Ledger uses cookies and analytics tools (including via OneTrust consent management) to track user behavior on its website and in Ledger Live, with some tracking subject to user consent.
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
Analytics and advertising cookies collect behavioral data that may be shared with third-party platforms; the effectiveness of this control depends on whether the consent mechanism is properly configured to block tracking before consent is given.
Interpretive note: The specific categories of cookies used, the full list of analytics vendors, and the precise configuration of the OneTrust consent tool were not visible in the truncated document.
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 →Ledger uses OneTrust to manage cookie consent on its website, meaning you can adjust your tracking preferences; however, the scope of analytics and advertising tracking depends on how the consent tool is configured and whether it covers all tracking technologies in use.
How other platforms handle this
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We use cookies and similar tracking technologies (collectively, "Cookies") to enhance your experience on our Platform... We may use Cookies for purposes such as recognizing you when you log in, remembering your preferences, delivering advertising to you on third-party websites, understanding how you...
If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to access, correct, or erase your personal data; the right to restrict or object to our processing of your personal data; the right to data portability; and, where our processing is based on your...
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"At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.— Excerpt from Ledger's Ledger Privacy Policy
REGULATORY LANDSCAPE: Cookie and analytics tracking engages the EU ePrivacy Directive (as implemented in national law) and GDPR, requiring prior informed consent for non-essential cookies in EU jurisdictions. The CNIL has issued specific guidance on cookie consent requirements, including that consent must be freely given, specific, and unambiguous. The FTC's guidance on online tracking applies to US users. OneTrust is a widely used consent management platform, but its correct configuration is the compliance team's responsibility. GOVERNANCE EXPOSURE: Medium. The presence of Google Tag Manager (visible in page source) and connections to analytics and advertising platforms suggests a complex cookie ecosystem. Compliance depends on whether all tracking scripts are gated on consent before firing, and whether the consent mechanism meets current regulatory standards in all relevant jurisdictions. JURISDICTION FLAGS: EU/EEA users are subject to ePrivacy Directive consent requirements enforced by national data protection authorities including the CNIL. UK users are subject to the UK Privacy and Electronic Communications Regulations. California users have CCPA rights relating to the sharing of personal information with analytics and advertising providers. CONTRACT AND VENDOR IMPLICATIONS: Data processing agreements with analytics vendors (such as Google Analytics or equivalent) should reflect the limited controller or processor role of those vendors and specify data retention and deletion obligations. Procurement teams should confirm that advertising platform agreements include appropriate data use restrictions. COMPLIANCE CONSIDERATIONS: Compliance teams should conduct a cookie audit to inventory all tracking technologies in use and confirm that the OneTrust consent management configuration correctly gates each category of non-essential cookie on prior consent. The audit should cover both the shop.ledger.com website and any tracking within the Ledger Live application.
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Analytics and advertising cookies collect behavioral data that may be shared with third-party platforms; the effectiveness of this control depends on whether the consent mechanism is properly configured to block tracking before consent is given.
Ledger uses OneTrust to manage cookie consent on its website, meaning you can adjust your tracking preferences; however, the scope of analytics and advertising tracking depends on how the consent tool is configured and whether it covers all tracking technologies in use.
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