Ledger Multisig Privacy Policy

At Ledger, earning and maintaining our users' trust is a top priority. That’s why we are deeply committed not only to protect your privacy and securing your personal data, but also to be fully transparent about how we handle it. 

This Privacy Policy explains how we collect, use, and protect your personal data when you interact with us in different ways, and why we do so. 

Keep in mind that we can update this Privacy Policy whenever needed or if the law requires it. If you keep using our services after updates, you’re agreeing to the new terms. 

The last time we updated the policy was on September 2025.

What data do we collect?

In the table below, we aim to clearly explain what data we collect when you use Ledger Multisig, the reasons behind this data collection and how long we store your data.

Why do we collect your data?

Which data do we collect?

Which legal ground do we rely on?

For how long do we keep your data?

To run the service and report revenue

We collect:

- Your Safe account address, 

- Your signer wallet address, 

- Your transaction data (including transaction type, date, amount and hash, network, safe account balance, signer wallet signature).

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

We keep your data up to 10 years from the transaction date to comply with our legal obligations.

More details: We collect your Safe account and signer wallet addresses to operate Ledger Multisig, including to make your balance and transaction history available to you at any time. 

When you make a transaction using Ledger Multisig, we may share the transaction hash with technical service providers to broadcast the transaction and calculate the fee amount applicable. Your information may be stored by these providers for up to 5 days. 

If you choose to use third-party services, such as swap services (‘Third-Party Services’), we may share your IP address when necessary to verify that the Third-Party Services are available in your country. We do not keep this information. 

To measure the performance of Ledger Multisig and improve the service and your experience

We collect:

- Your User ID, 

- Your Safe account address,

- Your signer wallet address,

- Your clicks and actions (e.g. Safe account creation, pages visited, timestamp), 

- Your transaction data (including transaction type, date, amount, fees and hash, network, Safe account balance), 

- Your user properties (e.g. region, operating system type and version, Ledger device type and version).

We rely on your consent

We keep your data for 5 years from your last activity date

More details: With your express consent, we can use your data to measure the performance of Ledger Multisig and improve the service and your experience. We use a User ID to identify your device (mobile or desktop). 

You have the option to accept or decline this use of your data, and you can withdraw your consent at any time in the settings.

To run business analysis

We collect:

- Your Safe account address,

- Your balance.

We rely on our legitimate interest

We keep your data for 5 years

More details: We use your Safe account address to calculate the global amount of digital assets secured by Ledger Multisig. We are not able to link your Safe account address to any personal identifiable information, including the data you provide when ordering a product on our website.

With whom do we share your data?

Your information is available to our teams and our technical service providers, when necessary to provide our services, and to Third-Party Services providers, if you choose to use them.

Where do we store your data?

We usually store your data in France or within the European Economic Area (EEA). However, sometimes we may need to transfer it outside the EEA, for example, if a technical or Third-Party Service provider is based in another country. 

When this happens, we make sure your data stays protected. We only transfer it: 

Your rights

You may access your data in an interoperable format and request their rectification or deletion. You may also object to, or request the limitation of, the processing of your data. You can revoke your consent to the use of your data for analytics purposes in the settings.

To make any request regarding your data or if you have any question pertaining to their processing, please contact Ledger’s Data Protection Officer here. If you're not satisfied with our response, you can complain to your national data protection authority.

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