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 →Removal of this provision addressing the public visibility of blockchain transactions represents a gap in addressing the unique privacy considerations of cryptocurrency users regarding immutable transaction records.
View full 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 data between our affiliates for the safety and security of our users and may take necessary actions if we believe you have violated these Terms, including banning you from our Services and/or our affiliates' services...
Protect us, our business, our users, and others, for example to enforce our terms of service, prevent spam or other unwanted communications, and investigate or protect against fraud
Each payment processor uses and processes your complete payment information in accordance with its applicable privacy policy (Stripe and PayPal).
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 …
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
ConductAtlas detected a major restructuring of Meta’s privacy policy that removed detailed consumer rights disclosures and relocated them to separate documents.
Your genetic data may be transferred to a new owner as a business asset. Here is what the Terms of Service actually say and what you can do right now.
Get the research letter
Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean.
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.
ConductAtlas has identified this type of provision across 288 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Ledger.