The policy states that Ledger may update its Privacy Policy at any time and that continued use of its services following an update constitutes the user's agreement to the revised terms.
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 establishes an implied acceptance mechanism for policy changes, meaning that users who continue using Ledger products after a policy update are treated as having agreed to the new terms without requiring affirmative acknowledgment. Under GDPR, this mechanism may be subject to evaluation against requirements for valid consent, particularly where material changes to data processing are introduced.
Interpretive note: The enforceability of implied consent via continued use may be limited under GDPR and certain state privacy laws depending on the materiality of the policy change and the adequacy of user notification.
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 establishes a constructive acceptance mechanism where continued use constitutes agreement to policy changes, which may limit users' ability to opt-out of unfavorable terms.
View full change record →Under this clause, continued use of Ledger's services after a privacy policy update is treated as acceptance of the revised terms. Users who do not wish to accept updated terms would need to discontinue use of Ledger's services, as the policy does not describe an opt-out or objection mechanism specific to policy changes.
Cross-platform context
See how other platforms handle Continued Use as Policy Update Acceptance and similar clauses.
Compare across platforms →"Keep in mind that we may update this Privacy Policy whenever needed or if the law requires it. If you continue to use our services after updates, you're agreeing to the new terms.Excerpt from Ledger's Privacy Policy
1) REGULATORY LANDSCAPE: This provision implicates GDPR Articles governing consent validity and transparency, as well as the requirement that data subjects be informed of material changes to processing activities.
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This provision establishes an implied acceptance mechanism for policy changes, meaning that users who continue using Ledger products after a policy update are treated as having agreed to the new terms without requiring affirmative acknowledgment. Under GDPR, this mechanism may be subject to evaluation against requirements for valid consent, particularly where material changes to data processing are introduced.
Under this clause, continued use of Ledger's services after a privacy policy update is treated as acceptance of the revised terms. Users who do not wish to accept updated terms would need to discontinue use of Ledger's services, as the policy does not describe an opt-out or objection mechanism specific to policy changes.
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