Ledger · Ledger Privacy Policy · View original document ↗

Legitimate Interest as Legal Basis

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Document Record

What it is

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

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.

Recent Activity

This document changed recently

High Apr 19, 2026

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 →
Medium Apr 2, 2026

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 →

Consumer impact (what this means for users)

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

Adobe Medium

As required by Adobe to conduct our business and pursue our legitimate interests: Analyzing your content and its characteristics using automated techniques... Where we process your information based on legitimate interests, you can object to this processing in certain circumstances. In such cases, w...

Pinterest Medium

We use information about you to provide, improve, and develop our products and services, personalize your experience, show you relevant content and ads, and communicate with you. We draw inferences about your interests and preferences based on your activity on Pinterest and elsewhere.

TikTok Medium

To make the Platform more relevant and enjoyable for you, we customize parts of your experience on the Platform to show you creators and content we think you will be interested in, including ads and other content sponsored by or in collaboration with our creators and our partners. We customize what ...

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ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

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 for marketing and profiling activities.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC may investigate whether reliance on legitimate interest without meaningful consumer notice constitutes an unfair or deceptive practice for US consumers.
    File a complaint →

Applicable regulations

ePrivacy Directive
European Union
FTC Act Section 5
United States Federal
GDPR
European Union

Provision details

Document information
Document
Ledger Privacy Policy
Entity
Ledger
Document last updated
May 5, 2026
Tracking information
First tracked
March 20, 2026
Last verified
March 20, 2026
Record ID
CA-P-001468
Document ID
CA-D-00278
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
c75d6e4bcb2997d48e8c0bb89a1ca1dc4347f8de57f584825d2699f987d08a1b
Analysis generated
March 20, 2026 10:46 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Ledger
Document: Ledger Privacy Policy
Record ID: CA-P-001468
Captured: 2026-03-20 10:46:12 UTC
SHA-256: c75d6e4bcb2997d4…
URL: https://conductatlas.com/platform/ledger/ledger-privacy-policy/legitimate-interest-as-legal-basis/
Accessed: May 20, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Frequently Asked Questions

What does Ledger's Legitimate Interest as Legal Basis clause do?

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.

How does this clause affect you?

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.

Is ConductAtlas affiliated with Ledger?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Ledger.