PRIVACY POLICY

AllianceBernstein and its affiliates, the data controllers (collectively referred to as “AllianceBernstein”, “AB”, “we”, “our”, and similar pronouns) understand the importance of maintaining the confidentiality and security of our clients’ personal information. This notice describes the privacy practices of AB globally and aims to provide our clients with transparent information, in accordance with privacy laws.

The following describes information we collect about you, with whom we share your information, how we safeguard your information, and how you can contact us regarding our privacy notice and practices or to exercise your rights.

Our privacy notice reflects current global principles and standards on handling personal information. These principles include notice of data use, choice of data use, data access, data integrity, security, onward transfer, and enforcement/oversight. We abide by the privacy laws in the countries where we do business.

Security and Safeguarding of Personal Information

We have policies and procedures reasonably designed to safeguard the confidentiality and security of personal information that includes restricting access to nonpublic personal information to properly authorized persons and maintaining generally accepted physical, electronic and procedural safeguards. We train our employees in the proper handling of personal information. When we use other companies to provide services for us, we require them to protect the confidentiality of personal information they receive. However, although we will do our best to protect your personal data, we cannot totally guarantee the security of your data.

Information that we collect

We collect various elements of public and nonpublic personal information from a variety of sources including:

  1. Information we receive through applications or other means, which can include name, address, phone number, tax identification number or other government ID number (when allowed or required by applicable law), assets, income and other household information;
  2. Information about transactions with us, our affiliates and non-affiliated third parties (as further detailed below), which can include account balances and transactions history;
  3. Communications with AB, including but not limited to telephone calls and e-mails to provide you with requested products and services;
  4. Images of visitors to our offices from closed circuit television footage; and
  5. Information from visitors to our websites provided through online forms, website visit data and online information collecting technologies such as cookies, web beacons and pixels. Our Cookie policy can be found here.

We also collect information from publicly or commercially available sources that we deem credible. Such information may include your name, address, email address, interests and demographic/profile data. The information we collect from public or commercial sources may be used along with the information we collect from you directly or from when you visit AB’s sites.

How we use your information

We use information we collect from you as necessary or appropriate for our business purposes including to:

  • Fulfill contractual obligations
  • Open and administer accounts
  • Register users and provide you access to the website or services requested
  • Respond to inquiries or requests direct to us
  • Fulfill requests for products or services
  • Perform internal analysis, analytics, research and development to improve and add to our product offerings
  • Send communications and administrative emails about the website and our services and products
  • Personalize and better tailor the features, performance and support of the website and our services
  • Analyze, benchmark and conduct research on user data and user interactions with the website and our services
  • Assist in determining the likelihood that a person, account, transaction, message or device is associated with fraud or other malicious behavior
  • Administer our site and as part of our efforts to keep our site safe and secure
  • Deliver customer services
  • Conduct due diligence checks on business contacts as part of AB’s financial crimes and anti-corruption program
  • Satisfy required legal or regulatory obligations
  • Fulfill other purposes related to any of the above

Legal basis

We have a legal basis for collecting this information, as processing is necessary for either (i) the performance of a contract to which you are party or to take steps at your request prior to entering into a contract; or (ii) for direct marketing purposes carried out in AB’s legitimate interests; or (iii) for the purpose of conducting business with an entity you work for, or otherwise represent, in furtherance of AB’s legitimate interests, but only to the extent our legitimate interests are not overridden by your fundamental rights and freedoms.

Our legal basis for processing your personal information is that it is required for (i) the performance of a contract to which you are party or to take steps at your request prior to entering into a contract; (ii) direct marketing purposes; (iii) conducting business with an entity you work for, or otherwise represent, or (iv) in furtherance of AB’s legitimate interests, but only to the extent that our legitimate interests are not overridden by your fundamental rights and freedoms

How we disclose your information to third parties

We may disclose any of the personal information that we collect, as described above, to non-affiliated third parties under the circumstances described below and in this notice.

For legal and regulatory reasons:

We may disclose your information if we are under a duty to disclose or share your Information to comply with any legal or regulatory obligations; to enforce, apply or fulfil our terms and conditions and other agreements or to protect the rights, property, or safety of our customers, our group companies or others. This includes exchanging information with other companies and organizations to conduct due diligence checks on business contacts as part of AB’s financial crimes and anti-corruption programs.

To provide contracted services:

We use a number of third party organizations in the provision of services to our customers (i.e. processing centers, development and maintenance of our networks and systems). These organizations act as data processors and are strictly contractually controlled in how they may/may not use your Information and we remain responsible for the protection of your Information.

Please contact AB if you would like additional information about the third parties used to fulfil our contractual obligations.

For marketing:

We may also disclose any of the personal information that we collect as described above, to our affiliated investment, brokerage, service and insurance companies for the purpose of marketing their products or services under circumstances that are permitted by law. We have policies and procedures to ensure that certain conditions are met before an AB affiliated company may use information obtained from another affiliate to solicit clients for marketing purposes.

Our website may link to third party websites that have privacy policies that differ from ours, and you should consult those websites’ privacy policies to understand how they will collect, store, process, transfer, and otherwise use your personal information.

Should any third party, whether affiliated or not, be or become co-controller of a data processing activity with AB, because it jointly determines the purposes or the essential elements of the means which characterize a data controller, we will update our policies to inform you of the processing and how to exercise your rights.

To be removed from our email distribution lists, simply click the unsubscribe button found at the bottom of any of the emails that we send you. Please allow us at least ten (10) business days from when the request was received to complete the removal, as some of our promotions may already be in process before you submit your request. To alter your preferences regarding other marketing efforts please speak with your account representative or an AB service person as applicable.

TRANSFER OF PERSONAL INFORMATION OUTSIDE OF THE EUROPEAN ECONOMIC AREA (EEA) & SWITZERLAND

For the abovementioned purposes, the personal information listed in this notice may be transferred to our affiliates or non-affiliated third parties established in countries outside of the EEA & Switzerland, which do not offer the same level of protection for personal data.

We will take all reasonable steps necessary, including the use of the Model Contractual Arrangements as approved by the EU, or other contractual means to ensure that your Information is treated securely and in accordance with this notice, the EU General Data Protection Regulation and other applicable privacy rules.

AB transfers of personal data from the EEA & Switzerland are conducted in accordance with Model Contractual Clauses approved by European Data Protection Authorities.

We will only share information with third parties if those third parties provide an adequate level of data protection to help ensure the security of personal data as noted previously or such as being EU-U.S. or Swiss-EU Privacy Shield certified where applicable, or agreeing to the terms of an appropriate non-disclosure agreement (“NDA”) or a data transfer agreement.

Your rights

The following rights apply if you reside in the EEA or Switzerland. If you reside elsewhere, your rights may vary based on local laws and regulations.

Please note that we may retain your Information in conformance with our data retention policy most specifically for legal or regulatory purposes or to honor opt-out requests as appropriate.

Before we provide any information or make any changes, we may ask you to verify your identity and/or provide other details to help us respond to your request.

Accessing, Correcting or Erasing Your Information

As prescribed by the GDPR, you have the right to be informed about the data that AB holds about you, be able to access this information and be able to correct this information at any time. Additionally, you may have the right to have information that AB holds about your erased.

AB will treat requests to access information or change information in accordance with applicable legal requirements.

We want to maintain the accuracy of your information that is held by us. If you need to correct it, please do so by logging into your account or speaking with your account representative or an AB service person as applicable.

Right to Restrict processing of Your Information

You may have the right to object at any time, and on grounds relating to your individual situation, to AB’s processing of your information. Should you object to AB’s processing of your information, we may be unable to provide you, or the entity you work for, or otherwise represent, with the services requested the services requested. When you object to the processing of your information for direct marketing purposes, we shall no longer process your information for such purposes.

Right to data Portability

You have the right to receive your information that you have provided to AB in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without hindrance from us, where the processing of that information was based on your consent, explicit consent of special categories of data, or on a contract concluded between you and AB. Please note that such right to data portability only applies to processing carried out by automated means.

To exercise the rights above, contact the appropriate office in the Contact Information section of this document. We will treat your requests confidentially and will make reasonable efforts to provide information on actions taken by AB to respond without undue delay and in any event within one month of receiving a request to exercise the rights above

Right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint with a supervisory authority, in the Member State of your usual residence or the place of the alleged infringement if you believe that the processing of your personal information infringes data protection principles.

Enforcement and Complaints

We regularly review our compliance with this Privacy Notice. Any questions, concerns or complaints from customers outside of the EEA or Switzerland regarding this Notice or our treatment of your information may be directed to us.

A representative will contact you within a reasonable time after receipt of your complaint to address your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in a timely and appropriate manner.

Length of data retention

AB is subject to extensive recordkeeping requirements. The requirements are driven by laws and regulations based on the jurisdictions in which we are located and the regulated businesses that we operate. In addition to delineating the types of records that must be maintained, the various regulations also address the periods of time for which they must be kept and, in some cases, establish specific protocols for how, and in what form, those records may be maintained.

It is AB’s policy to maintain records for periods of time sufficient to meet its needs in accordance with operational, contractual, legal, regulatory, tax, audit and/or historical requirements, with respect to the purposes for which the personal data are obtained and processed.

Privacy Policy Changes

We may make changes to our privacy practices and this notice from time to time. If we change our privacy notice, we will post the revised notice here, with an updated revision date. If we make significant changes to our privacy practices that materially affect this privacy notice, we will provide a more prominent notification such as by sending a copy through the mail, sending you an email or posting a banner notice on our corporate website.

Contact Information

Global (excluding those areas noted below)
By e-mail: PrivacyOfficeAB@alliancebernstein.com
By letter:
AllianceBernstein L.P.
Attn: Privacy Office
1345 Avenue of the Americas
New York, NY 10105

Europe excluding Luxembourg
By e-mail: DPO-Europe-ExLux@alliancebernstein.com
By letter:
AllianceBernstein Limited
Attn: Privacy Office
50 Berkeley Street
London, W1J 8HA, England

Luxembourg
By e-mail: ABLuxDPO@alliancebernstein.com
By letter:
AllianceBernstein (Luxembourg) S.à r.l.
Attn: Privacy Office
2-4, rue Eugène Ruppert
L-2453 Luxembourg

Australia
By phone: 02 9255 1299
By e-mail: PrivacyAustralia@alliancebernstein.com
By letter:
AllianceBernstein Investment Management Australia Limited
Attn: Privacy Officer
Level 32, Aurora Place
88 Phillip Street
Sydney, NSW 200

Singapore
By phone: +65 62304600
By e-mail: PrivacySingapore@abglobal.com
By letter:
AllianceBernstein (Singapore) Ltd
Attn: Privacy Officer
One Raffles Quay
#27-11, South Tower
Sydney, NSW 200