Ledger relies on 'legitimate interest' as a legal justification for certain data processing activities including analytics, fraud prevention, and some marketing activities, without requiring your explicit consent for these uses.
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
Legitimate interest as a legal basis permits data processing without requiring explicit user consent, provided the organization's interests do not override privacy protections. This basis enables Ledger to conduct certain processing activities—such as fraud prevention, service improvement, or analytics—through a balancing test rather than through affirmative opt-in mechanisms.
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 disclosure of how Ledger relies on legitimate interest as a legal basis for processing, reducing transparency about data processing justifications.
View full change record →Processing based on legitimate interest means your behavioral and usage data may be analyzed and used for business purposes without your consent, though you can object to this processing at any time by contacting Ledger.
How other platforms handle this
We use your personal information to comply with applicable legal and regulatory obligations and respond to legally valid requests and communications from law enforcement authorities to the extent required by applicable law.
Preventing and prosecuting potentially prohibited or illegal activities; Enforcing our agreements; and Complying with our legal obligations
We use your Personal Information to comply with applicable laws and regulations, respond to legal process, and/or respond to requests and communications from law enforcement authorities or other government officials.
Reliance on legitimate interest under GDPR Article 6(1)(f) requires a balancing test demonstrating that Ledger's interests do not override data subjects' rights; given the sensitivity of financial and crypto-related data, regulators may scrutinize this basis …
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
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Legitimate interest as a legal basis permits data processing without requiring explicit user consent, provided the organization's interests do not override privacy protections. This basis enables Ledger to conduct certain processing activities—such as fraud prevention, service improvement, or analytics—through a balancing test rather than through affirmative opt-in mechanisms.
Processing based on legitimate interest means your behavioral and usage data may be analyzed and used for business purposes without your consent, though you can object to this processing at any time by contacting Ledger.
ConductAtlas has identified this type of provision across 279 platforms. See the full comparison.
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