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Privacy Policy - 2007

AN IMPORTANT NOTICE CONCERNING OUR U.S. PRIVACY POLICY
We are required by federal law to provide you with a copy of our Privacy Policy annually. The following Policy applies to individual clients of Morgan Stanley Credit Corporation. This Policy is not applicable to partnerships, corporations, trusts or other non-individual clients or account holders. Please note that we may amend this Policy at any time, and will inform you of any changes to this Policy as required by law.

WE RESPECT YOUR PRIVACY
We appreciate that you have provided us with your personal financial information and understand your concerns about guarding such information and information about your Loan. We strive to maintain the privacy of such information while we help you achieve your financial objectives.

This Policy describes what non-public personal information we collect about you, how we collect it, and when we may share it with others.
It also discusses the steps you may take to limit our sharing of information about you with affiliated Morgan Stanley companies (“other Morgan Stanley companies”), including but not limited to our global financial services affiliates that are part of our integrated securities and investment management business, and our credit services affiliates. We hope this Policy will help you understand how we collect and share non-public personal information that we gather about you.

Throughout this Policy, we refer to the non-public information that personally identifies you or your accounts as “personal information.”

WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?
To serve you better and manage our business, it is important that we collect and maintain accurate information about you. We obtain this information from applications and other forms you submit to us, from your dealings with us, from consumer reporting agencies, from our Web sites and from third parties and other sources.

For example:

  • We collect information such as your name, address, e-mail address, telephone/fax numbers, assets, income and liabilities through applications and other forms you submit to us.

  • We may obtain information about loan balances, account balances, payment history and the types of products and services you prefer to receive from us through your dealings and transactions with us and other sources.

  • We may obtain information about your creditworthiness, credit history, balances of your loans and credit cards with other lenders and your payment history with others from consumer reporting agencies.

  • We may collect background information from and through third-party vendors to verify representations you have made and to comply with various regulatory requirements.

  • We may collect information about your Internet service provider, your domain name, your computer's operating system and Web browser, your use of our Web sites and your product and service preferences, through the use of “cookies.” “Cookies” recognize your computer each time you return to one of our sites, and help to improve our sites’ content and personalize your experience on our sites by, for example, suggesting offerings that may interest you. Please consult the Terms of Use of these sites for more details on our use of cookies.
  • WHEN DO WE DISCLOSE PERSONAL INFORMATION WE COLLECT ABOUT YOU?
    To provide you with the products and services you request, to serve you better and to manage our business, we may disclose personal information we collect about you to other Morgan Stanley companies and to non-affiliated third parties as required or permitted by law.

    a) Information we disclose to other Morgan Stanley companies In order to manage your account(s) effectively, including servicing and processing your Loan, to let you know about products and services offered by us and other Morgan Stanley companies, and as otherwise required or permitted by law, we may disclose personal information to other Morgan Stanley companies. Offers for products and services from other Morgan Stanley companies are developed under conditions designed to safeguard your personal information.

    b) Information we disclose to third parties
    We do not disclose personal information that we collect about you to non-affiliated third parties except to enable them to provide marketing services on our behalf, to perform joint marketing agreements with other financial institutions, or as otherwise required or permitted by law. For example, some instances where we may disclose information about you to third parties include: for servicing and processing transactions, to offer our own products and services, to protect against fraud, for institutional risk control, to respond to judicial process or to perform services on our behalf. When we share personal information with these companies, they are required to limit their use of personal information to the particular purpose for which it was shared and they are not allowed to share personal information with others except to fulfill that limited purpose.

    HOW DO WE PROTECT THE SECURITY, CONFIDENTIALITY AND INTEGRITY OF PERSONAL INFORMATION WE COLLECT ABOUT YOU?
    We maintain physical, electronic and procedural security measures to help safeguard the personal information we collect about you. We have internal policies governing the proper handling of client information. Third parties that provide support or marketing services on our behalf may also receive personal information, and we require them to adhere to confidentiality standards with respect to such information.
    It is important that the information we maintain about you is accurate and complete. If you see information in your monthly billing statements or elsewhere which suggests that our information is incomplete or inaccurate, please write to us at Morgan Stanley Credit Corporation, P.O. Box 5079, Sioux Falls, SD 57117-5079 so we can update this information.

    HOW CAN YOU LIMIT THE SHARING OF CERTAIN TYPES OF PERSONAL INFORMATION WITH OTHER MORGAN STANLEY COMPANIES?
    We respect your privacy and offer you choices as to whether we share with other Morgan Stanley companies personal information that was collected to determine your eligibility for products and services you request (“eligibility information”). Please note that, even if you direct us not to share eligibility information with other Morgan Stanley companies (“opt-out”), we may still share personal information, including eligibility information, with those companies in circumstances excluded from the opt-out under applicable law, such as to process transactions or to service your account. We may also share certain other types of personal information with other Morgan Stanley companies-such as your name, address, telephone number, e-mail address and account number(s), and information about your transactions and experiences with us.
    If you wish to opt-out, you may do so by:

  • Calling us toll-free at 1-800-767-7282

  • Writing to us at the following address:


  •      Morgan Stanley Credit Corporation
         4708 Mercantile Drive North
         Fort Worth, TX 76137
         Attn: Privacy Department

    If you choose to write to us, your written request should include your name, address, telephone number and account number(s) to which the opt-out applies and should not be sent with any other correspondence. In order to process your request, we require that the request be provided by you directly and not through a third party.

    If you have previously notified us about your privacy preferences, it is not necessary to do so again unless you decide to change your preferences. Your opt-out preference will remain in effect with respect to this Policy (as it may be amended) until you notify us otherwise in writing.

    If you have a joint account, your direction for us not to share this information with other Morgan Stanley companies will be applied to all account holders on that account.

    If you hold more than one account with Morgan Stanley Credit Corporation, you may receive multiple privacy policies from us, and would need to follow the directions stated in each particular policy for each account you have with us.

    If you are a new client, we will not share any information about you, except as permitted by law, for thirty days after we provide this Policy to you in order to give you an opportunity to inform us about your preferences, unless you have affirmatively provided us consent to share the information immediately.

    Please understand that if you opt-out, you and any joint account holders may not receive information about Morgan Stanley products and services that could help you manage your financial resources and achieve your investment objectives.

    SPECIAL NOTICE TO RESIDENTS OF VERMONT
    The following section supplements our Policy with respect to our individual clients who have a Vermont address and supersedes anything to the contrary in the above Policy with respect to those clients only.

    The State of Vermont requires financial institutions to obtain your consent prior to sharing personal information that they collect about you with affiliated companies and non-affiliated third parties other than in certain limited circumstances.
    As explained above, we do not disclose personal information that we collect about you to non-affiliated third parties except to enable them to provide marketing services on our behalf, to perform joint marketing agreements with other financial institutions, or as otherwise required or permitted by law. To the extent we enter into such joint marketing agreements with other financial institutions, we will only provide those institutions with your name, contact information and information about our transactions and experiences with you, unless you provide us with your written consent to share additional information (“opt-in”).
    In addition, except as described herein, we will not share eligibility information with other Morgan Stanley companies unless you opt-in.
    Please note that, even if you do not opt-in, we may still share personal information, including eligibility information, with those companies in circumstances permitted by applicable law, such as to process transactions or to service your account. We may also share certain other types of personal information with other Morgan Stanley companies-such as your name, address, telephone number, e-mail address and account number(s), and information about your transactions and experiences with us.
    If you wish to receive offers for investment products and services offered by or through other Morgan Stanley companies, please notify us in writing at the following address:

    Morgan Stanley Credit Corporation
    4708 Mercantile Drive North
    Fort Worth, TX 76137
    Attn: Privacy Department

    Your authorization should include your name, address, telephone number and account number(s) to which the opt-in applies and should not be sent with any other correspondence. In order to process your authorization, we require that the authorization be provided by you directly and not through a third party.

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