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 operationalizes Ledger's compliance obligations under GDPR by explicitly acknowledging specific data subject rights and establishing a mechanism through which users may exercise those rights by contacting the organization. The clause creates a procedural pathway for rights assertion rather than requiring automatic implementation.
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 →EEA residents are authorized to request that Ledger provide, correct, amend, delete, or restrict their personal data, and Ledger commits to take reasonable steps to fulfill such requests upon receipt. The provision does not establish automatic data handling but instead requires users to initiate contact to exercise these rights.
How other platforms handle this
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...
Depending on where you live, you may have certain rights regarding your personal information. These may include the right to access, correct, or delete your personal information; the right to restrict or object to our processing of your personal information; the right to data portability; and the ri...
We use information to enhance the quality, reliability, and/or accuracy of our AI Features by creating, developing, training, testing, improving, and maintaining AI and ML models run by Strava or our service providers. We use aggregated, de-identified data for this purpose. We also use personal info...
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"If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Ledger aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us. In certain circumstances, you have the following data protection rights: the right to access, update or to delete the information we have on you; the right of rectification; the right to object; the right of restriction; the right to data portability; the right to withdraw consent.— Excerpt from Ledger's Ledger Privacy Policy
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
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This provision operationalizes Ledger's compliance obligations under GDPR by explicitly acknowledging specific data subject rights and establishing a mechanism through which users may exercise those rights by contacting the organization. The clause creates a procedural pathway for rights assertion rather than requiring automatic implementation.
EEA residents are authorized to request that Ledger provide, correct, amend, delete, or restrict their personal data, and Ledger commits to take reasonable steps to fulfill such requests upon receipt. The provision does not establish automatic data handling but instead requires users to initiate contact to exercise these rights.
ConductAtlas has identified this type of provision across 6 platforms. See the full comparison.
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