California Consumer Privacy Act Disclosure

Under the CCPA, "Personal Information" is information that identifies, relates to, or could reasonably be linked with a particular California resident or household, subject to certain exclusions. The CCPA, however, does not apply to certain information, such as information subject to the Gramm-Leach-Bliley Act (“GLBA”). As a result, this Disclosure does not apply with respect to information that we collect about consumers who request information about, apply for or obtain our financial products and services for personal, family, or household purposes.

We collect Personal Information relating to California residents in a variety of contexts. For example, we collect Personal Information relating to California residents: (i) who are prospective consumers of our services for their personal, family or household purpose with whom we do not yet have a relationship, (ii) who obtain our products and services on behalf of institutional or other commercial purposes or are individuals associated with our institutional-investor customers, (iii) who represent businesses that we interact with (e.g., our service providers, vendors, business partners, counterparties, and third party professional services providers), (iv) who visit our locations or facilities in California, and (v) who visit our web sites. The specific Personal Information that we collect, use, and disclose relating to a California resident will depend on our specific relationship or interaction with that individual.

In the past 12 months, we have collected the following categories of Personal Information relating to California residents. These categories are defined by California law. We do not necessarily collect all information listed in a particular category, nor do we collect all categories of information for all individuals.

We have shared information in each of the following categories with our affiliates and service providers for our business purposes within the last 12 months. As a financial services company, we may also receive requests for information from regulatory authorities, our auditors and/or our legal advisors. If requested from such parties, we would share your Personal Information as appropriate. In the event we are acquired by or merge with another company, or otherwise undergo a change of control, we may also share each of the below categories as part of that transaction.

In the past 12 months, however, we have not "sold" or “shared” for “cross-context behavioral advertising” any Personal Information relating to California residents within the meaning of the CCPA. Please note that Personal Information we collect from or generate about you in connection with providing you a financial service or product for personal, family, or household purposes may be shared with third parties pursuant to the GLBA. 

• Identifiers, such as name, contact information, online identifiers, Social Security numbers and other government ID numbers;
• Personal information, as defined in the California customer records law, such as name, contact information, signature, government ID numbers, insurance and financial account information, and education and employment information;
• Protected classifications under California or federal law, such as sex and marital status;
• Commercial information, such as transaction and transaction history;
• Internet or network activity information, such as browsing history and interactions with our website;
• Geolocation data, such as device location;
• Audio, electronic, visual, and similar information, such as call and video recordings;
• Professional or employment-related information, such as work history and prior employer; and/or
• Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.

We also collect the below categories of Sensitive Personal Information as defined under California law (even though as with Personal Information more broadly, the California Consumer Privacy Act may not apply at all times). 

We have shared information in each of the following categories with our affiliates and service providers for our business purposes within the last 12 months. As a financial services company, we may also receive requests for information from regulatory authorities, our auditors and/or our legal advisors. If requested from such parties, we would share your Personal Information as appropriate and as permissible under federal and state law. In the event we are acquired by or merge with another company, or otherwise undergo a change of control, we may also share each of the below categories as part of that transaction: 

• Social security, driver’s license, state identification card, or passport number; and/or
• Account log-in or financial account number in combination with any required security or access code, password, or credentials allowing access to an account.

We do not use or disclose your sensitive personal information for purposes other than providing our products and services or as otherwise permitted under applicable law.

In the past 12 months, however, we have not "sold" Sensitive Personal Information relating to California residents within the meaning of the CCPA. 

We may collect Personal Information and Sensitive Personal Information from you (directly or indirectly); from recruiters, from third party service providers (e.g., benefits providers), and from government agencies and actors.

The purposes for which we use the Personal Information and Sensitive Personal Information that we collect depends on our relationship or interaction with a specific California resident. Nonetheless, we may use this information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives. For example, we use this information to personalize, develop, and market our products and services to retail and institutional investors, and to provide our products and services to institutional investors, conduct research and data analysis, maintain our facilities and infrastructure, conduct risk and security control and monitoring, detect and prevent fraud, perform identity verification, perform accounting, audit, and other internal functions, such as internal investigations, comply with law, legal process, and internal policies, maintain business records, and exercise and defend legal claims.

We store personal information about you on computer systems operated by us or our service providers. Due to being a highly regulated company, we keep various records that contain personal information in accordance with applicable state and federal regulations, or pursuant to contractual obligations. In general, we aim to keep personal information only for as long as necessary and only for the reason(s) we collected it. It may be necessary to keep personal information longer than our official retention periods for legal or regulatory reasons, including litigation. To support us in managing how long we hold personal information and our record management, we maintain a data retention policy which includes guidelines on retention and deletion. 

We consider the following criteria when determining how long a particular record will be retained, including any personal information contained in that record:

• How long the record is needed to provide you with the products and services you request;
• How long the record is needed to support and enhance our operational processes;
• How long the record is needed to protect our rights and legal interests; and
• How long the record must be retained to comply with applicable laws and regulations.

The same personal information about you may be included in more than one record and used for more than one purpose, each of which may be subject to different retention periods based on the factors listed above.

We do not currently support the capability to respond to web browser “do not track” signals or opt-out preference signals. We do not sell your personal information or share it for cross-context behavioral advertising.

We do not knowingly collect Personal Information directly from individuals under 16 years of age.  Our services are not intended for individuals under 16 years of age. No one under 16 years of age should submit or post Personal Information through our services. We may collect Personal Information regarding individuals under 16 years of age from their parents or legal guardians, but only as necessary to provide our products and services.

California residents have certain rights regarding their Personal Information, including:

• Right to know and access – You may be entitled to request that we disclose to you Personal Information we have collected about you, the categories of sources from which we collected the information, the purposes of collecting the information, the categories of third parties with whom we have shared the information, and the categories of Personal Information that we have shared with third parties for a business purpose. In some instances, you may have the right to receive the information about you in a portable and readily usable format. Before providing any of this information, we must be able to verify your identity.
• Right to opt-out of sale – We currently do not sell Personal Information to third parties within the meaning of the CCPA, and therefore do not offer this option. We may disclose Personal Information about you to our affiliates and service as permitted by law. Please see “Our Collection, Use, and Disclosure of Personal Information” section of this Disclosure for more information.
• Right to opt-out of share –We currently do not sell or share Personal Information within the meaning of the CCPA, and therefore do not offer this option. We may disclose Personal Information about you to our affiliates and service as permitted by law. Please see “Our Collection, Use, and Disclosure of Personal Information” section of this Disclosure for more information.
• Right to correct – You have the right to correct certain Personal Information. There are many types of correction requests and our service areas are ready to assist you with your request.
• Right to deletion – Subject to certain conditions, you may be entitled to request that we delete Personal Information about you. Before deleting information, we must be able to verify your identity. We will not delete Personal Information about you when the information is required to fulfill a legal obligation, is necessary to exercise or defend legal claims, or where we are required or permitted to retain the information by law. For example, we cannot delete information about you while continuing to provide you with financial services or where required to be retained for regulatory purposes.

We do not discriminate against you if you choose to exercise these rights. Please see the “How to Make Requests” section below for details on how to exercise these rights. 

If you are a California resident, you may make a request to exercise the rights described above, or questions about this policy or our privacy practices, by contacting us at:

By telephone: 800-237-5822
By e-mail: PrivacyOfficeAB@alliancebernstein.com
By letter:
AllianceBernstein L.P.
Attn: Privacy Office
501 Commerce Street
Nashville, TN 37203

For some Personal Information requests, we may need to verify your identity before fulfilling your request. To verify your identity, we will collect information from you, including, to the extent applicable, your name, government identification number, date of birth, contact information, your account information, answers to security questions, or other personal identifying information. We will match this information against information we have previously collected about you or against information available from consumer reports to verify your identity and to respond to your request. Information collected for purposes of verifying your request will only be used for verification and to respond to your personal information request.

If you maintain an account with us, we may require you to login to that account as part of submitting your request. If we are unable to verify your identity as part of your request, we will not be able to satisfy your request. For deletion requests, you will be required to submit a verifiable request for deletion and then to confirm separately that you want Personal Information about you deleted. 

If you would like to appoint an authorized agent to make a request on your behalf, and that agent is not already authorized to access your account in your profile, we require you to verify your identity with us directly before we provide any requested information to your approved agent.

We may change or update this Disclosure from time to time. When we do, we will post the revised Disclosure on this page with a new "Last Updated" date.