Ledger retains personal data for varying periods depending on the purpose, such as retaining customer purchase data for the duration of the legal warranty period and marketing data until you unsubscribe or object.
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
Data retention periods define the operational duration of personal data storage and establish when deletion or anonymization occurs. This provision determines the scope and duration of Ledger's data processing obligations under applicable privacy regulations.
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 →Even after you stop using Ledger products, your data may remain on file for legal, warranty, or business purposes, and you would need to actively request deletion to remove it.
How other platforms handle this
Oura also has legal obligations to retain certain personal data for a specific period of time, such as for tax purposes. These required retention periods may include, for example, accounting and tax requirements, legal claims...
We collect and keep personal data only as needed or allowed for the purposes set out in this Statement, based on the reason we collected the personal data in the first instance and what is permitted under the laws that apply to the processing.
Affirm will retain your information in accordance with our Privacy Policy and any applicable state or federal law, rule or regulation.
Data minimisation and storage limitation principles under GDPR Articles 5(1)(c) and 5(1)(e) require that retention periods are proportionate and justified; legal teams should verify that stated retention periods align with documented legitimate purposes and are …
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
Get the research letter
Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean.
Data retention periods define the operational duration of personal data storage and establish when deletion or anonymization occurs. This provision determines the scope and duration of Ledger's data processing obligations under applicable privacy regulations.
Even after you stop using Ledger products, your data may remain on file for legal, warranty, or business purposes, and you would need to actively request deletion to remove it.
ConductAtlas has identified this type of provision across 274 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Ledger.