Chainalysis Applicant Privacy Policy

Last updated: July 21, 2022


About this privacy policy

In this Applicant Privacy Policy (“Policy”), we outline how we collect, use, and disclose Personal Data in connection with our recruitment and hiring efforts, as well as separate rights our job applicants may have with respect to such information. If you are a job applicant, we recommend that you periodically read this Policy in full to ensure you are fully informed about our handling of your Personal Data. This Policy is not a contract and does not create any legal rights or obligations not otherwise provided by applicable law.

We may choose or be required by law to provide different or additional disclosures relating to the processing of Personal Data about residents of certain countries, regions, or states, such as the European Economic Area (EEA) or the State of California. Where we provide jurisdiction-specific disclosures in this Policy, we will identify the jurisdiction to which they apply. Please note that references in this Policy to the EU General Data Protection Regulation (GDPR) are aimed at EEA citizens only, and references to the United Kingdom (UK) GDPR are aimed at UK citizens only. For the avoidance of doubt, neither the GDPR nor the UK GDPR applies if you are based elsewhere in the world.

When we use the words “you”, “your” or “yours”, we mean employment candidates of Chainalysis or its affiliates, and when we use the words “we”, “us” or “our”, we are referring to Chainalysis and its affiliates.


What do we mean by “Personal Data”?

This Policy relates only to Personal Data, and not to any data we have collected that is anonymous or aggregated. As defined in this Policy, “Personal Data” does not include anonymized information or aggregated data or any data that does not relate to an identified or identifiable natural person.


What information does Chainalysis collect about you?

Chainalysis collects a variety of personal information about you to support the recruiting and hiring process, conduct our businesses, and comply with relevant legal obligations (“Personal Data”). Such information generally includes, but is not limited to the following (although some may not apply to you specifically):

  • Your name and other identifying data or documents;
  • Your address and other contact details;
  • Your qualifications, skills, experience, work preferences, and employment history;
  • Information and notes from interviews and assessments;
  • Information about your current level of remuneration, including benefit entitlements; and
  • Information about your eligibility to work in the region of the position to which you are applying.

We also collect optional data to support our Diversity and Inclusion efforts, which may include information about your ethnic origin, sexual orientation, disability, medical condition, and religion or belief. As you progress through the recruitment process, we may collect additional information related to any background checks.

You are under no statutory or contractual obligation to provide Personal Data to Chainalysis during the recruitment process. However, if you do not provide information, depending on the circumstances we may not be able to proceed with your application.


How do we collect this information?

Oftentimes, we obtain it directly from you, the job applicant – for example, in application forms or resumes that you submit to us. We also create Personal Data about you during the application process, such as through interviews or other methods of assessment. In addition, we collect Personal Data about you from third parties, such as references supplied by former employers or when working with recruiting agencies.


Why do we process your personal data?

We process your Personal Data in order to run our recruitment and hiring process, maintain records, and other related purposes including, but not limited to, the following:

  • Managing your job application;
  • Conducting assessments, including processing feedback;
  • Administering the interview process, including travel and expense reporting;
  • Conducting background checks and screening; and
  • Verifying eligibility to work

We will also process your Personal Data for recordkeeping and internal and external reporting purposes. If necessary, your data may be used in investigations and legal proceedings.


Who has access to your personal data?

Your Personal Data will be shared internally within the Chainalysis corporate group for the purposes described in this Policy. Recipients include members of our Talent Acquisition and People teams, interviewers involved in the recruitment process, and business managers.

In addition, we use third-party service providers and vendors to help support our recruiting and hiring functions, which process your Personal Data on Chainalysis’ behalf. Where relevant, we will share your personal data with other kinds of third parties, which separately determine the purposes and means of processing your Personal Data.

In addition to those described above, we disclose Personal Data to third parties such as legal advisors and law enforcement, to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such Personal Data if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our agreement for services, or as otherwise required by law.


Does Chainalysis transfer your Personal Data to countries outside of your own?

Under some circumstances, for example, when we need to rely on the support of personnel or service providers located in other countries, we will transfer your Personal Data to countries outside of the one where you are based or where you are applying.

Chainalysis only transfers Personal Data to countries outside the UK and EEA if that country has an adequate level of protection according to the EU or EU Commission or the UK Government, if this is specifically done on the basis of your consent when you provide your Personal Data to us, or where we rely on a mechanism for protecting your Personal Data as provided for in the UK GDPR and GDPR. For example, we may rely on the standard contractual clauses published by the European Commission and similar measures under UK laws when we share your Personal Data within the different Chainalysis group entities.


How do we protect your data?

Chainalysis takes security of your Personal Data seriously. We have internal policies and controls in place to help protect your data against unlawful or unauthorized access and accidental loss or deletion.


How long do we keep your data?

If your application for employment is unsuccessful, we will retain your Personal Data for as long as reasonably necessary to comply with our legal obligations, resolve disputes, enforce our contractual agreements, or pursue legitimate interests such as considering you for other employment opportunities at Chainalysis.

If your application for employment is successful, Personal Data gathered during the recruitment process will be transferred to your personnel file and retained in accordance with our employee data retention policies.


What are your rights under applicable data protection laws?

If you are based in California, the European Economic Area (EEA), or the United Kingdom (UK), please see the section entitled “Your Rights” in the Chainalysis Privacy Policy for more information. Otherwise, see below:

Applicants may access or delete the Personal Data they have provided to Chainalysis by contacting us at [email protected]. Where consent is the legal basis we rely on to process your Personal Data, you can revoke your consent at any time, subject to applicable laws. To do this, please contact us using the contact details below, giving us enough information to identify you and the relevant data and also verify proof of your identity. We will let you know if we can comply with this request, and the applicable timeframe for doing so.


Our legal basis for processing Personal Data

When you apply to a job with Chainalysis, the personal data contained within your application will be processed by Chainalysis during the recruitment process and for keeping records of the process.

Processing personal data from applicants allows Chainalysis to assess a candidate’s suitability for employment and make decisions on job offers. This includes complying with legal obligations such as verifying eligibility to work before employment starts.

For people based in the UK and/or EEA only, when we use your Personal Data, under the UK GDPR and the GDPR, we are required to have a legal basis for doing so. Here, we set out the various legal bases on which we may rely in the recruiting and hiring context:

  • consent: where you have given us clear consent for us to process your Personal Data for a specific purpose;
  • contract: where our use of your Personal Data is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract;
  • legal obligation: where our use of your Personal Data is necessary for us to comply with the law (not including contractual obligations);
  • public task: where our use of your Personal Data is necessary for us to perform a task in the public interest and the task or function has a clear basis in law; or
  • legitimate interests: where our use of your Personal Data is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your Personal Data that overrides our legitimate interests).

If you are based elsewhere in the world this section does not apply to you and your local privacy laws may apply.


Responsible Chainalysis entity

Data privacy laws sometimes differentiate between “controllers” and “processors” of personal information. A “controller” determines the purposes and means (i.e., the why and how) of processing personal information. A “processor”, which is sometimes referred to as a “service provider,” on the other hand processes personal information on behalf of a controller subject to the latter’s instructions and corresponding contractual restrictions. Chainalysis is the controller of Personal Data (defined above) as described in this Policy unless otherwise noted. This Policy does not generally apply to the company’s processing activities in its capacity as a processor or service provider.

As Chainalysis is based in the U.S, Chainalysis Inc. has appointed a UK and an EU representative under Article 27 of the GDPR, as follows:

  • EU Representative: Chainalysis ApS, which is based in Denmark
  • UK Representative: Chainalysis UK Limited, which is based in the United Kingdom.

Changes to this Privacy Policy

This Policy was updated on July 21, 2022. We may change this Policy from time to time – if we make any material changes to this Policy, we will notify you by email, through the Service, or by posting a prominent notice on the Chainalysis website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. All changes shall be effective from the date of publication unless otherwise provided.

How to Contact Us

Please contact us if you have any questions about this Policy or the Personal Data we hold about you, by email at [email protected], or by mail at:

Chainalysis Inc.
ATTN: Head of Privacy
114 5th Avenue, 18th Floor
New York, NY 10011

Please see the Chainalysis Privacy Policy for more information on how the company processes Personal Data generally, including that which is collected on our website,, and its associated pages and sites.