What can I do about this clause?

{'method': 'EMAIL', 'recipient': 'dpo@ledger.fr', 'difficulty': 'EASY', 'action_type': 'DELETE_DATA', 'instructions': 'Email dpo@ledger.fr requesting erasure of your personal data including Ledger Live usage data and any associated blockchain address records. Specify that you are invoking your GDPR right to erasure (or CCPA right to delete if you are a California resident).', 'deadline_days': None, 'deadline_hours': None}

Which regulatory agencies enforce this type of clause?

{'agency': 'FTC', 'reason': 'The FTC has authority over unfair or deceptive data practices under FTC Act Section 5, including inadequate security for sensitive financial-linked personal data.', 'complaint_url': 'https://reportfraud.ftc.gov/'}

What is the severity of this clause?

ConductAtlas classifies this Collection and Linkage of Blockchain Address Data with Identity clause as high severity. Severity reflects the magnitude of rights affected, the breadth of users impacted, and the degree of discretion the platform retains.

Collection and Linkage of Blockchain Address Data with Identity — Ledger

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What it is

Ledger records which cryptocurrency wallet addresses you use in Ledger Live and links those addresses to your real name and email — effectively tying your identity to your crypto holdings.

Consumer impact (what this means for users)

This provision means your real identity is connected to your cryptocurrency portfolio activity in Ledger's systems — if this data is breached or subpoenaed, it could reveal your crypto holdings to third parties.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.

Delete Your Data

Email dpo@ledger.fr requesting erasure of your personal data including Ledger Live usage data and any associated blockchain address records. Specify that you are invoking your GDPR right to erasure (or CCPA right to delete if you are a California resident).

Cross-platform context

See how other platforms handle Collection and Linkage of Blockchain Address Data with Identity and similar clauses.

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Why it matters (compliance & risk perspective)

This linkage means Ledger holds data that reveals both who you are and what cryptocurrency you own, making you a higher-value target in any future data breach and potentially exposing sensitive financial information.

View original clause language

When you use Ledger Live, we collect information about your usage of the application, including the public addresses of your cryptocurrency accounts. This information is associated with the personal data we have collected about you, such as your name and email address, to provide you with our services and improve your experience.

Institutional analysis (Compliance & legal intelligence)

REGULATORY FRAMEWORK: This processing implicates GDPR Art. 6(1)(b) (contract performance) and Art. 6(1)(f) (legitimate interests) as potential lawful bases; however, given that blockchain addresses can reveal financial wealth and transaction history, this may constitute processing of data revealing financial status, potentially engaging heightened scrutiny under GDPR Art. 5(1)(c) (data minimisation). CNIL and other EU DPAs have issued guidance on blockchain data and privacy. In the US, FinCEN's cryptocurrency guidance and state money transmission laws may be tangentially relevant if this data is shared with regulated entities.

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Applicable agencies

FTC

The FTC has authority over unfair or deceptive data practices under FTC Act Section 5, including inadequate security for sensitive financial-linked personal data.
File a complaint →

Provision details

Document information

Document

Ledger Privacy Policy

Entity

Ledger

Document last updated

April 29, 2026

Tracking information

First tracked

April 27, 2026

Last verified

April 28, 2026

Record ID

CA-P-003652

Document ID

CA-D-00278

Evidence Provenance

Source URL

https://www.ledger.com/privacy-policy

Wayback Machine

View archived versions →

SHA-256

9a6fc1c6566c5db4f79f71e6b92bfb73f8160ea24b52ecc228c23699f2fbc16b

Verified

✓ Snapshot stored ✓ Change verified

How to Cite

ConductAtlas Policy Archive
Entity: Ledger | Document: Ledger Privacy Policy | Record: CA-P-003652
Captured: 2026-04-27 15:33:24 UTC | SHA-256: 9a6fc1c6566c5db4…
URL: https://conductatlas.com/platform/ledger/ledger-privacy-policy/collection-and-linkage-of-blockchain-address-data-with-identity/
Accessed: May 2, 2026

Classification

Severity

High

Collection and Linkage of Blockchain Address Data with Identity