Privacy at AB

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 policy and practices of AllianceBernstein globally and aims at providing our clients with complete information, in accordance with privacy laws.

The following describes information we collect about you, with whom we share data, how we protect your privacy and keep your information secure, and how you can contact us regarding our privacy policy and practices or in order to exercise your rights.

Our privacy policy 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, and
  3. Information from visitors to our websites provided through online forms, site visitorship data and online information-collecting devices known as "cookies." Our policy on cookies 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, preferences, 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:

  • Fulfil contractual obligations arising from contracts
  • Open and Administer accounts
  • Register users and provide you access to the website or services requested
  • Respond to inquiries or requests direct to us
  • Fulfil requests for products or services
  • 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
  • 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 programs
  • To satisfy any and all required legal or regulatory obligations
  • Fulfil 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 and in compliance with your fundamental rights and freedoms; 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.

Should you restrict the information that we collect from you, or the processing of your information, we may be unable to provide you, or the entity you work for, or otherwise represent, with the services requested.

How we disclose your information to third parties

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

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 or in order to enforce or apply or fulfil our terms and conditions and other agreements or 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 all 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 AllianceBernstein 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 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.

We will also use personal information about our clients for our own internal analysis, analytics, research and development, and to improve and add to our client offerings.

Transfer of Personal Information Outside of the European Economic Area (EEA)

For the abovementioned purposes, the personal information listed in this policy may be transferred to our affiliates or non-affiliated third parties established in countries outside of the EEA, which do not offer the same level of protection for personal data, e.g. in the following countries: United States; Canada; Latin America; Australia; Japan; Korea; Taiwan; Singapore; Hong Kong; China.

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 Policy, the EU General Data Protection Regulation and other applicable privacy rules.

AB transfers of personal data from the EEA are conducted in accordance with approved 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. Privacy Shield certified where applicable, or agreeing to the terms of an appropriate non-disclosure agreement (“NDA”) or a data transfer agreement.

Your rights

Access and Accuracy/Reviewing or Deleting Your Information

As prescribed by the GDPR, you have the right to access information about you held by AB and have the right to have this information corrected or amended at any time, or where it is inaccurate or inappropriate for the specified purposes of processing.

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.

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 update or correct it, please do so by logging into your account where applicable, speaking with your account representative or an AB service person where applicable.

You also may update your information by contacting us. See the Contact Information section of this document for more information.

We will make reasonable efforts to incorporate the changes as soon as possible. Before we make any changes, we may ask you to verify your identity and/or provide other details to help us respond to your request.

Right to object to processing

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 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 is based on your consent 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.

Right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint with a supervisory authority, if you believe that the processing of your personal information infringes data protection principles or laws.

Enforcement and Complaints

We regularly review our compliance with this Policy. Any questions or concerns regarding this Policy or our treatment of your information may be directed to us. See the Contact Information section of this document for more information.

We will treat your requests or complaints confidentially. 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 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 policy and this statement from time to time. If we change our privacy policy statement, we will post the revised statement here, with an updated revision date. If we make significant changes to our privacy policy that materially alter our privacy practices, we will provide a more prominent notice such as sending a copy through the mail, providing notice via email or posting a notice on our corporate website. This privacy policy statement was last updated on May 21, 2018.

Contact Information

Global ex Europe

By e-mail: DPO-Europe-ExLux@alliancebernstein.com
By letter:
AllianceBernstein L.P.
Attn: Privacy Office
1345 Avenue of the Americas
New York, NY 10105

Europe ex 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: DPO-Europe-ExLux@alliancebernstein.com
By letter:
AllianceBernstein (Luxembourg) S.à r.l.
Attn: Privacy Office
2-4, rue Eugène Ruppert
L-2453 Luxembourg