information does not identify you to MSSB. It may, however let us know anonymously, which services and features you are using the most within the application, as well as device type and hardware features, country and language of download.

Use of Collected Information

We may use information you provide us through or otherwise available on our online services to:

Information Sharing

We may disclose personal information we collect about you in each of the categories listed immediately above to affiliated companies and to nonaffiliated third parties. Please be aware that Morgan Stanley will also share your information (including personal, transactional and tax information), along with information about how you use our online services, with other users within your current and/or former employer for administrative purposes such as recordkeeping, to comply with laws, regulations, legal processes and law enforcement requirements and any other purposes that complies with applicable law and regulation.

When we share personal information about you with a nonaffiliated third party, they are required to limit their use of personal information about you to the particular purpose for which it was shared and they are not allowed to share personal information about you with others except to fulfill that limited purpose or as may be permitted or required by law.

If we have personal information obtained from you, or information that is available from other sources, including from third parties (like your current and/or former employer), from both offline and online sources, we may use it in combination with the information that we have collected through our online services. We can use this information to better tailor and personalize our services and communications with you, both online and offline, and for any other purpose that complies with applicable law and regulation.

We may also use and share data that we collect on an aggregate or anonymous basis (such that it does not identify any individual consumers) for various business purposes, where permissible under applicable laws and regulations.

Our Security Procedures

At MSSB, our goal is to protect your personal information submitted to us. We maintain physical, electronic, and procedural safeguards reasonably designed to guard personal information about you against loss, misuse or unauthorized access, disclosure, alteration or destruction of the information that has been provided to us through our online services. We have internal policies governing the proper handling of personal information by our employees. Morgan Stanley employees who misuse personal information may be subject to disciplinary action. Third parties that provide support on our behalf may also receive personal information about you, and we require them to adhere to appropriate security standards with respect to such information. As noted above, your current and/or former employer also will receive your personal information along with transactional and tax information and they will be subject to their own internal security procedures.

Do Not Track Policy

We do not engage in the collection of personal information about your online activities over time and across third party Web sites and do not allow third parties to collect personal information about your online activities over time and across third-party Web sites when you use our online services. We do not respond to Web browser "do not track signals".

Updating Your Information

You may review, or update certain account information by logging into our online service. If you cannot change the incorrect information online, or you prefer to request changes offline, please update such information by contacting your financial advisor or customer service using the contact information listed on your account statements, records, or other account materials. Please note that certain information, such as your name, corporate email address, home address, hire date and birth date, may only be changed through your current or former employer.

Links to Other Websites

This Online Privacy Policy only applies to the use and disclosure of information we collect through our online services. Our online services may contain links to other sites such as other Morgan Stanley websites and sites belonging to third parties, such as your current and/or former employer. The inclusion of a link on the Website or App does not imply endorsement of the linked site or service by us. While we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other sites or links posted on our online services. Information you disclose to other parties (including your current and/or former employer) or through such sites, is subject to the privacy and security practices and policies of those parties or sites. We encourage our users to read the privacy statements of each and every website or online service visited, in order to learn how such third parties may treat your information.

International Users

Our online services are United States-based and are controlled, operated and administered by MSSB from its offices within the United States of America. This Online Privacy Policy is provided in accordance with and subject to applicable U.S. law. If you decide to continue to access our online services from your location outside the United States, you hereby agree that your use of those services is subject to this Online Privacy Policy and your personal information may be transferred or processed in the United States.

Changes to this Privacy Policy

We reserve the right to modify or supplement this Online Privacy Policy at any time. Therefore, we recommend that you review this Online Privacy Policy, updated and posted on the Website, regularly for changes. The Effective Date of this Online Privacy Policy, as stated above, indicates the last time this Online Privacy Policy was revised or materially changed. Your continued use of our online services after we have changed the Privacy Policy signifies your acceptance of the revised terms. Under certain circumstances (i.e. with respect to material changes to this Privacy Policy), we may also elect to notify you through additional means, such as posting a notice on the front page of the Website or sending you an email.