Date Last Updated: December 7, 2023

Under the California Consumer Privacy Act (“CCPA”), as amended and expanded by the California Privacy Rights Act, California residents may have certain privacy rights depending upon the nature of their relationship with Equitable. This Notice to California Residents (“California Privacy Policy”) describes those rights and how they may be exercised. It also provides information regarding the categories of personal information and sensitive personal information (collectively, “personal information”) that Equitable collects and how it is used and disclosed.

The CCPA provides certain exemptions with respect to the personal information that Equitable collects that is regulated by certain other state and federal laws. With respect to such personal information, you may not have any or all of the rights listed below. 

For purposes of this California Privacy Policy, “Equitable” means Equitable Holdings, Inc. and its subsidiaries, excluding AllianceBernstein Holding, L.P., AllianceBernstein L.P., and their subsidiaries. For information regarding AllianceBernstein’s privacy policy and practices, please visit alliancebernstein.com.

We do not sell or share your personal information

Equitable does not sell or share your personal information, as such terms are defined under the CCPA. This includes the personal information of persons under the age of 16. However, as described below, we may share personal information with third parties as directed or consented to by you or your employers or plan sponsors, as necessary for you to receive the benefit of such third party’s services.

What personal information we collect and disclose

We collect personal information from the following sources, in addition to directly from you:

• From employers and plan sponsors
• Payment processors and financial institutions
• Public records
• Vendors and service providers
• Government agencies and self-regulatory organizations
• Policyholders and other customers
• Beneficiaries and other persons associated with an insurance policy, annuity, or financial product or service
• Financial professionals and third-party agents and brokers
• Medical professionals and paramedical professionals

We may disclose personal information that we collect about you to the following categories of third parties:

• Third parties to whom you request we disclose your information
• Beneficiaries and other persons associated with an insurance policy, annuity, or financial product or service
• Service providers, vendors, and reinsurers
• Credit reporting agencies
• Government agencies, self-regulatory organizations, and other third parties as required by law
• Employers and plan sponsors
• Financial professionals and third-party agents and brokers

Within the past 12 months, Equitable has collected and disclosed the below categories of personal information and sensitive personal information relating to California residents. Please note that not every category of personal information or sensitive personal information is collected about each consumer or in connection with each transaction, product, or service. In the past 12 months, Equitable has not sold or shared personal information, as such terms are defined under the CCPA.

Sensitive Personal Information. We collect certain categories of personal information that are considered “sensitive personal information” under California law. We collect the following sensitive personal information data identifiers primarily for the purposes of providing services to our clients, employees and financial professionals, maintaining the security of our systems, and as permitted by California law: (i) your Social Security, driver’s license, state identification, or passport number; (ii) your log-in information, financial account, debit card, or credit card number, in combination with any required security access code, password, or credentials allowing access to an account; (iii) your precise geolocation data; (iv) your racial or ethnic origin, religious or philosophical beliefs, or union membership; (v) your genetic data; (vi) your biometric information for unique identification; and (vii) your information collected and analyzed regarding your health, including (viii) information regarding sexual life or orientation. We may also receive certain communications, including your mail, email and text message communications. To the extent that they are forwarded to us by third parties, such communications may be unrelated to the provision of services to our clients, employees and financial professionals.

The purposes for which we use personal information

We collect personal information to develop, provide, and offer retirement and other financial products, life insurance products, and related services to our existing and potential clients, and as otherwise required by law or regulations. The following are business purposes for which Equitable uses the personal information that it collects:

• For our everyday business purposes, and those of your financial professional — such as processing your transactions, providing services that you request, billing and processing of payments, maintaining your account(s), providing customer service, underwriting and related activities, responding to court orders and legal investigations, or reporting to credit bureaus
• For our marketing purposes — to offer our products and services to you and to identify potential new clients
• For developing new products and services and to improve existing products and services
• For security purposes – to protect your account(s) and prevent, detect, and respond to illegal activity and security incidents
• For debugging and analytics purposes – to improve our websites and IT infrastructure and analyze web traffic and consumer interactions and activity on our websites and customer portals
• For recruiting purposes – to identify potential job candidates

How We Retain Your Personal Information

Equitable strives to limit the personal information it collects to those categories necessary to accomplish the specific business purpose for which it is being collected. As a result, how long we retain personal information depends upon the purpose for which it was collected. Equitable retains personal information for as long as legally and operationally required based on applicable legal and regulatory requirements and the administrative and operational requirements of Equitable’s businesses. As a general matter, if you are a client of Equitable, we may retain your personal information for the duration of your client relationship with us, plus any additional periods required to (i) fully administer or service any product(s) (for example, as necessary to pay any death benefit to your beneficiaries under a life insurance policy) and/or (ii) comply with applicable legal or regulatory requirements. If you are a current or former employee or financial professional, we may retain your personal information for the duration of your affiliation with Equitable, plus any additional periods required to (i) administer any benefits following the end of your affiliation with us and/or (ii) comply with applicable legal or regulatory requirements.

California Consumer Rights

The CCPA provides California residents with right to receive certain disclosures regarding the collection, use, and sharing of their personal information, and the right to know, delete, correct, and limit sharing of personal information. To the extent that we collect personal information that does not fall under an enumerated exemption to the CCPA, your rights as a California resident are set forth below. In responding to a rights request, we will let you know if we comply with or deny the request. If we deny your request, in whole or in part, we will explain the basis for the denial.

Right to Know

You have the right to request information regarding the personal information that Equitable has collected about you, including the categories of personal information collected, the categories of sources from which the personal information is collected, the business purpose for which the personal information was collected, and the categories of third parties to whom we disclose personal information. You also have a right to request the specific pieces of personal information we have collected about you.

Right to Delete

You have the right to request that we delete any of your personal information that was collected by Equitable directly from you. Please note that Equitable is generally unable to honor a request to delete the following:

• Personal information that is necessary to complete a transaction or provide a service that you requested;
• Personal information that was collected from a source other than directly from you;
• Personal information that is necessary to prevent, detect, and respond to fraudulent or illegal activity and other security incidents;
• Personal information that is necessary to exercise free speech or another right provided for by law;
• Personal information used to debug, identify or repair errors that impair existing intended functionality; or
• Personal information that is necessary to meet a legal obligation

Right to Correct

You have the right to request that we correct any inaccurate personal information that we maintain about you. 

Right to limit the use and disclosure of sensitive personal information

You have the right to request that we limit the use and disclosure of your sensitive personal information to that use which is necessary to provide you with products and services you have requested, and for certain other limited purposes as provided for under the CCPA.

Right to know about and opt-out of sale or sharing of personal information

Equitable does not sell or share your personal information, as those terms are defined under the CCPA.

Right to Non-Discrimination

Equitable will not discriminate against you for exercising your privacy rights under the CCPA.

Exercising your California consumer rights and our contact information

Equitable will take steps to verify your identity before processing your request to know, correct, or delete your personal information. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the individual about whom we collected personal information. If you have an account with us, we will use our existing account authentication practices to verify your request. If you do not have an account with us, we may request additional information about you. We will only use the personal information provided by you in the verification process to verify your identity or authority to make a request and to track and document request responses, unless you initially provided the information for another purpose. You may use an authorized agent to submit a request to know or a request to delete. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your personal information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf.

Please contact us with any questions or concerns regarding this California Privacy Policy or to exercise a right under the CCPA by either visiting our California Information Request Portal or by calling toll-free (877) 806-4573.