Data collected on the Ledger Wallet™ app

To note:

When you install the Ledger Wallet app on your phone and/or your computer, we generate an equipment ID to identify you. You have a different equipment ID for your phone and computer. We generate a new equipment ID when you reinstall Ledger Wallet. • By default, we do not link your wallet address to your equipment ID, unless otherwise specified in this Privacy Policy. • We cannot link your different wallet addresses together. • We are not able to link your wallet address to the information you provide when you purchase products on our website.

To display your accounts, balance and transaction history

We collect:  • Your wallet address • On-chain data

We rely on the Terms of Use your accepted when you signed up for Ledger Wallet.

We do not keep this data.

More details: When you connect to the Ledger Wallet app, we collect logs which include your wallet address. We input your wallet address in our explorers to make your balance and transaction history available to you at any time, but we do not store this information.

To run market analyses

We collect:  • Your wallet address • On-chain data

We rely on our legitimate interest.

We keep this data for five years after your most recent connection to Ledger Wallet.

More details: We use the wallet addresses included in Ledger Wallet logs to link your wallet address with public on-chain data to conduct various analyses. For example: to calculate the global amount of digital assets we secure.

We know how much assets in total are held by Ledger Wallet users but:  • We do not know how much assets you have personally. • We cannot link your different wallet addresses together. • We are not able to link your wallet address to any personal identifiable information, including the data you provide when you purchase products on our website.

To manage the referral program (reward redemption and notifications)

We collect:  • Your equipment ID  • Your wallet address • The amount of your rewards • The date of the payment  • The order ID of the user you have referred

We rely on the Terms & Conditions you accepted when you signed up for the program.

We keep your data for ten years to comply with our legal obligations. Your data is archived two years after the last reward payment.

More details: We also collect your ETH address for authentication purposes, but we do not store it.

To measure the performance of Ledger Wallet and our marketing campaigns, and personalize your experience through in-app content and push notifications

We collect:  • Your equipment ID • Your signer ID • Your user properties (e.g. type of tokens owned, language) • Your terminal properties (e.g. type and version of operating system, app version) • Your wallet properties (e.g. firmware version, signer model) • Clicks and actions you make in the app (e.g. launch of the application, pages viewed) • Notifications (push notifications, content cards and in app modals sent and opened)

We rely on your consent. You can consent to the use of your data by turning on ‘App Performance’ and/or ‘Personalized Experience’ on the Ledger Wallet app.

We keep your data for five years after your most recent connection to Ledger Wallet.

More details: • We do not collect any personal identifying information (such as your name or email address). • We do not collect information regarding the value of your assets. • We do not link your data with data collected from other companies’ apps or websites for targeted advertising or advertising measurement purposes. • We do not share your data with data brokers.

To identify you, we use: • Your equipment ID, which is the internal ID generated to identify the phone or computer on which you install Ledger Wallet.  • Your signer ID, which is the internal ID we generate to identify each Ledger signer. This ID is not derived from your private key. Ledger has zero access to your private keys.

We use both of these IDs to understand how you use Ledger Wallet across all relevant devices (phones and computers you use to access Ledger Wallet, and the Ledger signers you use to complete transactions).  If you consent to the use of your data for analytics purposes (‘App performance’ toggle in the settings): • We use your data to measure Ledger Wallet’s performance and improve your Ledger Wallet experience. • We also analyse your interactions on Ledger Wallet (such as clicks, mouse movements, and scrolling during each session). We anonymize any keystrokes and the content of the pages you visit. Your data is only stored for thirty days. These reports help us fix bugs and improve the user experience.

If you consent to the use of your data for personalization purposes (‘Personalized experience’ toggle in the settings), we use your data to send you personalized recommendations and content that match your preferences, and to measure the performance of our marketing campaigns. If you connect to Ledger Wallet from a dApp, with your consent, we collect analytics data to measure the service’s performance and improve your experience. We collect data such as: event ID and type, dApp ID, list of accounts and configuration (encrypted), token and network. You have the option to accept or decline the use of your data, and you can withdraw your consent at any time in the settings of our Ledger Wallet app and when you connect to Ledger Wallet from a dApp.

To fix bugs

We collect: 

• Your equipment ID,  • Your crash logs and reports

We rely on our legitimate interest.

We keep your data for ninety days.

More details: You can opt out at any time via the settings in Ledger Wallet.

To operate Ledger Sync and synchronize your crypto accounts across all your phones and computers

We collect: • Account name • Public key • Balance • Metadata (e.g. account color, derivation path)

We rely on your consent.

We keep your data until you disable Ledger Sync.

More details: If you enable Ledger Sync in Ledger Wallet, we can synchronize your crypto accounts across all relevant devices (phones and computers you use to access Ledger Wallet). Your data is encrypted and stored on our servers. We use your public key to identify your portfolio. Please note that we cannot decrypt your data, and it is impossible to derive your private key from your public key. You can withdraw your consent at any time by disabling Ledger Sync in the app settings.

To operate Transaction Alerts

We collect: • Your equipment ID • Your wallet address • Transactional data (e.g. hashed transaction, network)

We rely on your consent.

We keep your data for one week.

More details: If you enable Transaction Alerts in Ledger Wallet, we can link your equipment ID to your wallet address so that we can notify you when your transaction is completed. Your wallet address is hashed and then deleted after seven days. You can withdraw your consent at any time by disabling Transaction Alerts in the app settings.

To note:

• When you use Third-Party Services through Ledger Wallet (e.g. you buy or sell crypto assets, or create a Cash-to-Stablecoin account), you are stepping outside our ecosystem. These services may ask you to provide information such as your name, date of birth and postal address, to meet their legal requirements. We are not responsible for how these providers handle your data. • For more information, check our Ledger Wallet Terms of Use and make sure to read the relevant Third-Party Service Providers’ Privacy Policy to have full control over your data. They might have different policies including in terms of data retention.

To display the pricing quotes of selected Third-Party Service Providers integrated in Ledger Wallet.

We collect:  • Your transaction data (e.g. transaction amount, currency, payment method, country and wallet address) • Your IP address

We rely on the Terms of Use you accepted when you signed up for Ledger Wallet.

We do not keep this data.

More details: When you want to use Third-Party Services, we share certain transaction data with Third-Party Service Providers. These providers use your data to craft pricing quotes that we display to you. 

We may also use your IP address or share it with Third-Party Service Providers to verify what services are available in your country. We do not keep this information.

To comply with specific sanctions laws by blocking transactions and filtering IP addresses

We collect:  • Your wallet address • Your IP address

We rely on our legal obligations.

We do not keep this data.

More details: We must follow all sanctions laws that apply. This means we block any transactions that involve sanctioned wallet addresses and prevent users located in countries subject to comprehensive sanctions from accessing our services. To this end, we do not store any information.

To track and report revenue generated through integrated Third-Party Services in Ledger Wallet

We collect your transaction data (e.g. transaction amount, currency, time stamp, status, ID and hash, fee, trade or payment method, country, wallet address and blockchain)

We rely on the Terms of Use you accepted when you signed up for Ledger Wallet.

We keep specific transaction data for ten years to comply with our legal obligations.

More details: We collect transaction data to report completed transactions. This data either comes from blockchain explorers or directly from Third-Party Service providers.

If you use the Buy feature and have agreed to app performance in Ledger Wallet, we can temporarily link the transaction data from Third-Party Service providers to your equipment ID for up to five days. This helps us confirm that your transaction was successful and improve our service quality. After five days, this link is deleted. We do not link this data with the equipment IDs for opted-out users.