Introduction
AllianceBernstein Investment Management Limited, AllianceBernstein L.P 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.
At AB, protecting the privacy and confidentiality of your personal information is a priority. We understand that any personal information provided through the course of business is entrusted with us. This Privacy Policy sets forth details on how we collect, hold, use, disclose and safeguard your personal information and privacy.
AB Privacy Policy
This privacy notice was last updated on March 31, 2023.
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 personal information. This notice describes the privacy practices of AB globally and aims to provide transparent information, in accordance with privacy laws.
The following describes information we collect about you, those with whom we share your information, how we safeguard your information, and how you can contact us regarding our privacy notice and practices or how to exercise your rights. AB does not sell your personal information.
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.
Current, former and prospective investors may also receive a privacy notice as part of their investment document, and, in those cases, that specific notice will control this general notice. This Policy Notice generally applies equally to all investors, although certain sections include disclosures intended for investors in certain jurisdictions (e.g., those in the European Union, California, Canada or the Cayman Islands). If you are a current, former, or prospective employee or contractor of AB, the privacy policy applicable to you will be provided as part of the relevant employment documentation.
Security and Safeguarding of Personal Information
We have policies and procedures reasonably designed to safeguard the confidentiality and security of personal information; this includes restricting access to nonpublic personal information to properly authorized persons and maintaining generally accepted physical, electronic, and procedural safeguards. Despite these efforts, 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:
- Information we receive through account 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;
- Information about transactions with us, our affiliates and nonaffiliated third parties (as further detailed below), which can include account balances and transaction history;
- Communications with AB, including, but not limited to, telephone calls and emails to provide you with requested products and services;
- Information from publicly or commercially available sources, such as your name, address, email address, interests, and demographic/profile data;
- Images of visitors to our offices from closed-circuit television footage; and
- 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, as well as data from other websites and services that aggregate publicly available information. Our cookie policy can be found here. We do not currently use technology that recognizes “Do Not Track” signals from web browsers.
The information we collect from these various sources may be used along with the information we collect from you directly or from your visits to AB’s sites.
How We Use Personal Information
We use the information we collect from you as necessary or appropriate and in proportion to our business purposes, including to:
- Fulfill contractual obligations
- Open and administer accounts
- Register users and provide access to the website or services requested
- Respond to inquiries or requests directed to us
- Fulfill requests for products or services
- Perform internal analyses, analytics, and research and development to improve and add to our product offerings and to further inform our outreach to market segments
- 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 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 and best practices
- Investigate and assert our legal rights
- Work in connection with corporate transactions such as the sale, reorganization, or liquidation of assets or corporate entities
- 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: (i) the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract to provide services you request; (ii) for business and 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 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 nonaffiliated 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 or otherwise deem it appropriate to disclose or share your information to comply with any legal or regulatory obligations; to investigate, establish, enforce, apply or fulfill 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 (e.g., processing centers, facilities for the 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; we remain responsible for the protection of your information.
Please contact AB if you would like additional information about the third parties used to fulfill our contractual obligations.
For Marketing:
We do not sell personal information or otherwise transfer personal data to unaffiliated third parties for their own purposes. We may 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. To opt out of sharing or to alter your preferences regarding other marketing efforts, please speak with your account representative or an AB service person, as applicable, using the contact information below.
To be removed from our email distribution lists, simply unsubscribe. Please allow us at least ten (10) business days from when the request was received to complete the removal.
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.
Notice to Residents of California
If you are a California resident, as defined in the California Code of Regulations, you have rights under the California Consumer Privacy Act of 2018, as amended, which can be found here.
Transfer of Personal Information Outside of the UK, The European Economic Area (EEA) & Switzerland
For the abovementioned purposes, the personal information listed in this notice may be transferred to our affiliates or nonaffiliated third parties established in countries outside of the UK, EEA, and Switzerland, which do not offer the same level of protection for personal data.
We will take reasonably necessary steps, including the use of the Model Contractual Arrangements as approved by the relevant UK or EU authorities (as appropriate), or other contractual means to ensure that your information is treated securely and in accordance with this notice, the EU General Data Protection Regulation, the UK Data Protection Act, and other applicable privacy rules.
AB transfers of personal data from the UK, EEA and Switzerland are conducted in accordance with Model Contractual Clauses approved by the relevant UK and 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 Swiss-EU Privacy Shield certified, where applicable, or agreeing to the terms of an appropriate non-disclosure agreement or a data transfer agreement.
Your Rights
The following rights apply if you reside in the UK, EEA or Switzerland. Individuals in Andorra, Argentina, Australia, California, Canada, the Cayman Islands, the Faroe Islands, Guernsey, Hong Kong, the Isle of Man, Israel, Japan, Jersey, Mexico, New Zealand, Singapore, South Korea, Switzerland, Uruguay and certain other jurisdictions may have certain data subject rights. 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. You may appoint an agent to make a request on your behalf, but we may then still need to verify your identity and the legality of the agent’s appointment and attempted actions.
Accessing, Correcting or Erasing Your Information
You may 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 you erased or provided to you.
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 the 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. 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 may have the right to receive the information that you have provided to AB in a structured, commonly used and machine-readable format; and you 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 and respond without undue delay and, in any event, within one month of receiving a request to exercise the rights above. AB will treat requests to access information or change information in accordance with applicable legal requirements, and we do not discriminate or retaliate against anyone for the exercise of any privacy rights.
Enforcement and Complaints
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 on data-protection principles.
Raising Complaints, Questions or Concerns with AB
Any questions, concerns or complaints regarding this notice or our treatment of your information may be directed to us, using the contact information below.
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.
If You are Located in the DIFC
AllianceBernstein Limited is providing the following information for individuals whose personal information is collected or held by AllianceBernstein (DIFC) Limited, which is the controller of personal information and so is responsible for this privacy notice. Where you are such an individual:
- AllianceBernstein (DIFC) Limited is registered in the Dubai International Finance Centre (DIFC) with the DIFC-registered number 6639 and with its registered office at Office 29, Level 15, The Gate Bldg., East Wing, DIFC, Dubai, UAE.
- The processing of your personal data by AllianceBernstein (DIFC) Limited is governed by the DIFC Data Protection Law, No. 5 of 2020.
- It is likely that personal information about you will be collected, held, and transferred outside of the DIFC, including in and to countries within the UK or the EEA. It may also be disclosed to persons in other countries in the circumstances described in this privacy notice.
- We will take all reasonable legal, technical, and organizational measures to ensure that if your personal information is transferred outside of the DIFC, it will be treated securely and with an adequate level of protection comparable to the level of protection offered in the DIFC. In particular, transfers of personal data outside of the DIFC will take place only where the transfer of this information is subject to a written agreement in line with the requirements of the DIFC data-protection law.
- You have the right to make a complaint to the Commissioner of Data Protection in the DIFC (Commissioner) at any time (Tel: +971 [0]4 362 2222 or at commissioner@dp.difc.ae).
- We would, however, appreciate the chance to deal with your concerns before you approach the Commissioner, so please contact us at the first instance at privacy@alliancebernstein.com.
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 by sending a copy through the mail, sending you an email or posting a banner notice on our corporate website.
Australian Premises – CCTV
Our Australian offices have closed circuit televisions (“CCTV”). As a result, your image may be captured if you visit one of our Australian premises. The CCTVs are used as a deterrent to verify identity to support access control data by remote staff within the AB group, to facilitate investigations and to assist the AB group to remotely manage vendors from a distance. The CCTVs do not record personal workspace or audio information. Footage is recorded locally within Australia and stored for 30 days and it is only ever retrieved and reviewed in the event of an incident related to the above listed purposes. The footage is overwritten every 30 days and no copies are retained after that period.
Privacy Complaints and Breaches
Despite our best efforts, client complaints may occasionally arise, and they will be handled in a prompt, thorough and professional manner. We have established procedures for dealing with complaints, including any complaints which may relate to privacy or handling of personal information.
AB is committed to a culture in which complaints are acknowledged, addressed and handled in line with industry best practices. Effective complaints management can enhance customer satisfaction by creating a customer focused environment that is open to feedback and continuous improvement thereby enhancing AB’s delivery of financial services.
Privacy Complaints which constitute Errors are to be handled in accordance with the AB Statement of Policy and Procedures on Error Reporting and Escalation. This includes a review to determine whether a breach of privacy practices or the Australian Privacy Principles or relevant laws may have occurred. In such circumstances where a determination has been made that a breach has transpired, it will be handled in accordance with AB’s Error and Breach reporting practices and include notifications to required parties.
Our Complaints Policy is available here and our Complaints Officer may be contacted at the following:
Complaints Officer
AB
Level 32, Aurora Place
88 Phillip Street
Sydney NSW 2000
Phone: 02 9255 1200
Fax: 02 9247 9445
Email: ComplaintsAustralia@alliancebernstein.com
