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 transferred outside the EEA may be subject to less protective legal regimes, and compliance with post-Schrems II transfer requirements depends on whether Ledger has implemented the 2021 updated SCCs and conducted transfer impact assessments.
Interpretive note: The specific countries of transfer, the list of non-EEA processors, and confirmation of whether 2021 updated SCCs are in use were not visible in the truncated document text.
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 →Removal of this provision eliminates explicit discussion of cross-border data transfers and mechanisms like Standard Contractual Clauses, reducing transparency about international data flow compliance.
View full change record →Your personal data may be sent to service providers or affiliates located outside the EU, meaning it may be processed in countries with different privacy protections; Standard Contractual Clauses are the stated safeguard, though their practical effectiveness depends on implementation details not visible in this policy.
How other platforms handle this
to request that your data be transferred to a third party (data portability)
Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.
Further, you may take legal actions in relation to any potential breach of your rights regarding the processing of your Personal Information, as well as to lodge complaints before the competent data prot...
"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 Privacy Policy
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
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Data transferred outside the EEA may be subject to less protective legal regimes, and compliance with post-Schrems II transfer requirements depends on whether Ledger has implemented the 2021 updated SCCs and conducted transfer impact assessments.
Your personal data may be sent to service providers or affiliates located outside the EU, meaning it may be processed in countries with different privacy protections; Standard Contractual Clauses are the stated safeguard, though their practical effectiveness depends on implementation details not visible in this policy.
ConductAtlas has identified this type of provision across 289 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Ledger.