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PRIVACY POLICY

Last update: November 2023

At Ledger, we are committed to creating products that provide the highest level
of security for your crypto assets but that also allow you to manage them
easily. To do this, we provide you with a software application (Ledger Live) and
websites (ledgerwallet.com and ledger.com) (our ‘Services’).

We can collect personal data about you when you use these Services. We have
created this Confidentiality Policy to explain what we do with it.



Please note: the vault.ledger.com website is not covered by this Confidentiality
Policy.

What is personal data?
Personal data (‘Data’) is information that makes it possible to identify you:

 * directly, such as your name or email address;
 * or indirectly, such as your customer number or IP address.


 1. When do we collect your data and why?
 2. Data collected through our websites
 3. Data collected through our Ledger Live application
 4. Data collected by third parties accessible from Ledger Live
 5. Who do we share your Data with?
 6. Where do we store your Data?
 7. How do we keep your Data secure?


WHEN DO WE COLLECT YOUR DATA AND WHY?

We collect your Data when you use our Services. 

We store your Data only for the time needed to carry out the operations for
which it was collected, except when we need to assert our legal rights or are
legally required to retain it for a different period of time. At the end of
these retention periods, your Data is erased or anonymised. 


DATA COLLECTED THROUGH OUR WEBSITES

User action Data collected Data usage Reason for processing (legal basis)
Retention period Purchase of a Ledger product Name, email address, delivery and
billing address, phone number, company name, intra-community VAT number, product
bought, delivery method and payment, order amount, currency Invoicing, delivery,
analytics and sending service notifications Performance of the contract you
agreed upon buying one of our products Active database: 3 months from delivery
of the product Archive: 10 years (accounting obligations) Request to receive
marketing emails (including our newsletter) Email address, campaign number, logs
Sending emails on our latest developments, promotions and customer surveys
Consent to receive marketing emails 3 years from the request Request sent to
customer services (on the dedicated platform or through social media) Name,
email and postal address, telephone number (for product exchanges), Handle used
on social media, content of our exchanges, identification document (if
verification is necessary) Processing the request, quality control, verifying
information is correct and preventing fraud Ledger’s legitimate interest 5 years
from the request Browsing our websites
Please note: We collect your Browsing Data using various technologies such as
cookies (for more information, please visit our Cookie Policy). Consent or
refusal to save cookies on your device Cookies are saved (or not saved) on the
device Legitimate interest 6 months from the user’s decision IP address,
operating system, browser, devices used, date and time of visit, URLs of
clickstream to, through and from our website, products viewed and searched,
download errors, duration of visit on certain pages, interaction between pages
Bug-fixing, analytics, combating fraud, personalising your experience,
displaying adverts on third-party websites Dependent on the purpose of the
cookies saved: - Legitimate interest for technical cookies - Consent for
functional, performance and advertising cookies The time needed to fulfil the
purpose of the cookies saved (for example, one session for session cookies)
Participation in customer surveys Name, age, email address, family situation,
profession, country, product opinion, comments Carrying out marketing studies,
improving our products and services Legitimate interest 6 months from the end of
the survey Request to be re-contacted on the subject of our B2B products Name,
company, role, email address, telephone number, country Making contact, sending
emails on our latest developments, promotions and customer surveys Legitimate
interest 5 years from the request Signing up to our affiliate programme Name,
email address, company, BTC address, identity document, intra-community VAT
number and proof of residence (where required). Managing the programme, sending
emails on the programme’s latest developments, remuneration Performance of the
contract you agreed with Ledger when signing up to the programme For as long as
the affiliate is a member of the programme, except in the event of prolonged
inactivity

Please note: your payment information is collected directly by our payment
providers. Ledger only has access to a truncated version of this information for
anti-fraud purposes.


DATA COLLECTED THROUGH OUR LEDGER LIVE APPLICATION

User action Data collected Data usage Reason for processing (legal basis)
Retention period Use of Ledger Live Device session identifier, IP address*,
clicks, actions (e.g. launching the application, use of transactional
functionalities, pages viewed), properties (e.g. type, version, language and
region recorded for your operating system), currency, time stamp, amount and
status of transactions, transaction identifier, identifier used by our partners
to identify you (when you use their services) Bug-fixing, analytics to improve
our products and services and identify additional services and functionalities
you might need, processing requests for assistance, finding and preventing
security problems, fraudulent activity and violations, optimising marketing
operations (e.g. information on the most-used functionalities) and sending
important information (e.g. security notifications). Legitimate interest 5 years
from collection Participating in our referral programme ETH address (for
authentication purposes only / data not stored), UUID, BTC address Managing the
programme, reward redemption Performance of the contract you agreed with Ledger
by participating in the programme Active database; for as long as the referrer
is a member of the programme, except in the event of prolonged inactivity
Archive: 10 years (tax and accounting obligations)

Please note: Ledger Live does not contain identifying information that allows us
to know your identity.(*Your IP address is only collected to be transmitted to
our partners when this information is required to provide their services, and is
not stored by Ledger) Ledger neither stores nor has access to your crypto assets
and private keys. We only provide ‘cold storage’ services.


DATA COLLECTED BY THIRD PARTIES ACCESSIBLE FROM LEDGER LIVE

Below are several concrete examples:
You use our partners’ services: information (like your name, date of birth,
postal address and IP address) can be collected by our partners (or by Ledger on
their behalf) to meet their anti-money laundering and customer-identification
obligations.
You are a validator for a proof of stake-type service: we display your
name/handle, the balances delegated or any information communicated on Ledger
Live.

Please note: Ledger is not responsible for the way in which our partners use
your Data. If you have any questions on this subject, please consult their
confidentiality policy.


WHO DO WE SHARE YOUR DATA WITH?

We share your Data with:

 * Our technical service providers who help provide the Services (e.g. delivery,
   online payments and combating fraud). 

 * Our subsidiaries, when they help provide the Services. 
 * Our partners who use your Data to offer you:
   * Services accessible from Ledger Live, or
   * Personalised adverts. The list of these partners can be found in our
     Cookies Policy. 

 * Other companies to which we could sell or assign all or part of our
   activities.

The administrative or legal authorities or any other authorised third party
where this data sharing is set out in law.

Please note: Ledger never sells your Data to third parties and we prohibit our
service providers from re-using it for their own behalf.


WHERE DO WE STORE YOUR DATA?

Your Data is stored in France, but we might have to transfer it to countries
located outside of the European Economic Area. 

We only transfer your Data to companies:

 * That are established in a country recognised by the European Commission as
   offering an adequate level of protection, or
 * With which we have signed the European Commission’s standard contractual
   clauses, or 
 * That commit to apply a code of conduct or a certification mechanism validated
   by the competent European authorities.


HOW DO WE KEEP YOUR DATA SECURE?

We implement all technical and organisational measures we deem necessary to
safeguard your Data at an appropriate level of security, including:

 * Payment information security: your payment information is encrypted using a
   secure commercial Internet protocol (TLS) and is never stored on our server. 
 * An awareness programme and employee training.
 * Encryption during exchanges and storage.
 * Regular audits of data hosting companies. 
 * Data redundancy for more resilience in the event of catastrophe.
 * Role-based authentication.
 * Two-factor authentication for our authorised contributors.
 * Continuous monitoring of the system.
 * Security assessments in line with industry standards.
 * Security tests and intrusion tests by independent third parties.

To assess the level of appropriate security, we take into account, among other
things, the nature of the Data and the risks its processing presents. Although
we strive to ensure an optimal protection of your Data, we would remind you that
transmitting information on the Internet is not entirely secure.

Please note: Ledger does not have access to your passwords, PIN codes and
recovery phrases. You are therefore solely responsible for keeping these
confidential.


YOU CAN EXERCISE YOUR RIGHTS OVER YOUR DATA – THIS IS HOW TO DO IT!

If you want to ... All you have to do is...

Withdraw your consent

 * Upon receiving marketing emails (including our newsletter) 
 * Upon the saving of cookies on your device

 

 * Click on the ‘Unsubscribe’ link in the footer of the emails you receive
 * Consult our Cookies Policy

Obtain a copy of your Data (in a format that can be used by third parties)

Make a request on our customer services website

Modify your Data if it is incorrect or incomplete

Make a request on our customer services website

Delete your Data (in certain cases)

Make a request on our customer services website

Object to the processing of your Data

 * Analytics and bug-fixing when browsing on Ledger Live
 * Other cases

 * Change the settings in Ledger Live
 * Make a request on our customer services website

Limit the processing of your Data (particularly if you do not want it to be
deleted)

Make a request on our customer services website

Upon receiving a request, we may have to ask you for an identity document if you
need to confirm your identity. If, after contacting us, you believe that your
rights have not been respected, you have the option of sending a complaint to
supervisory authority in your country.

MODIFICATIONS TO OUR CONFIDENTIALITY POLICY

We can modify our Confidentiality Policy if we deem it necessary or if the law
requires it, and you accept these modifications in continuing to use our
Services.

CONTACT

If you have any questions, do not hesitate to contact our Data Protection
Officer (DPO) by making a request on our customer services website.


STAY IN TOUCH

Announcements can be found in our blog. Press contact:
media@ledger.com

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PRIVACY PREFERENCE CENTER




 * YOUR PRIVACY


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YOUR PRIVACY

When you visit any website, it may store or retrieve information on your
browser, mostly in the form of cookies. This information might be about you,
your preferences or your device and is mostly used to make the site work as you
expect it to. The information does not usually directly identify you, but it can
give you a more personalized web experience. Because we respect your right to
privacy, you can choose not to allow some types of cookies. Click on the
different category headings to find out more and change our default settings.
However, blocking some types of cookies may impact your experience of the site
and the services we are able to offer.
More information

STRICTLY NECESSARY COOKIES

Always Active

These cookies are necessary for the website to function and cannot be switched
off in our systems. They are usually only set in response to actions made by you
which amount to a request for services, such as setting your privacy
preferences, logging in or filling in forms. You can set your browser to block
or alert you about these cookies, but some parts of the site will not then work.
These cookies do not store any personally identifiable information.

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PERFORMANCE COOKIES

Performance Cookies


These cookies allow us to count visits and traffic sources so we can measure and
improve the performance of our site. They help us to know which pages are the
most and least popular and see how visitors move around the site. All
information these cookies collect is aggregated and therefore anonymous. If you
do not allow these cookies we will not know when you have visited our site, and
will not be able to monitor its performance.

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FUNCTIONAL COOKIES

Functional Cookies


These cookies enable the website to provide enhanced functionality and
personalisation. They may be set by us or by third party providers whose
services we have added to our pages. If you do not allow these cookies then some
or all of these services may not function properly.

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TARGETING COOKIES

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These cookies may be set through our site by our advertising partners. They may
be used by those companies to build a profile of your interests and show you
relevant adverts on other sites. They do not store directly personal
information, but are based on uniquely identifying your browser and internet
device. If you do not allow these cookies, you will experience less targeted
advertising.

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These cookies are set by a range of social media services that we have added to
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