Ledger · Ledger Privacy Policy · View original document ↗

Cookie and Behavioral Tracking via OneTrust

Medium severity Unique · 0 of 343 platforms
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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)

The provision operationalizes behavioral tracking as a condition of service access. By conditioning certain service features on cookie acceptance, the terms create a mechanism linking tracking technology deployment to service usability.

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 →

Consumer impact (what this means for users)

Users who disable cookies may experience restricted access to portions of the Ledger Service. The terms establish that cookie acceptance functions as a prerequisite for unrestricted service use, creating a practical dependency between tracking technology and feature availability.

How other platforms handle this

Arlo Medium

<!-- OneTrust Cookies Consent Notice start for arlo.com --> <script async data-cfasync="false" type="text/javascript" src="https://cdn.cookielaw.org/consent/dabf8452-cb28-42ac-b994-02f10392b33c/OtAutoBlock.js"></script> <script async data-cfasync="false" src="https://cdn.cookielaw.org/scripttemplate...

Teladoc Medium

function initMunchkin() { if (didInit === false) { didInit = true; Munchkin.init('479-KGM-236', { altIds: ['138-DRH-707'], }); } } var s = document.createElement('script'); s.type = 'text/javascript'; s.async = true; s.src = '//munchkin.marketo.net/munchkin.js';

OpenAI Medium

We automatically collect certain information from your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Service, we collect information about the individual web pages or products th...

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▸ View Original Clause Language DOCUMENT RECORD
"
We use cookies and similar tracking technologies to track the activity on our Service and hold certain information. Cookies are files with small amount of data which may include an anonymous unique identifier. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

— Excerpt from Ledger's Ledger Privacy Policy

Applicable regulations

Connecticut Data Privacy Act Amendments
US-CT
ePrivacy Directive
European Union
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-003654
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-003654
Captured: 2026-04-27 15:33:24 UTC
SHA-256: 9a6fc1c6566c5db4…
URL: https://conductatlas.com/platform/ledger/ledger-privacy-policy/cookie-and-behavioral-tracking-via-onetrust/
Accessed: June 17, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Built from archived source documents, structured governance mappings, and historical version tracking.

Frequently Asked Questions

What does Ledger's Cookie and Behavioral Tracking via OneTrust clause do?

The provision operationalizes behavioral tracking as a condition of service access. By conditioning certain service features on cookie acceptance, the terms create a mechanism linking tracking technology deployment to service usability.

How does this clause affect you?

Users who disable cookies may experience restricted access to portions of the Ledger Service. The terms establish that cookie acceptance functions as a prerequisite for unrestricted service use, creating a practical dependency between tracking technology and feature availability.

Is ConductAtlas affiliated with Ledger?

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