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 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 →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 European Economic Area, Switzerland, or the United Kingdom, you have the right to access, correct, or erase your personal data; the right to restrict or object to our processing of your personal data; the right to data portability; and, where our processing is based on your...
Depending on where you are located, you may have certain rights regarding your personal information, including the right to access, correct, delete, or restrict processing of your personal information, the right to data portability, and the right to object to or withdraw consent for certain processi...
For individuals in the United States, please also refer to our Notice For Individuals Residing In Certain US States below and the Consumer Health Data Policy.
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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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