Candidate Privacy Notice
Effective Date: 01 October 2026
Fireblocks Global Candidate Privacy Notice
Fireblocks is committed to protecting the privacy and security of your personal data. This Privacy Notice explains how Fireblocks and its subsidiaries, affiliates, and related entities (“Fireblocks,” “we,” or “us”) collect, use, protect, share, and transfer personal data about job applicants during the recruitment process. It also explains your privacy rights and how you can exercise them. We will process your personal data only as described in this Privacy Notice, or where otherwise required by applicable law, and will ensure that any personal data we collect is relevant, proportionate, and used only for appropriate recruitment-related purposes.
Fireblocks Ltd. and the relevant Fireblocks entity responsible for the recruitment process are the controllers of your personal data for the purposes described in this Privacy Notice. If you have questions regarding this Notice or our processing activities, please contact [email protected].
For this Privacy Notice, personal data means any information relating to an identified or identifiable individual collected as part of the recruitment process. We may collect personal data directly from you or may receive it from third parties, for example, in connection with a background, employment, or reference check, subject to your consent, where required by law. Personal data does not include information that has been irreversibly anonymized so that it can no longer be used to identify an individual, directly or indirectly.
We may collect, store, and process the following categories of personal data, in connection with our recruiting activities:
- Personal contact details such as name, title, addresses, telephone numbers, personal email addresses and social media contact information.
- Work history and other relevant experience including information contained in a resume, CV, cover letter, or job application.
- Education information including degrees awarded, transcripts, and other information provided in support of the job application.
- Information collected during phone screenings and interviews, including notes and transcripts generated by AI-assisted notetaking tools used in virtual or recorded interview settings.
- Details regarding the type of employment sought, desired salary, willingness to relocate, job preferences, and other information related to compensation and benefits.
- Reference information and information received from background checks, where applicable, including information provided by third parties.
- Information related to previous applications to Fireblocks or previous employment history with Fireblocks.
- AI-generated scores, rankings, or assessments produced during initial application screening (see “Automated Processing and AI-Assisted Recruitment” below).
- Technical data collected automatically when you submit an application, including your IP address, device type, browser type and version, operating system, and related device identifiers. This data is collected for fraud prevention and security purposes (see “Use of Personal Data” below).
You are under no statutory or contractual obligation to provide data to Fireblocks during the recruitment process. However, if you do not provide the information, we may not be able to process your application.
We process your personal data for the purposes described below. Depending on the circumstances and your location, we rely on one or more legal bases under applicable data protection laws. Where we rely on our legitimate interests, we have assessed that the processing is necessary for the relevant purpose and that our interests are not overridden by your interests, rights, and freedoms.
| Purpose of Processing | Categories of Personal Data | Legal Basis (GDPR/UK GDPR where applicable) |
| Assessing your application, qualifications, skills, experience, and suitability for a role | Application materials, CV/resume, interview information, work history, education information | Legitimate interests in recruiting and selecting suitable candidates where applicable; taking steps at your request prior to entering an employment contract |
| Communicating with you regarding your application and the recruitment process | Contact details and application information | Legitimate interests where applicable, taking steps prior to entering an employment contract |
| Conducting interviews and maintaining recruitment records | Interview notes, interview transcripts, recruiter assessments, application records | Legitimate interests in administering and documenting the recruitment process |
| Using AI-assisted tools to support candidate screening, application review, and recruitment administration | CV/resume information, application responses, qualifications, experience, interview information | Legitimate interests in efficiently managing recruitment and identifying candidates whose qualifications align with role requirements |
| Verifying information and conducting reference, employment, background, right-to-work, or eligibility checks | Identification information, employment history, reference information, screening results | Legitimate interests; compliance with legal obligations where applicable; consent where required by law |
| Complying with employment, immigration, regulatory, tax, and legal requirements | Identification information, nationality, right-to-work documentation, and related information | Compliance with legal obligations |
| Detecting and preventing fraud, abuse, unauthorized activity, and security incidents | IP address, device information, browser information, technical identifiers, and application activity data | Legitimate interests in protecting the security, integrity, and reliability of our recruitment process |
| Improving recruitment processes, systems, and candidate experience | Recruitment metrics, application data, feedback, and analytics | Legitimate interests in improving recruitment effectiveness and operational efficiency |
| Establishing, exercising, or defending legal claims and maintaining appropriate records | Any information relevant to the claim or legal obligation | Legitimate interests; compliance with legal obligations |
Fraud Prevention and Security
We process certain technical information, including IP addresses, device-related information, browser information, and other technical identifiers submitted when you apply, to detect and prevent fraudulent, abusive, or unauthorised activity in connection with the recruitment process and to protect the security and integrity of our systems.
To support these efforts, we use third-party fraud detection service providers acting as our processors. These providers analyse technical signals, including IP reputation and device-related information, on our behalf for fraud prevention and security purposes.
The legal bases applicable to this processing are described in the table above. Where we rely on legitimate interests, those interests include protecting the security, integrity, and reliability of our recruitment process and systems.
We will process special category or other sensitive personal data only where permitted by applicable law. Depending on your location and applicable law, this may include processing that is necessary to comply with employment-related obligations, assess your fitness or eligibility for employment, monitor equal opportunity commitments, establish, exercise or defend legal claims, protect important public interests, or where you have provided your explicit consent where required.
We may process sensitive personal information for the following purposes:
- To determine whether reasonable accommodations or adjustments are required during the recruitment process, for example during an assessment, test, or interview.
- To assess your eligibility to work and determine whether a work permit, visa, or other employment authorization is required for the role.
- To monitor equal opportunity commitments and evaluate the effectiveness of our recruitment processes. Providing diversity and inclusion information is voluntary and will not affect your application, recruitment assessment, or hiring outcome. Where practicable, this information will be aggregated, anonymized, or otherwise separated from recruitment decision-making processes.
- Where permitted by applicable law and relevant to the position, to conduct background screening, including processing information relating to criminal convictions where necessary to assess suitability for employment or to comply with legal, regulatory, contractual, or industry requirements applicable to the role.
Fireblocks uses AI-powered tools and automated processing at certain stages of the recruitment process. This section explains how those tools operate, what data they process, and your rights in connection with their use.
AI-Assisted Application Screening
We use AI-enabled tools, including functionality within our applicant tracking system, to assist with the initial review and screening of job applications. These tools may automatically analyse the information you submit in your application, such as your CV, cover letter, and responses to screening questions, and generate a score, ranking, or recommendation that reflects your apparent suitability for a given role. This process is used to assist our recruiters in managing high volumes of applications efficiently and consistently.
AI-Assisted Interview Notetaking
We use AI-powered notetaking tools in connection with virtual or recorded interviews. These tools may automatically transcribe the conversation and generate a summary or structured notes to assist our recruiters and hiring managers. Where interviews are recorded or transcribed using such tools, you will be informed at the outset of the interview. Transcripts and AI-generated summaries are treated as personal data and handled in accordance with this Privacy Notice.
How AI-Assisted Screening Works
The AI screening tools we use may compare information you submit against criteria relevant to the role, such as qualifications, skills, and experience. This may result in your application being assigned a score, ranking, or recommendation to assist recruiters in reviewing applications. These outputs are used as one input into the recruitment process and are not the sole or determinative basis for any hiring decision.
Human Review
Final decisions regarding your application, including whether to progress your candidacy, invite you to interview, or make you an offer of employment, are made by human reviewers. AI-generated scores, rankings, recommendations, summaries, and other outputs are reviewed by members of our recruitment team and are not used as the sole basis for hiring decisions. You will not be subject to a hiring decision based solely on automated processing that produces legal or similarly significant effects concerning you.
Where required by applicable law, you may have the right to request human review of certain automated processing activities, express your point of view, or object to such processing. To exercise these rights, please contact us at [email protected].
Legal Basis
The legal bases applicable to AI-assisted recruitment activities are described in the table above. We implement appropriate safeguards to ensure that AI-assisted tools support, rather than replace, human decision-making during the recruitment process.
We will only disclose your personal data to third parties where required by law or to our employees, contractors, designated agents, or third-party service providers who require such information to assist us with administering the recruitment process. We may use third-party service providers for various purposes, including but not limited to obtaining employment verification and background checks, and data storage or hosting. These third-party service providers may be located outside of the country in which you live or the country where the position you have applied for is located.
Categories of third-party processors we engage in connection with the recruitment process include:
- Applicant tracking system (ATS) providers – technology providers whose platforms manage application collection, candidate communications, interview scheduling, and AI-assisted screening, acting as data processors on our behalf subject to a data processing agreement.
- AI-assisted interview notetaking providers – technology providers that deliver automated transcription and interview summary services for virtual or recorded recruitment interviews, acting as data processors subject to appropriate contractual safeguards.
- Background check and reference providers – third-party services used to verify employment history and conduct pre-employment screening, subject to your consent where required by applicable law.
- Fraud detection and IP reputation providers – technology providers that analyse IP address and device data submitted at the point of application for the purpose of detecting and preventing fraudulent or abusive activity in connection with the recruitment process, acting as data processors subject to a data processing agreement.
We require all our third-party service providers, by written contract, to implement appropriate security measures to protect your personal data consistent with our policies and any data security obligations applicable to us. We do not permit our third-party service providers to process your personal data for their own purposes. We only permit them to process your personal data for specified purposes in accordance with our instructions.
We may also disclose your personal data for the following additional purposes where permitted or required by applicable law:
- To other members of our group of companies (including outside of your home jurisdiction) for the purposes set out in this Privacy Notice and as necessary to administer the application and recruitment process.
- As part of our regular reporting activities to other members of our group of companies.
- To comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we disclose your personal data to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum personal data necessary for the specific purpose and circumstances.
- To protect the rights and property of Fireblocks.
- During emergency situations or where necessary to protect the safety of persons.
- Where the personal data is publicly available.
- If a business transfer or change in ownership occurs and the disclosure is necessary to complete the transaction. In these circumstances, we will limit data sharing to what is absolutely necessary, and we will anonymize the data where possible.
- For additional purposes with your consent where such consent is required by law.
Where permitted by applicable law, we may transfer the personal data we collect about you to other jurisdictions that may not be deemed to provide the same level of data protection as your home country for the purposes set out in this Privacy Notice. When this happens, we ensure that appropriate safeguards are put in place, such as:
- Standard Contractual Clauses (SCCs) approved by the European Commission, or the UK International Data Transfer Addendum (IDTA) issued by the UK Information Commissioner’s Office, for transfers from the EEA or UK respectively;
- The EU–US Data Privacy Framework (DPF), the UK Extension thereto, or the Swiss–US Data Privacy Framework, where applicable;
- Other transfer mechanisms recognised as lawful under applicable data protection legislation.
Where we transfer personal data to third-party processors located outside of the EEA, UK, or other jurisdictions with adequacy determinations, we rely on appropriate safeguards as described above.
We have implemented appropriate physical, technical, and organizational security measures designed to secure your personal data against accidental loss and unauthorized access, use, alteration, or disclosure. In addition, we limit access to personal data to those employees, agents, contractors, and other third parties that have a legitimate business need for such access.
We retain your personal data only for as long as necessary to fulfil the purposes described in this Privacy Notice, comply with legal or regulatory obligations, resolve disputes, and establish, exercise, or defend legal claims.
If your application is unsuccessful, we generally retain your application information and related recruitment records for up to 12 months following the conclusion of the recruitment process, unless a longer retention period is required or permitted by applicable law.
If you are offered and accept employment with Fireblocks, the personal data collected during the recruitment process will become part of your employment record and will be retained and processed in accordance with our employee privacy notice and applicable records retention practices.
Where permitted by applicable law, we may anonymize personal data so that it can no longer be associated with you. Once anonymized, the information is no longer considered personal data and may be used for legitimate business purposes, including analytics, reporting, and improving our recruitment processes.
It is important that the personal data we hold about you is accurate and up to date. Please let us know if your personal data changes during the recruitment process.
Depending on your location and applicable law, you may have one or more of the following rights in relation to your personal data:
- Right of access – to request confirmation of whether we process your personal data and to obtain a copy of the personal data we hold about you.
- Right to rectification – to request that we correct or update inaccurate or incomplete personal data.
- Right to erasure – to request deletion of your personal data where there is no lawful basis for us to continue processing it.
- Right to restrict processing – to request that we temporarily limit how we use your personal data in certain circumstances.
- Right to object – to object to processing based on our legitimate interests where permitted by applicable law.
- Right to data portability – to request a copy of certain personal data in a structured, commonly used, machine-readable format and, where technically feasible, to have that information transferred to another organization.
- Rights relating to automated decision-making – where required by applicable law, you may have the right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects concerning you, and to request human review where applicable. Please see the AI-Assisted Recruitment section above for further information.
- Right to withdraw consent – where we rely on your consent to process your personal data, you may withdraw that consent at any time. This will not affect the lawfulness of any processing carried out before your consent was withdrawn.
- Right to lodge a complaint – where applicable, you have the right to lodge a complaint with your local data protection authority or other competent regulator if you believe your personal data has been processed unlawfully.
Additional Rights for Certain US Residents
Residents of certain US states, including California, may have additional privacy rights under applicable state law, including:
- Right to opt out of the sale or sharing of personal information for cross-context behavioural advertising. Fireblocks does not sell or share candidate personal data for these purposes.
- Right to non-discrimination for exercising your privacy rights.
- Right to appeal our decision regarding a privacy rights request, where provided under applicable state law.
Exercising Your Rights
To exercise any of these rights, please contact us at [email protected].
We may ask you for additional information to verify your identity before responding to your request. In certain circumstances, applicable law may permit or require us to refuse or limit a request. Where this applies, we will explain the reasons unless we are legally prevented from doing so.
We reserve the right to update this Privacy Notice at any time, and we will provide you with a new Privacy Notice when we make any updates. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose. We may process your personal data without your knowledge or consent only where required by applicable law or regulation.
If you have any questions about our processing of your personal data, wish to exercise any of your rights, or would like to make an access or other request, please contact us at: [email protected].
If you are unsatisfied with our response to any issues that you raise, you may have the right to make a complaint with the data protection authority in your jurisdiction. EEA-based individuals may contact their national supervisory authority; UK-based individuals may contact the Information Commissioner’s Office (ICO) at www.ico.org.uk; individuals in other jurisdictions should contact the relevant authority in their country.