Ledger states that its services are not directed at children under the age of 18 and that it does not knowingly collect personal data from minors.
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
Children's data provisions are operationally significant because they establish compliance frameworks with children's privacy regulations (such as COPPA in the United States) and define the procedural requirements for lawful data processing when minors are involved. This provision determines Ledger's consent and notification obligations to parents or guardians.
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 children's data protections removes explicit age-related restrictions and safeguards, which is notable given the inclusion of wallet addresses as personal data.
View full change record →Parents or guardians who believe a minor has created a Ledger account or had their data collected should contact Ledger to request deletion of that data.
How other platforms handle this
to request that your data be transferred to a third party (data portability)
Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.
Further, you may take legal actions in relation to any potential breach of your rights regarding the processing of your Personal Information, as well as to lodge complaints before the competent data prot...
Age restriction policies must comply with GDPR Article 8 (which sets the age of digital consent at 16 in France, with member state variation), COPPA in the US, and equivalent frameworks; the policy's blanket 18+ …
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
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Children's data provisions are operationally significant because they establish compliance frameworks with children's privacy regulations (such as COPPA in the United States) and define the procedural requirements for lawful data processing when minors are involved. This provision determines Ledger's consent and notification obligations to parents or guardians.
Parents or guardians who believe a minor has created a Ledger account or had their data collected should contact Ledger to request deletion of that data.
ConductAtlas has identified this type of provision across 289 platforms. See the full comparison.
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