Ledger relies on multiple legal bases for processing personal data under GDPR, including contract performance for order fulfillment, legitimate interests for fraud prevention and analytics, and consent for marketing communications and non-essential cookies.
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
The legal basis used for each processing activity determines what rights users can exercise and whether they can object to or stop that processing; reliance on legitimate interests rather than consent means some processing may occur without an active opt-in.
Interpretive note: The specific legal basis assigned to each processing activity was not visible in the truncated document; the analysis reflects standard GDPR-compliant policy structures commonly used by French companies.
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 →Some data processing by Ledger may occur under the legitimate interests basis without requiring your consent, which means you cannot withdraw consent to stop it but can object to such processing; marketing emails and non-essential cookies require your consent and can be withdrawn.
How other platforms handle this
If you are in the European Economic Area (EEA), we only process your personal data when we have a valid legal basis to do so, including when: (a) you have consented to the processing; (b) the processing is necessary to perform a contract with you; (c) we have a legitimate interest in processing your...
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...
We may disclose your information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements. We may also disclose your information if we believe it...
Monitoring
Ledger has changed this document before.
Receive same-day alerts, structured change summaries, and monitoring for up to 25 platforms.
"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: GDPR Article 6 requires that each processing activity have a valid legal basis, and Article 13 requires that the applicable legal basis be disclosed to data subjects at the time of collection. The CNIL and other EU data protection authorities have issued guidance on when legitimate interests can be relied upon versus when consent is required. The European Data Protection Board's opinions on legitimate interest are directly relevant to analytics and profiling use cases. GOVERNANCE EXPOSURE: Medium. Reliance on legitimate interests for analytics, fraud prevention, and product improvement is common practice but subject to a balancing test under GDPR that weighs Ledger's interests against the data subject's rights and expectations. Given the sensitivity of crypto wallet customer data, the threshold for legitimate interests reliance may be higher than for a standard retail context. JURISDICTION FLAGS: EU/EEA users can object to processing based on legitimate interests under GDPR Article 21, and Ledger must stop such processing unless it can demonstrate compelling legitimate grounds that override the user's interests. UK users have equivalent rights under UK GDPR. CONTRACT AND VENDOR IMPLICATIONS: The legal basis relied upon for sharing data with processors and analytics partners affects the scope of data processing agreements required. Where consent is the basis, processing agreements must include obligations to cease processing if consent is withdrawn. COMPLIANCE CONSIDERATIONS: Compliance teams should map each processing activity to its stated legal basis and confirm that the legitimate interests assessments (LIAs) are documented, proportionate, and defensible. Where analytics or profiling is conducted under legitimate interests, LIA documentation should specifically address the sensitivity of crypto-ownership-correlated data as a factor in the balancing test.
Full compliance analysis
Regulatory citations, enforcement risk, and due diligence action items.
Free: track 1 platform + weekly digest. Monitor: 25 platforms + same-day alerts. No credit card required.
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
Compliance Governance Intelligence
Need to monitor specific governance provisions?
Compliance includes provision-level monitoring, governance timelines, regulatory mapping, and audit-ready analysis.
Built from archived source documents, structured governance mappings, and historical version tracking.
The legal basis used for each processing activity determines what rights users can exercise and whether they can object to or stop that processing; reliance on legitimate interests rather than consent means some processing may occur without an active opt-in.
Some data processing by Ledger may occur under the legitimate interests basis without requiring your consent, which means you cannot withdraw consent to stop it but can object to such processing; marketing emails and non-essential cookies require your consent and can be withdrawn.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Ledger.