Privacy Policy

Last Updated: March 2026

Controller

Ledger SAS, 1 rue du Mail, 75002 Paris, France. Company registration number: 529 991 119. Data Protection Officer: [email protected]

Data We Collect

We collect the following categories of personal data when you use Ledger Live and our staking services:

• Account Information: Email address, username, and account preferences when you create or use an account.
• Device & Usage Data: Device type, operating system, app version, IP address, and how you interact with our services (e.g., features used, session duration).
• Transaction Data: Public blockchain addresses and transaction metadata visible on public ledgers when you use staking or other crypto features.
• Support Data: Communications with our support team, including tickets, chat logs, and any information you provide when seeking help.
• Marketing Preferences: Your choices regarding newsletters, promotional communications, and marketing consent.

Important: We do not collect your recovery phrase, private keys, or PIN codes. These remain exclusively on your device and are never transmitted to us.

Cookies

We use cookies and similar technologies for:

• Essential Cookies: Required for the website and app to function (e.g., session management, security).
• Analytics Cookies: To understand how visitors use our services and improve performance.

We do not use advertising cookies or sell data to third parties for advertising purposes.

Legal Bases

We process your personal data based on the following legal grounds under the GDPR and applicable laws:

• Contractual Necessity: Processing required to provide our services, fulfill our contract with you, and enable staking and wallet functionality.
• Legitimate Interests: Improving our services, ensuring security, preventing fraud, and communicating important updates.
• Legal Obligations: Compliance with applicable laws, regulations, and legal processes.
• Consent: Where we rely on your consent (e.g., marketing communications), you may withdraw it at any time.

Sharing

We may share your personal data with:

• Service Providers: Trusted partners who assist with hosting, analytics, customer support, and infrastructure, under strict data processing agreements.
• Legal Requirements: Authorities when required by law, court order, or to protect our rights and safety.
• Business Transfers: In connection with a merger, acquisition, or sale of assets, subject to the same privacy commitments.
• With Your Consent: Where you have given explicit consent for specific sharing.

We never sell your personal data.

Retention

We retain your data for as long as necessary to fulfill the purposes described in this policy:

• Account Information: While your account is active and for a reasonable period after closure.
• Usage Data: Typically 24–36 months for analytics and improvement purposes.
• Support Records: Up to 5 years for legal and quality assurance purposes.
• Marketing Data: Until you unsubscribe or withdraw consent.
• Blockchain Data: Note that data recorded on public blockchains is permanent and cannot be deleted by Ledger.

Security

We implement industry-standard measures to protect your data:

• TLS Encryption: All data in transit is encrypted using TLS.
• Access Controls: Strict access policies and role-based permissions for our staff.
• Security Audits: Regular audits and assessments of our systems and practices.
• Hardware Security: Your private keys and sensitive data remain on your Ledger device and are never transmitted to our servers.

Your Rights

Under applicable data protection laws (including GDPR), you have the right to:

• Access: Request a copy of the personal data we hold about you.
• Correction: Request correction of inaccurate or incomplete data.
• Deletion: Request deletion of your personal data where legally applicable.
• Portability: Receive your data in a structured, machine-readable format.
• Objection: Object to processing based on legitimate interests.
• Restriction: Request restriction of processing in certain circumstances.
• Withdrawal: Withdraw consent where processing is based on consent.

To exercise these rights, contact us at [email protected]. We will respond within 30 days.

Changes

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We will notify you of material changes via email or an in-app notice. The "Last Updated" date at the top indicates when this policy was last revised.

Contact

For privacy-related inquiries:

• Email: [email protected]
• Data Protection Officer: [email protected]
• Address: Ledger SAS, 1 rue du Mail, 75002 Paris, France