Ledger · Ledger Privacy Policy · View original document ↗

Third-Party Data Sharing

Medium severity Medium confidence Inferredfromcontext Uncommon · 25 of 343 platforms
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Document Record

What it is

Ledger shares your personal data with third-party service providers including logistics companies, payment processors, and analytics platforms to fulfill orders and improve its services.

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)

Sharing identity and purchase data with multiple third parties increases the number of organizations that hold sensitive information linking you to a cryptocurrency hardware wallet purchase.

Interpretive note: The specific categories of third parties and the complete list of data sharing arrangements were not fully visible in the truncated document; analysis is based on available content and standard Ledger policy disclosures.

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 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 →
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 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 →

Clause Stability Stable

0
Changes
3
Months Monitored
May 10, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 1153 other provisions on other platforms.

Consumer impact (what this means for users)

Your name, address, and purchase details may be shared with logistics partners, payment providers, and analytics companies, each of which represents an additional data exposure point for information that signals cryptocurrency asset ownership.

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.
  • Export Your Data
    Submit a data access request to Ledger to obtain a copy of all personal data held about you, including information shared with third parties. This will help you understand the full scope of data sharing.

How other platforms handle this

Skillshare Medium

We may share your information with third-party vendors and service providers that perform services on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. We may also share your information with third-party advertising p...

Bumble Medium

We may also share your personal information with third parties that assist us in providing our services, or where we are under an obligation to report to. But rest assured: we will only ever share your personal information in the limited circumstances described in this Policy.

Betterment Medium

We may share your personal information with third parties in the following circumstances: With service providers who perform services on our behalf, such as data analytics, marketing, customer service, and technology services. With financial partners, including banks, brokerage firms, and payment pr...

See all platforms with this clause type →

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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: Third-party data sharing implicates GDPR Articles 28 and 44 (processor agreements and international transfers), requiring that all recipients operate under binding data processing agreements and that transfers outside the EEA are protected by appropriate safeguards. The FTC Act applies to US-facing data sharing practices. CCPA requires disclosure of categories of third parties with whom data is shared. GOVERNANCE EXPOSURE: Medium. Data sharing with logistics and payment providers is standard for e-commerce, but the inclusion of analytics and marketing partners as recipients of customer data requires careful purpose limitation analysis under GDPR. The elevated sensitivity of crypto-ownership-correlated data applies equally to all downstream recipients. JURISDICTION FLAGS: EU/EEA transfers to non-adequate countries require SCCs or Binding Corporate Rules. California residents have CCPA rights to know the categories of third parties receiving their data and to opt out of sharing for cross-context behavioral advertising. UK users fall under UK GDPR transfer rules. CONTRACT AND VENDOR IMPLICATIONS: All third-party recipients should operate under current GDPR-compliant data processing agreements. Procurement teams should assess whether analytics vendors (such as those connected to Google Tag Manager or similar tools visible in the page source) have appropriate agreements in place and whether consent is properly obtained before data is shared with advertising or analytics platforms. COMPLIANCE CONSIDERATIONS: A vendor inventory and data flow map should be maintained to document all third-party recipients, the legal basis for each transfer, and applicable safeguards. Cookie consent mechanisms should be audited to confirm that analytics and marketing data sharing is gated on valid consent rather than legitimate interest where consent is legally required.

Full compliance analysis

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

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Applicable agencies

  • FTC
    The FTC has authority over data sharing practices and unfair or deceptive trade practices affecting US consumers, including undisclosed or insufficiently disclosed third-party data transfers.
    File a complaint →

Applicable regulations

Connecticut Data Privacy Act Amendments
US-CT
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-008445
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-008445
Captured: 2026-04-27 15:33:24 UTC
SHA-256: 9a6fc1c6566c5db4…
URL: https://conductatlas.com/platform/ledger/ledger-privacy-policy/third-party-data-sharing/
Accessed: June 27, 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 Third-Party Data Sharing clause do?

Sharing identity and purchase data with multiple third parties increases the number of organizations that hold sensitive information linking you to a cryptocurrency hardware wallet purchase.

How does this clause affect you?

Your name, address, and purchase details may be shared with logistics partners, payment providers, and analytics companies, each of which represents an additional data exposure point for information that signals cryptocurrency asset ownership.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 25 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.