Ledger transfers personal data outside the European Economic Area to countries that may not have equivalent data protection laws, using Standard Contractual Clauses as the stated legal mechanism to protect those transfers.
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 →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
Your personal information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.
Your personal information may be transferred to, stored, and processed in the United States or other countries outside of your country of residence, which may have data protection laws that are different from those in your country.
Your personal information may be transferred to, stored, and processed in the United States or other countries where our service providers and partners operate. By using our Services, you acknowledge that your personal information may be transferred to countries outside your country of residence, in...
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"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
REGULATORY LANDSCAPE: International data transfers from the EEA engage GDPR Chapter V (Articles 44-49), requiring either an adequacy decision, Standard Contractual Clauses, Binding Corporate Rules, or another approved derogation. Post-Schrems II (CJEU Case C-311/18), SCCs must be supplemented by transfer impact assessments where the recipient country's law may undermine the SCC protections. The European Data Protection Board's guidance on supplementary measures is directly applicable. GOVERNANCE EXPOSURE: Medium. Use of SCCs is standard practice, but compliance depends on whether Ledger has adopted the 2021 European Commission updated SCCs and conducted the required transfer impact assessments for each recipient country, particularly for US-based service providers post-Privacy Shield invalidation. JURISDICTION FLAGS: EU/EEA users are the primary affected population. UK users are subject to UK GDPR transfer rules (International Data Transfer Agreements rather than EU SCCs). Transfers to the US require specific attention given the history of EU-US data transfer framework invalidations, though the EU-US Data Privacy Framework adopted in 2023 provides a new adequacy mechanism for certified US recipients. CONTRACT AND VENDOR IMPLICATIONS: All data processing agreements with non-EEA processors should incorporate current SCCs or applicable equivalent mechanisms. Legal teams should confirm whether US-based analytics and logistics vendors are certified under the EU-US Data Privacy Framework, which would simplify transfer compliance. Transfer impact assessments should be documented and updated when vendor locations or processing activities change. COMPLIANCE CONSIDERATIONS: A transfer mapping exercise should identify all non-EEA recipients, the legal mechanism relied upon for each transfer, and documentation of transfer impact assessments. Compliance teams should verify that SCCs in use are the 2021 updated versions and that module selection reflects the actual controller-processor or controller-controller relationship in each case.
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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.
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