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Effective Date: January 2023 Candidate Privacy Notice

I. SCOPE AND OVERVIEW

Fireblocks is committed to protecting the privacy and security of your personal data. This Privacy Notice describes how Fireblocks and its subsidiaries, affiliates, and related entities (collectively, “Fireblocks,” “we,” or “us“) collect and process personal data about you during the application and recruitment process. This Privacy Notice applies to job applicants only.

This Privacy Notice describes the categories of personal data that we collect, how we use your personal data, how we secure your personal data, when we may disclose your personal data to third parties, and when we may transfer your personal data outside of your home jurisdiction. This Privacy Notice also describes your rights regarding the personal data that we hold about you, including how you can access, correct, and request erasure of your personal data.

We will only process your personal data in accordance with this Privacy Notice unless otherwise required by applicable law. We take steps to ensure that the personal data that we collect about you is adequate, relevant, not excessive, and processed for limited purposes.

II. COLLECTION OF PERSONAL DATA

For the purposes of this Privacy Notice, personal data means any information about an identifiable individual collected in connection with the recruitment process. Fireblocks may collect personal data directly from you, as a job applicant, or may receive personal data from third parties, for example, in connection with a background, employment, or reference check, subject to your consent where required by law. Personal data excludes anonymous or de-identified data that is not associated with a particular individual.

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.
  • 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.

III. WHAT IF YOU DO NOT PROVIDE PERSONAL DATA?

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.

IV. USE OF PERSONAL DATA

We only process your personal data:

  • where applicable law permits or requires it in connection with carrying out our application and recruitment process,
  • to take steps necessary to enter into an employment contract with you,
  • where the processing is necessary to comply with a legal obligation that applies to us,
  • for our legitimate interests or the legitimate interests of third parties, or
  • with your consent if applicable law requires consent.

We may process your personal data for the following legitimate business purposes:

  • Identifying and evaluating job applicants, including assessing skills, qualifications, and interests for the purposes of determining suitability for the position for which you have applied.
  • Verifying your information and carrying out employment, background, and reference checks, where applicable, subject to your consent where required by applicable law.
  • Communicating with you about the recruitment process and your application.
  • Keeping records related to our hiring processes, for only as long as appropriate under the circumstances.
  • Creating and submitting reports as required by applicable laws or regulations.
  • To comply with our legal, regulatory, or other corporate governance requirements.
  • Analyzing and improving our application and recruitment process.

We will only process your personal data for the purposes we collected it for or for compatible purposes. If we need to process your personal data for an incompatible purpose, we will provide notice to you and, if required by law, seek your consent. We may process your personal data without your knowledge or consent only where required by applicable law or regulation.

You will not be subject to hiring decisions based solely on automated data processing.

V. HOW DO WE USE SENSITIVE PERSONAL INFORMATION?

We will use your sensitive personal data only in so far as we are permitted by Law to do so. Where applicable,

  • We will use data about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.
  • We will use data about your nationality or ethnicity, to assess whether a work permit and a visa will be necessary for the role.
  • We will use diversity and inclusion information to assist us with anonymised equal opportunities monitoring to evaluate the effectiveness of our recruitment process. If you choose to provide this information, it will not be used in the recruitment and selection process.
  • We will use information about criminal convictions to decide whether to proceed with your application or offer of employment (where applicable to the job role). This information may be required to fulfil regulatory obligations.

VI. DATA SHARING

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, including third-party service providers who provide services to us or on our behalf. 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.

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.

VII. CROSS-BORDER DATA TRANSFERS

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 approved by the European Commission or UK regulator.

VIII. DATA SECURITY

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.

IX. DATA RETENTION

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting requirements, or as necessary to resolve disputes. To determine the appropriate retention period for personal data, we consider our statutory obligations, the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes we process your personal data for, and whether we can achieve those purposes through other means. We specify the retention periods for your personal data in our data retention policy.

Under some circumstances we may anonymize your personal data so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

If you are offered and accept employment with Fireblocks, the personal data we collected during the application and recruitment process will become part of your employment record, and we may use it in connection with your employment consistent with our employee personal data policies. If you do not become an employee, or, once you are no longer an employee of Fireblocks, we will retain and securely destroy your personal data in accordance with our document retention policy and applicable laws and regulations.

X. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND OBJECTION

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during the recruitment process. By law you may have the right to request access to, correct, and erase the personal data that we hold about you, or object to the processing of your personal data under certain circumstances. You may also have the right to request that we transfer your personal data to another party. If you wish to exercise any of these rights, please contact us at [email protected].

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal data that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal data that we hold about you, or we may have destroyed, erased, or anonymized your personal data in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal data, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

XI. RIGHT TO WITHDRAW CONSENT

Where you have provided your consent to the collection, processing, and transfer of your personal data, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at [email protected].

XII. CHANGES TO THIS PRIVACY NOTICE

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.

XIII. CONTACT US

If you have any questions about our processing of your personal data 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 by contacting the data protection authority.