Privacy Policy

NYPPEX has a long-standing commitment to safeguard the privacy of information our clients entrust to us is essential to our goal of business leadership. Protecting the confidentiality and security of client information has always been an integral part of how we conduct our business worldwide.

We pledge to continue to ensure that our global business practices protect your privacy. Where applicable, more specific privacy policies are posted on the home pages of our individual businesses. We are committed to maintaining the privacy and confidentiality of your personal information.

This Policy explains what personal information we collect about you, how we use, disclose and share that information, and the rights you have in connection with that information. Certain rights, requirements, and disclosures in this Policy  may be subject to exemption or otherwise may not apply to you based, for example, on applicable law or regulations. This information is required by law and is not a promotion of our products and services.

Personal information that we collect about you when you apply for a job at NYPPEX or when you act as an employee or contractor at NYPPEX is governed by a separate Policy, which will be provided to you at or before the time your personal information is collected.

Before providing NYPPEX with access to, or permitting any access to, or permitting the processing of, any personal information regarding an individual other than yourself, in connection with services provided, you should ensure that you have the requisite legal authority under all applicable privacy laws to provide such personal information.

Information We Collect

As described in this Policy, we may collect personal information from or about you in order to provide, enhance, market, and offer our products and services, including the products and services of our NYPPEX affiliates (together, “Services”) to you and to our institutional clients.  “Services” include, among other things, maintaining or servicing accounts.

This section describes the categories of personal information we may collect, including personal information we may have collected in the past twelve months.  The type of personal information we collect 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. For purposes of this Policy, personal information generally includes information that may be used to identify you. We only collect personal information in accordance with applicable law.

You are not required to supply any of the personal information that we request. However, failure to supply any of the personal information that we request may result in our being unable to open or maintain your account, provide services to you or your company, discuss any other opportunities with you or deal with other matters.

In addition, we may compile aggregate, anonymous, or de-identified data from various sources, including, but not limited to, accounts and transactions.  This data, which we may use for our business purposes consistent with applicable law, does not identify an individual and is not personal information.

Sources of Information and Purposes of Collection and Disclosure

This section describes the sources we may collect personal information from, and why we may collect and, if applicable, disclose personal information. We only use sensitive personal information for purposes not subject to use limitation rights under applicable law.

Information We May Disclose and to Whom We May Disclose It

This section describes the categories of personal information we may disclose to certain entities, including, but not limited to, third parties that perform services for us and affiliates.  This includes personal information we have disclosed in the past twelve months.  We may disclose your personal information for the purposes described in Section 2, (i) if you have provided your consent for disclosure, or (ii) as otherwise permitted or required by law. 

 Information We May Disclose for Cross-Context Behavioral Advertising Purposes

This section describes the categories of personal information we may disclose for “cross-context behavioral advertising” i.e. delivering targeted advertising to consumers based on personal information we may obtain from their activity across businesses, distinctly-branded websites, applications, or services, other than those with which they

intentionally interact.  We do not and have not sold personal information for monetary consideration; however, we may share personal information with cookie providers for targeted online advertising.

Policy to California Residents

This section describes your rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CPRA”) and how to exercise those rights. 

 Description of Your Rights

 Subject to certain exceptions and limitations, you have the following rights with respect to covered personal information. 

• Right to request access to personal information.  You have the right to request the following information from us.
  • Specific pieces of personal information we have about you;
  • Categories of personal information we have collected about you;
  • Categories of sources from which the personal information is collected;
  • Categories of personal information sold, shared, or disclosed, if any;
  • Categories of third parties with whom the personal information was sold, shared, or disclosed; and
  • The purpose(s) for collecting, sharing, or selling the personal information.
• Right to delete personal information.  You have the right to request that we delete the personal information we have collected about you.

• Right to correct inaccurate personal information. You have the right to request that we correct inaccurate personal information that we maintain about you.

• Right to opt-out of the sale/sharing of personal information.  You have the right to request to be opted out from the sale/sharing of your personal information; however, as set forth in Section 4, we do not and have not sold your personal information for monetary consideration; however, we may share personal information with cookie providers for targeted online advertising.  You can opt-out of sale/sharing of your personal information on morganstanley.com websites that have “Your Privacy Choices” in the footer.

• Right not to be discriminated against for exercising the rights identified above.  You have the right not to be denied goods or services, charged different prices or rates for goods or services, or receive a differing level of quality of goods or services as a result of exercising the above rights.
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Covered Personal Information

The rights described in Section 5.1 do not apply to certain categories of personal information.  The personal information excluded from coverage under the CPRA includes, among other things:

• Personal information we collect from or about you when you apply for or obtain a product or service for personal, family or household purposes; and
• Personal information sold or bought from a consumer reporting agency for use in a consumer report in compliance with applicable law.

    We will apply verifiable consumer requests to cover personal information.