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. 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 websites. 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:

• Identifiers, such as name, contact information, online identifiers, Social Security numbers and other government identification (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
• Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.

The purposes for which we use the Personal Information that we collect depend on our relationship or interaction with a specific California resident. Nonetheless, we may use Personal 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 Personal Information to personalize, develop and market our products and services to retail and institutional investors; 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.

In the past 12 months, we have disclosed the following categories of Personal Information relating to California residents to third parties for our business purposes:

• 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
• Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.

In the past 12 months, however, we have not “sold” Personal Information relating to California residents within the meaning of the CCPA. For purposes of this Disclosure, “sold” means the disclosure of Personal Information for monetary or other valuable consideration.

If you are a California resident, you may request that we disclose to you the following information covering the 12 months preceding your request:

1. The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
2. The business or commercial purpose for collecting Personal Information about you;
3. The categories of Personal Information about you that we disclosed to third parties for a business purpose and the categories of third parties to whom we disclosed such Personal Information (if applicable);
4. The specific pieces of Personal Information we collected about you.

If you are a California resident, you may also request that we delete Personal Information that we collected from you. In some instances, we may decline to honor your request where an exception applies, and where the disclosure of Personal Information would adversely affect the rights and freedoms of another consumer.

Nonetheless, you have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

If you are a California resident, you may make a request for the disclosures described above or make a request to delete Personal Information we collected from you by contacting us:

By telephone: 800-237-5822
By email: PrivacyOfficeAB@alliancebernstein.com
By letter:
AllianceBernstein L.P.
Attn: Privacy Office
1345 Avenue of the Americas
New York, NY 10105

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.