Ledger discloses that transactions conducted on public blockchains are inherently visible to anyone and cannot be deleted or altered, as this is a fundamental characteristic of blockchain technology.
This analysis describes what Ledger's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
The operational significance is that transaction data visibility occurs by design of the blockchain system rather than through Ledger's data collection or sharing practices. This distinguishes between data Ledger controls and data visibility that results from the user's choice to use a public blockchain network.
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.
View change record →Ledger removed language explicitly stating that this privacy policy does not cover Ledger Recover and Ledger Multisig services, and eliminated references to dedicated privacy policies for those services. This creates ambiguity about whether those services are now governed by the main privacy policy or whether separate policies exist but are no longer disclosed in this document. If you use Ledger Recover or Ledger Multisig, you should review the privacy disclosures for those specific services directly, as it is no longer clear from the main privacy policy whether separate protections apply.
View change record →Your right to erasure under GDPR does not apply to blockchain transaction data, meaning a permanent record of your financial activity exists and cannot be removed regardless of your privacy preferences.
How other platforms handle this
We may share your information in connection with, or during negotiations of, any merger, sale of company assets, financing, acquisition, or dissolution, transaction, or proceeding involving all or a portion of our business.
We may share personal information with third-party service providers and partners who support our business operations, including identity verification providers, payment processors, analytics providers, marketing partners, and blockchain analytics companies.
We may share your personal information with our affiliates, meaning entities that control, are controlled by, or are under common control with Consensys. We also share information with service providers who assist in operating our services, subject to confidentiality obligations.
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Ledger has changed this document before.
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The irreconcilability of blockchain immutability with GDPR's right to erasure (Article 17) represents a structural compliance tension that regulators have noted but not fully resolved; legal teams should assess whether adequate disclosures are made at point of collection.
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The operational significance is that transaction data visibility occurs by design of the blockchain system rather than through Ledger's data collection or sharing practices. This distinguishes between data Ledger controls and data visibility that results from the user's choice to use a public blockchain network.
Your right to erasure under GDPR does not apply to blockchain transaction data, meaning a permanent record of your financial activity exists and cannot be removed regardless of your privacy preferences.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Ledger.