The policy provides specific withdrawal mechanisms for four categories of consent: cookie-based processing (via Cookie Policy), marketing email communications (via unsubscribe link), Ledger Wallet application data processing (via app settings), and push notifications (via phone settings).
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
This provision enumerates distinct consent withdrawal pathways for each processing context, which is operationally relevant for compliance with GDPR's requirement that consent withdrawal be as easy as consent was given. The differentiation between in-app controls, email unsubscribe, and device-level settings reflects processing across multiple channels.
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 →This provision provides granular instructions for withdrawing consent across multiple channels, improving user transparency and facilitating easier opt-outs from various data collection methods.
View full change record →Under this clause, users may withdraw consent for cookies, marketing emails, in-app data processing, and push notifications through the specified mechanisms. Each withdrawal mechanism is specific to a processing channel, meaning users who wish to withdraw consent across all channels must use each mechanism separately.
Cross-platform context
See how other platforms handle Consent Withdrawal Mechanisms and similar clauses.
Compare across platforms →"Withdraw your consent Here is how: For cookies: click on the button at the bottom of our Cookie Policy. For marketing emails: click on the 'Unsubscribe' link in the footer of our emails. For Ledger Wallet: go to the settings of the application. For push notifications: go to the settings of your phone.Excerpt from Ledger's Privacy Policy
1) REGULATORY LANDSCAPE: GDPR requires that consent withdrawal be easy and as straightforward as consent was given.
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This provision enumerates distinct consent withdrawal pathways for each processing context, which is operationally relevant for compliance with GDPR's requirement that consent withdrawal be as easy as consent was given. The differentiation between in-app controls, email unsubscribe, and device-level settings reflects processing across multiple channels.
Under this clause, users may withdraw consent for cookies, marketing emails, in-app data processing, and push notifications through the specified mechanisms. Each withdrawal mechanism is specific to a processing channel, meaning users who wish to withdraw consent across all channels must use each mechanism separately.
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