Ledger · Ledger Privacy Policy · View original document ↗

Personal Data Collection Scope

Medium severity Medium confidence Inferredfromcontext Uncommon · 10 of 325 platforms
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Document Record

What it is

Ledger collects personal information including your name, email address, postal address, purchase history, device usage data, and technical diagnostics when you buy products or use Ledger Live.

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)

For cryptocurrency hardware wallet users, the combination of identity data and purchase records effectively signals asset ownership, creating a risk profile that goes beyond typical retail data collection.

Interpretive note: The full text of Ledger's data collection disclosures was not fully rendered in the provided document due to truncation; the analysis is based on available document text and the policy's stated purpose.

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 polici…

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 servi…

Consumer impact (what this means for users)

Your name, home address, and purchase history are stored together in Ledger's systems, and this combination has previously been exposed in a major 2020 data breach that enabled targeted phishing and fraud against customers.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    Contact Ledger's data protection team by email to request access to or deletion of your personal data. Specify clearly what data you want accessed or deleted and provide sufficient identification for Ledger to verify your identity.

How other platforms handle this

Discord Medium

We collect the following information when you register for and use our services: Account information. You can create a Discord account by providing an email address and creating a username and password. When you create an account, we will assign you a unique identifier. If you choose to, you may pro...

Egnyte Medium

We collect information you provide directly to us, such as when you create an account, contact us for support, sign up for marketing emails, or otherwise communicate with us. The types of information we may collect include your name, email address, postal address, phone number, company name, job tit...

ClickUp Medium

We collect information you provide directly to us, such as when you create an account, use our Services, make a purchase, or contact us for support. The types of information we may collect include your name, email address, password, phone number, credit card and other payment information, and any ot...

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▸ View Original Clause Language DOCUMENT RECORD
"
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

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: The scope of personal data collected engages GDPR Articles 5 and 13 (data minimization and transparency obligations), with the CNIL as lead supervisory authority. For US customers, FTC Act Section 5 unfair or deceptive practices standards apply, and CCPA imposes disclosure and rights obligations for California residents. GOVERNANCE EXPOSURE: Medium. The data collected is broadly consistent with e-commerce industry norms, but the specific context of cryptocurrency hardware wallet purchases elevates the sensitivity classification. Linking identity data to wallet purchase records creates an implicit dataset of likely crypto asset holders, which may attract regulatory or law enforcement interest beyond standard retail data scenarios. JURISDICTION FLAGS: EU/EEA users are protected by GDPR's data minimization and purpose limitation principles, which may constrain secondary uses of collected data. California residents have CCPA rights to know and delete. UK users fall under UK GDPR. The elevated sensitivity of crypto-ownership-correlated data warrants heightened attention in any jurisdiction with financial data protection frameworks. CONTRACT AND VENDOR IMPLICATIONS: Procurement teams should assess whether downstream data processors (logistics partners, analytics providers) have data processing agreements that reflect the elevated sensitivity of this dataset. Vendor contracts should specify data retention limits and prohibit secondary use of customer data for purposes not authorized by Ledger's privacy policy. COMPLIANCE CONSIDERATIONS: Compliance teams should verify that the purposes stated for each data category are sufficiently specific to satisfy GDPR's transparency requirements, and that data retention schedules are documented and enforced. Given the 2020 breach history, a data mapping exercise to confirm current data minimization practices is advisable.

Full compliance analysis

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

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Applicable agencies

  • FTC
    The FTC has jurisdiction over consumer data collection and privacy practices under the FTC Act's unfair or deceptive practices standard, applicable to Ledger's US customer data handling.
    File a complaint →

Applicable regulations

Connecticut Data Privacy Act Amendments
US-CT
ePrivacy Directive
European Union
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Ledger Privacy Policy
Entity
Ledger
Document last updated
May 5, 2026
Tracking information
First tracked
April 27, 2026
Last verified
May 10, 2026
Record ID
CA-P-008444
Document ID
CA-D-00278
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
9a6fc1c6566c5db4f79f71e6b92bfb73f8160ea24b52ecc228c23699f2fbc16b
Analysis generated
April 27, 2026 15:33 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Ledger
Document: Ledger Privacy Policy
Record ID: CA-P-008444
Captured: 2026-04-27 15:33:24 UTC
SHA-256: 9a6fc1c6566c5db4…
URL: https://conductatlas.com/platform/ledger/ledger-privacy-policy/personal-data-collection-scope/
Accessed: May 13, 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 Personal Data Collection Scope clause do?

For cryptocurrency hardware wallet users, the combination of identity data and purchase records effectively signals asset ownership, creating a risk profile that goes beyond typical retail data collection.

How does this clause affect you?

Your name, home address, and purchase history are stored together in Ledger's systems, and this combination has previously been exposed in a major 2020 data breach that enabled targeted phishing and fraud against customers.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 10 platforms. See the full comparison.

Is ConductAtlas affiliated with Ledger?

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