The policy commits to responding to all legitimate data subject rights requests within one month and informs users that they may escalate unsatisfactory responses to their national data protection authority, naming the French CNIL as an example.
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
This provision establishes the operational response standard for data subject requests and explicitly preserves the right to supervisory authority complaint, which is a GDPR requirement. The qualification of requests as 'legitimate' is not further defined in the excerpted text.
Interpretive note: The policy qualifies the response obligation as applying to 'legitimate' requests without defining this term, introducing potential ambiguity about which requests Ledger may decline to process within the stated timeline.
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 →GDPR Data Subject Rights provision was renamed and now includes specific one-month response timeline and complaint escalation procedures to national data protection authorities.
View full change record →Under this clause, users who submit data access, correction, deletion, restriction, or objection requests can expect a response from Ledger within one month. Users who are not satisfied with Ledger's response may file a complaint with their national data protection authority.
Cross-platform context
See how other platforms handle Data Subject Rights and One-Month Response Window and similar clauses.
Compare across platforms →"How long will it take to have a response? We respond to all legitimate requests within one month. If you're not satisfied with our response, you can complain to your national data protection authority. For instance, in France, it's the CNIL.Excerpt from Ledger's Privacy Policy
1) REGULATORY LANDSCAPE: GDPR requires controllers to respond to data subject requests within one month, with a possible extension of two additional months for complex or numerous requests.
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This provision establishes the operational response standard for data subject requests and explicitly preserves the right to supervisory authority complaint, which is a GDPR requirement. The qualification of requests as 'legitimate' is not further defined in the excerpted text.
Under this clause, users who submit data access, correction, deletion, restriction, or objection requests can expect a response from Ledger within one month. Users who are not satisfied with Ledger's response may file a complaint with their national data protection authority.
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