Effective Date: November 1, 2017


The GSPS business within Morgan Stanley Smith Barney LLC ("MSSB", "us", "our" or "we") appreciates that you have provided us with your personal information 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 and any alternative, replicated and/or back up website made available by or on behalf of us (the "Site") or through a software application on a mobile device that was made available by or on behalf of us (an "App"). Please read this Online Privacy Policy carefully before using the Site or an App (collectively, our "online services"). This Online Privacy Policy is applicable only to individuals when accessing and using our online services.

This Online Privacy Policy describes how we collect information when you access or use our online services, how we use, share and protect that information, and how you can update that information. This Online Privacy Policy does not apply to other information we collect, including information collected on other websites, such as separate websites operated by us or by our affiliates or business partners that do not post this Online Privacy Policy, 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 Online Privacy Policy, the GSPS Website Terms and Conditions and the GSPS Mobile Terms and Conditions, into which this Online Privacy Policy is incorporated.

Information Collected

We collect information provided by your current and/or former employer or that you provide via forms, applications, surveys or other online fields including 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 for identification purposes, to fulfill your online requests, or where we believe it is reasonably required for ordinary business purposes.

When you visit our online services, we and companies we work with may track and collect information from the computer or mobile device you used to access our online services, including the following:

Please see "Cookies and Other Tracking Technologies" below to understand how we collect some of the data described above. We, along with our service providers and business partners, use this data to calculate usage levels for our online services, diagnose problems, ensure that our online services function properly, and for the purposes described below under "Use of Collected Information."

Use of Collected Information

We, our affiliates and service providers, may use information we collected through our online services to:

How We Share Personal Information

We may disclose personal information we collect about you in each of the categories listed immediately above to affiliated companies and to non-affiliated third parties. Please be aware that Morgan Stanley may also share your information (including personal, transactional and tax information), along with information about how you use our online services, with your current and/or former employer for administrative purposes such as record keeping or to assess satisfaction with our services, 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 non-affiliated 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 information 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 consumer) for various business purposes, where permissible under applicable laws and regulations.

Cookies and Other Tracking Technologies

We, our affiliates and/or other persons acting on our or their behalf, use cookies and similar technology, such as web beacons (also known as clear GIFs or pixel tags), or similar technologies as they may develop over time. We use cookies and similar technologies to collect, use, and share information when you visit our online services or interact with us online, e.g., via email or other electronic means.

Cookies are small pieces of data sent from a website and stored on a device. Cookies may enable us to capture and compile statistical information about how you use our online services, including information relating to your device's IP address, the frequency of your visits, readership data (such as the average length of visits, which pages are viewed or shared during a visit or other interactions with our content, such as time spent viewing videos, PDFs read and links clicked), authentication information, acceptance or rejection of website terms, and periods of inactivity. We, our affiliates and/or other persons acting on our or their behalf use this information to assess the effectiveness of advertising and readership content, to deliver marketing communications that may be of interest to you (including ads or offers tailored to you), and for the purposes described under "Use of Collected Information."

To learn more about cookies, including information on what cookies have been set on your device and how cookies can be managed and deleted, visit Unless you have adjusted your browser setting so that it will reject cookies, our system will issue cookies when you access or use our online services. In the event you refuse to accept cookies by adjusting your browser setting, some or all areas of our online services may not function properly or may not be accessible.

Our online services may use Adobe Analytics to track your activity. To opt out of being tracked by Adobe Analytics across all websites, please click here

In addition to cookies, our online services also use web beacons. Web beacons are invisible tags and may be placed on a webpage or email or other message. They usually work in conjunction with cookies, registering when a particular device visits a particular page. We use web beacons for internal purposes, such as to measure the effectiveness of our communications, compile statistics about usage and response rates, and to assist us in resolving user questions about the use of our online services.

Do Not Track Policy

Most browsers can be set to send signals to third party websites requesting them not to track the user's activities. At this time, we do not respond to "do not track" signals. Consequently, our third party service providers such as Adobe Analytics, and other third party websites and online services, may indeed track and collect information about your online activities over time while navigating to, from and on our online services and across those third party websites and online services, notwithstanding any "do not track" signals we may receive.

Our Security Procedures

At MSSB, our goal is to protect your personal information submitted to us through our online services. We maintain reasonable physical, electronic, and procedural safeguards reasonably designed to guard nonpublic 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 personnel and requiring third parties that provide support on our behalf 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.

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.

Mobile Applications

When you connect to us using a mobile application, we may request your permission to access certain information, such as your location. These permission-related features are opt-in and you can turn these features off at any time.

Some mobile applications will utilize analytic tools to help us better serve our customers 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.

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 websites such as other Morgan Stanley websites and websites belonging to third parties, such as your current and/or former employer. The inclusion of a link on our Site or App does not imply endorsement of the linked website or service by us. While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites or links posted on our online services. Information you disclose to other parties (including your current and/or former employer) or through such websites, is subject to the privacy and security practices and policies of those parties or websites. We disclaim all liability with regard to your access to such linked websites. Access to any other websites is at your own discretion and we encourage our users to read the privacy statements of each and every website or online services 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, and made available to you on an unsolicited basis, without any marketing or promotion from MSSB or its personnel. MSSB does not offer these services to individuals directly and outside the context of GSPS. 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 to or processed in the United States.

Protecting Children's Privacy Online

Our online services are not directed to or intended for individuals under 18 years of age.

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 this Site, regularly for changes. The Effective Date of this Online Privacy Policy, as stated above, indicates the last time this Online Privacy Policy was revised. Your continued use of our online services after we have changed the Online Privacy Policy signifies your acceptance of the revised terms. Under certain circumstances (i.e., with respect to material changes to this Online Privacy Policy), we may also elect to notify you through additional means, such as by posting a notice on the front page of the Site or sending you an email.