Ledger · Ledger Privacy Policy · View original document ↗

Cookie and Analytics Tracking

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Document Record

What it is

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

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.

Recent Activity

This document changed recently

High Apr 19, 2026

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 →
Medium Apr 2, 2026

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 →

Clause Stability Stable

0
Changes
3
Months Monitored
May 10, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 3350 other provisions on other platforms.

Consumer impact (what this means for users)

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.

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.
  • Opt Out of Arbitration
    Visit the Ledger privacy policy page and use the OneTrust cookie preference center to adjust your consent settings. Select only the cookie categories you are comfortable with and save your preferences.

How other platforms handle this

Twilio Medium

TrustArcWrapper.withTrustArc(analytics, { alwaysLoadSegment: true }).load(segmentKey, cookieConfig);

Headspace Medium

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...

Garmin Medium

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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▸ View Original Clause Language DOCUMENT RECORD
"
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

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

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.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC has authority over online tracking and data collection practices affecting US consumers, including whether cookie consent mechanisms are accurately described and implemented.
    File a complaint →

Applicable regulations

Connecticut Data Privacy Act Amendments
US-CT
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Ledger Privacy Policy
Entity
Ledger
Document last updated
May 5, 2026
Tracking information
First tracked
April 27, 2026
Last verified
May 10, 2026
Record ID
CA-P-008447
Document ID
CA-D-00278
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
9a6fc1c6566c5db4f79f71e6b92bfb73f8160ea24b52ecc228c23699f2fbc16b
Analysis generated
April 27, 2026 15:33 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Ledger
Document: Ledger Privacy Policy
Record ID: CA-P-008447
Captured: 2026-04-27 15:33:24 UTC
SHA-256: 9a6fc1c6566c5db4…
URL: https://conductatlas.com/platform/ledger/ledger-privacy-policy/cookie-and-analytics-tracking/
Accessed: June 27, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Low
Categories

Other risks in this policy

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Frequently Asked Questions

What does Ledger's Cookie and Analytics Tracking clause do?

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.

How does this clause affect you?

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.

Is ConductAtlas affiliated with Ledger?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Ledger.