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 clause establishes Ledger's security standard as 'commercially acceptable means' rather than absolute protection, defining the operational scope of the entity's security obligations and limiting the baseline expectation for data protection.
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 →Users operate under terms that establish Ledger's security commitment as commercially reasonable efforts without absolute guarantees, meaning data protection is subject to inherent internet transmission and electronic storage vulnerabilities.
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We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, loss, destruction, or alteration. However, no internet transmission or electronic storage is completely secure, and we cannot guarantee absolute security. In the event of ...
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"The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.— Excerpt from Ledger's Ledger Privacy Policy
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The clause establishes Ledger's security standard as 'commercially acceptable means' rather than absolute protection, defining the operational scope of the entity's security obligations and limiting the baseline expectation for data protection.
Users operate under terms that establish Ledger's security commitment as commercially reasonable efforts without absolute guarantees, meaning data protection is subject to inherent internet transmission and electronic storage vulnerabilities.
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