15 Total
5 High severity
8 Medium severity
2 Low severity

Key Facts

When will Ledger delete user data?
Ledger will delete user data unless retention is required to respect its legal obligations.
Does Ledger commit to never discriminating against users for exercising their privacy rights?
Ledger commits to never discriminating against users for exercising their privacy rights.
What does Ledger treat continued use of its services as?
Ledger treats continued use of its services after policy updates as agreement to the new terms.
What right does Ledger grant users regarding their personal data?
Ledger grants users the right to ask that their personal data be deleted.
What right does Ledger grant users?
Ledger grants users the right to object to the processing of their data and commits to stopping that processing upon objection.
What will Ledger do upon a user's objection?
Ledger grants users the right to object to the processing of their data and commits to stopping that processing upon objection.
What does Ledger provide as the method for withdrawing cookie consent?
Ledger provides a button at the bottom of its Cookie Policy as the method for withdrawing cookie consent.
Who does Ledger direct users to contact as the method for exercising their rights?
Ledger directs users to contact its Data Protection Officer as the method for exercising their rights.
What does Ledger provide as the method for opting out of marketing emails?
Ledger provides an 'Unsubscribe' link in the footer of its marketing emails as the method for opting out of marketing emails.
What right do users who are unsatisfied with Ledger's response have?
Ledger acknowledges that users who are unsatisfied with its response have the right to complain to their national data protection authority.
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Summary

This document explains what personal data Ledger holds about you and what rights you have over it, including the ability to ask Ledger to delete, correct, or hand over a copy of your data, and to object to how it is processed. If you object, Ledger commits to stopping that processing. Using Ledger's services after a policy update means you accept the new terms, even without clicking anything to confirm.

Analysis

Ledger's Privacy Policy establishes a default data deletion commitment, subject to a legal-obligations carve-out, and grants users a suite of enumerated rights including erasure, objection to processing, data access, and rectification. Ledger commits to an unconditional cessation of processing upon a user's objection, responds to legitimate requests within one month, and designates its Data Protection Officer as the exclusive channel for rights exercise. The policy provides specific, bounded mechanisms for withdrawing cookie consent and opting out of marketing communications, and acknowledges users' right to escalate complaints to a national data protection authority. Continued use of Ledger's services following a policy update constitutes agreement to the revised terms.

What this means for you

As a Ledger user, you can request deletion, correction, or a copy of your personal data, and you can object to Ledger processing your data — with Ledger committing to stop upon objection. You can withdraw cookie consent using the button at the bottom of Ledger's Cookie Policy, opt out of marketing emails via the 'Unsubscribe' link in the footer of those emails, and route all rights requests through Ledger's Data Protection Officer. If you are unsatisfied with Ledger's response, you have the right to complain to your national data protection authority. Ledger commits to never discriminating against you for exercising any of these rights.

Institutional Analysis
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Which mapped governance frameworks each document engages, tied to the specific provisions that engage them.

4 important changes detected

7 versions captured · Last updated: July 2026

What changed Ledger revised its privacy policy to add introductory language about data subject rights. The updated policy now begins with a statement that 'You have rights when it comes to your personal data' and adds context that Ledger wants users to understand what those rights are so they can exercise them easily. The substantive rights listed in the policy (such as requesting a copy of personal data) remain unchanged; this revision primarily reframes how those rights are presented to users.
Why this matters The updated privacy policy reorganizes its presentation of user data rights without materially changing what rights are available. The policy now explicitly introduces the concept that users have rights regarding their personal data and states that Ledger's purpose in disclosing them is to help users understand and exercise those rights easily. The substantive rights themselves, such as the ability to request a copy of personal data, remain as previously described.
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What changed Ledger substantially rewrote its privacy policy on April 19, 2026, removing 188 sentences while adding only 11 new ones. The updated policy is shorter and restructured, with the opening section reorganized and language about policy updates and service exclusions removed. Notably, the policy no longer explicitly mentions that Ledger Recover and Ledger Multisig services are not covered by this privacy policy, and no longer directs users to separate privacy policies for those services.
Why this matters The updated policy removes explicit language stating that Ledger Recover and Ledger Multisig services are excluded from this privacy policy. Previously, users were directed to separate privacy policies for those services; that direction is now absent. This creates ambiguity about whether this policy now covers those services or whether separate policies still apply. The dramatic reduction in policy length (from 224 to 36 sentences) suggests substantial content was removed, though the specific implications depend on what other sections were condensed or eliminated. You should review the full updated policy to confirm what data practices and service exclusions remain in effect for all Ledger services you use.
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April 3, 2026 low

Ledger's privacy policy was updated on April 3, 2026 with a minor formatting change to the section heading 'With whom do we share your data?' The word 'Discover' was added …

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April 2, 2026 medium

Ledger significantly restructured its privacy policy on April 2, 2026, removing 188 sentences and adding 11 new ones. The policy now opens with 'Your privacy, our priority' instead of a …

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Featured, High severity
Featured, Medium severity

Complete Provision Index

Every distinct legal provision identified in this document. Featured provisions appear above with analysis.

15 provisions
12 featured
6 clause types
5 high severity
Data Retention 1 1 high
Enforcement Actions 1 1 high
Policy Changes 1 1 high
Disclosure and Transparency Requirements 1
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Mapped Governance Frameworks

ePrivacy Directive
European Union
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Archival ProvenanceSource & Archival Record
Last Captured July 23, 2026 00:48 UTC
Capture Method Automated scheduled archival capture
Document ID CA-D-000278
Version ID CA-V-005204
SHA-256 7197a8f92c5ad61de9b8a2c4f177c234640888db044660bc82a813ce3c746fea
✓ Snapshot stored ✓ Text extracted ✓ Change verified ✓ Hash verified

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