The policy states that users may request restriction of data processing (including halting automatic deletion) and may object to processing, with the stated consequence that Ledger will stop processing the user's data upon a valid objection.
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
The objection right as stated in this provision is described in absolute terms, stating that Ledger 'will stop processing your data' upon objection, which is broader than the conditional right to object under GDPR Article 21, which permits controllers to continue processing on compelling legitimate grounds. The restriction right's specific mention of stopping automatic deletion is operationally relevant for users seeking to preserve data records.
Interpretive note: The policy states objection will result in Ledger stopping all processing, but GDPR Article 21 permits continued processing on compelling legitimate grounds; it is unclear whether this provision reflects a policy commitment beyond GDPR's minimum or an oversimplification of applicable procedure.
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 →This provision establishes users' rights to restrict and object to processing, including an unusual carve-out preventing automatic deletion, which gives users greater control over how their data is handled.
View full change record →Under this clause, users may submit an objection to Ledger's processing of their personal data, and the policy states that Ledger will stop processing upon receiving such an objection. Users may also request processing restriction, including a halt to any automatic deletion, which may be useful for users seeking to preserve data for their own records.
Cross-platform context
See how other platforms handle Right to Restrict Processing and Object to Processing and similar clauses.
Compare across platforms →"Set your limits You can: Ask that we restrict the processing of your data. This includes asking us to stop any automatic deletion of your data. Object to the processing of your data. We will stop processing your data.Excerpt from Ledger's Privacy Policy
1) REGULATORY LANDSCAPE: GDPR Article 21 grants a conditional right to object to processing based on legitimate interests or direct marketing, and Article 18 grants a right to restriction under specific circumstances.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
Get the research letter
Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean.
The objection right as stated in this provision is described in absolute terms, stating that Ledger 'will stop processing your data' upon objection, which is broader than the conditional right to object under GDPR Article 21, which permits controllers to continue processing on compelling legitimate grounds. The restriction right's specific mention of stopping automatic deletion is operationally relevant for users …
Under this clause, users may submit an objection to Ledger's processing of their personal data, and the policy states that Ledger will stop processing upon receiving such an objection. Users may also request processing restriction, including a halt to any automatic deletion, which may be useful for users seeking to preserve data for their own records.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Ledger.