Both Ledger and Global-e are identified as independent data controllers for purchaser personal data, each processing data under separate privacy policies and subject to GDPR and French data protection law. The document directs consumers to separate privacy policies for Ledger and Global-e, and additionally introduces Klarna's separate privacy policy for purchasers using Klarna payment.
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 provision establishes that at least two separate data controllers (Ledger and Global-e) process purchaser personal data in connection with each transaction, with additional data sharing to Klarna and third-party payment processors where those payment methods are selected. Data subject rights requests and privacy complaints must be directed to the appropriate controller entity under this structure.
Interpretive note: The document does not specify whether a GDPR Article 26 joint controller agreement exists between Ledger and Global-e, and the allocation of data controller responsibilities between entities is not fully detailed in the document text.
Under this provision, purchaser personal data is processed by both Ledger and Global-e as independent data controllers, with separate privacy policies governing each entity's processing. Purchasers using Klarna as a payment method additionally share personal data with Klarna under Klarna's own privacy policy, for which the document states Global-e accepts no responsibility.
Cross-platform context
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Compare across platforms →"As part of its activities, Ledger (as well as Global-e, see Global-e Terms and Conditions) may process and collect personal data about you ("Data"). As data controller, Ledger (and Global-e - see below Global-e Terms of Sale) process the Data in compliance with the provisions of French law no. 78-17 of 6 January 1978, known as the "loi informatique et libertés", as amended, and the General Data Protection Regulation (Regulation (EU) 2016/679).Excerpt from Ledger's Terms of Sale
(1) REGULATORY LANDSCAPE: This provision engages GDPR Articles 13, 14, 24, and 26 governing data controller obligations, transparency disclosures, and joint controller arrangements.
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The provision establishes that at least two separate data controllers (Ledger and Global-e) process purchaser personal data in connection with each transaction, with additional data sharing to Klarna and third-party payment processors where those payment methods are selected. Data subject rights requests and privacy complaints must be directed to the appropriate controller entity under this structure.
Under this provision, purchaser personal data is processed by both Ledger and Global-e as independent data controllers, with separate privacy policies governing each entity's processing. Purchasers using Klarna as a payment method additionally share personal data with Klarna under Klarna's own privacy policy, for which the document states Global-e accepts no responsibility.
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