Ledger states that users have rights to access, correct, delete, and port their personal data, and EU users can object to or restrict processing; these rights can be exercised by contacting Ledger's data protection team.
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
Given the sensitivity of data held by Ledger (home address linked to crypto wallet purchase), the right to request deletion is particularly relevant for customers concerned about their data remaining accessible following the 2020 breach.
Interpretive note: The specific contact details for rights requests and the precise scope of rights afforded to non-EU users were not fully visible in the truncated document.
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 polici…
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 servi…
You have the right to request a copy of all data Ledger holds about you, ask for corrections, or request deletion; exercising the deletion right can reduce your exposure if you are concerned about the security of your personal information.
How other platforms handle this
If you are located in the EEA, UK, or Switzerland, you have certain rights with respect to your personal information, including the right to access your personal data, to correct or delete your personal data, to restrict processing of your personal data, to data portability, and to object to process...
Depending on where you live, you may have certain rights with respect to your personal information. These rights may include: The right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which we collected i...
If you are located in the European Economic Area or the United Kingdom, you have certain rights under applicable data protection laws, including the right to access, correct, or delete your personal data, the right to object to or restrict processing, and the right to data portability. You may also ...
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"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
REGULATORY LANDSCAPE: GDPR Articles 15-22 establish the data subject rights framework applicable to EU/EEA users, including rights of access, rectification, erasure, restriction, portability, and objection. CCPA provides analogous rights for California residents including the right to know, delete, and opt out of sale. Ledger as a French-incorporated entity is subject to CNIL enforcement of GDPR rights obligations. The UK GDPR provides equivalent rights for UK residents. GOVERNANCE EXPOSURE: Low to Medium. Rights frameworks are standard for GDPR-compliant companies, but the elevated sensitivity of Ledger's customer data makes the operational effectiveness of rights response processes more consequential than in typical retail contexts. Response time requirements (one month under GDPR, 45 days under CCPA) and identity verification procedures should be audited. JURISDICTION FLAGS: EU/EEA users benefit from GDPR rights with CNIL enforcement backstop. California residents have CCPA rights. UK users have UK GDPR rights. US users outside California have more limited rights depending on applicable state privacy laws (Virginia, Colorado, Connecticut, and others have enacted state privacy laws with similar rights frameworks). CONTRACT AND VENDOR IMPLICATIONS: Data subject rights requests that implicate data held by third-party processors require that Ledger's processor agreements include obligations for processors to assist with rights responses. Procurement teams should confirm that all data processing agreements include such assistance obligations. COMPLIANCE CONSIDERATIONS: Compliance teams should audit the rights request intake process to confirm response time SLAs meet GDPR and CCPA requirements, that identity verification procedures are proportionate and do not create unnecessary barriers, and that erasure requests result in deletion across all processors and subprocessors, not just Ledger's primary systems.
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Given the sensitivity of data held by Ledger (home address linked to crypto wallet purchase), the right to request deletion is particularly relevant for customers concerned about their data remaining accessible following the 2020 breach.
You have the right to request a copy of all data Ledger holds about you, ask for corrections, or request deletion; exercising the deletion right can reduce your exposure if you are concerned about the security of your personal information.
ConductAtlas has identified this type of provision across 2 platforms. See the full comparison.
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