Trezor and Ledger are the two most popular brands in the hardware wallet niche. Both manufacturers have their positives and negatives, but what do their Terms of Service agreements and Privacy Policies say?
Yes, those boring lists of rules you are asked to accept and must follow to keep using a service. Since most people don’t like reading those, I have decided to take a look at the ones provided by both Trezor and Ledger and highlight some of the most interesting findings, be it good or bad. I will copy/paste parts of the TOSs and Privacy Policies and offer my views on the content.
Additionally, I find Foundation Devices very appealing, so I will also take a look at them.
Let’s get straight to it and look at the Terms and Conditions.
TrezorTrezor’s official website links to 3 different TOS documents:
Website Terms of UseTrezor Shop Terms and ConditionsTrezor Suite Terms and ConditionsWebsite Terms of UseWe are not responsible for the content of any sites that may be linked to from the Website or any bulletin board or forum associated with us or the Website.
In addition, a link to any other website does not imply that we endorse or accept any responsibility for the content or use of such other website. In no event shall any reference to any third party or third-party product or service be construed as our approval or endorsement of that third party or of any product or service provided by a third party.
In other words, all content you find on Trezor’s website is there for informational purposes only. Trezor provides no guarantees about the quality, security, or accuracy of the information or the services.
Under no circumstances shall any information on the Website or provided to you by us constitute financial, investment or professional advice, unless explicitly stated so.
Just because a particular site, coin, or service is mentioned doesn’t mean Trezor is advertising or suggesting people should invest in it.
We are not obliged to fulfill any of our obligation under these Terms of Use, if temporarily or permanently prevented by vis maior - event or circumstance that is extraordinary, unforeseeable and unpreventable by usual means and with proper care, and that occurred independently of our will; such vis maior event is, among other things, a serious hacking attack or power shortage.
Vis major is described as “
natural occurrences that cause damage and are neither caused nor preventable by humans.” Trezor considers a “serious hacking attack” (something caused by humans that can be prevented by proper security measures) as vis major. Trezor is not responsible for any issues caused by hacking incidents on the website.
Trezor Shop Terms and Conditionsyou are entitled to withdraw from the Contract within fifteen (15) days from the date on which you or a third party named by you who does not deliver the products has taken the possession of the products.
If you are unsatisfied with your Trezor HW, you can return it within 15 days of receiving it.
In order to qualify for a full refund, the products must be returned unused and sealed in the original packaging, with all the original materials provided in their complete condition.
You will only receive a full refund if the package wasn’t opened and the device wasn’t used.
We shall not be responsible for any incidental or consequential damages which are incurred and/or have occurred in connection with the product or its purchase. We assume no responsibility for any loss or costs due to a third party's or the customer's loss of profit, or any other indirect cost or losses, however incurred.
Trezor is not responsible for any losses you incur when using their devices. If you lose money for any reason, you can’t hold Trezor accountable.
The next part concerns returning defective products and who bears the cost for those.
The costs incurred in connection with returning the product to us and back to you shall be always borne by you. If we find out that the product was defective or damaged and the damage or defect is covered by the Liability for Defects and/or Commercial Warranty, you are entitled to a refund of the necessary shipping costs.
Whenever you return a device under warranty that is not working as it should, you have to pay for the shipping fees. After Trezor inspects the device, they will refund the shipping charges only if the damage is covered by the warranty agreement.
If we conclude within the product inspection that the returned product was not damaged or defective or that the damage or defect is not covered by the Liability for Defects and/or Commercial Warranty, the costs for returning the product to you shall be due in advance, before we send the product back. In such an event and at our sole discretion, we might offer you a discount on a new product purchase as compensation for not returning the item to you.
If Trezor concludes that the device is not broken or the damage is not covered by the warranty, the shipping costs will not be returned, and you have to pay additional shipping fees to ship the product back to you.
Trezor Suite Terms and Conditions…we strongly recommend creating a recovery seed and setting up a PIN as described below to keep your cryptocurrency coins safe. If you continue using the Device with Suite without further protection and back up, we shall assume no liability for any damage incurred as a consequence thereof.
This is a warning to create a recovery seed and a PIN to keep your crypto safe.
Personal opinion: knowing that Trezor has an unsolvable vulnerability that can be mitigated by extending the seed with a passphrase, it would be desirable that Trezor mention the importance of using a passphrase.
You may at any time after your Device initialization create a recovery seed – a chain of randomly selected words. Recovery seed enables you to recover the information stored on your Device. Without a recovery seed, you may not recover information stored in your Device and your wallet and your cryptocurrency coins stored in the wallet may be lost forever.
Is it possible to use a Trezor for receiving and sending coins without having previously created a seed? This part of their TOS makes it sound like it is. If so, it’s something I really don’t like. It reminds me of a case of a user who made a thread a few years ago in which he lost access to his coins because his Coinbase wallet allowed him to start using it before creating a recovery phrase.
We shall not under any circumstances be held liable to you for any direct, indirect, special, consequential, punitive or any other damages and costs including but not limited to loss of profit, loss of revenue, loss of business opportunity arising out of or in connection with your access and use or inability to access and use of Suite services.
Trezor is not responsible for any losses that might result from using Trezor Suite.
Under no circumstances shall any information within Suite and/or Website or provided to you by us constitute financial, investment or professional advice, unless explicitly stated so.
Nothing you see written, mentioned, or promoted in the Trezor Suite shall be considered a good investment.
You must not endeavor to abuse any respective cryptocurrency network including but not limited to sending the cryptocurrency coins to multiple addresses at once (double spending).
You are not allowed to double-spend transactions with the Trezor Suite. Probably not to others or yourself.
LedgerSimilarly to Trezor, Ledger also has 3 different Terms of Use on its official website:
Sales Terms and ConditionsWebsite Terms of UseLedger Live Terms of UseDepending on the payment method used for the purchase, a service provider called Flow can be utilized. If that is the case, the following TOS will be in effect:
International Order Terms and Conditions When Flow is the Seller of the Goods Sales Terms and ConditionsThese terms are in effect when the purchase is made via Visa, Mastercard, American Express, Bitpay, and PayPal. If the customer uses any other payment method, Flow’s TOS applies.
In accordance with the provisions of Article L. 221-18 of the French Consumer Code, you have the right to withdraw from the contract within a period of fourteen (14) days without reason and without bearing any costs, except for the costs of returning the Product, if necessary. The aforementioned period runs from the day of receipt of the Product by you or by a third party, other than the carrier, designated by you.
If you are unsatisfied with your Ledger wallet, you have the right to return it within 14 days of it being delivered to you for any reason. You will get your money back, but you might be required to pay the return shipping costs.
The costs of return of the Product are at your own expense. You must return the Product in perfect condition in its original packaging.
You can even return a used device (since they don’t mention that the box can’t be opened) as long as it’s in perfect condition and in the original box.
We will reimburse you for all amounts received, including delivery charges, within fourteen (14) days from the date we were notified of your withdrawal decision, but we may defer the refund until we have received the Product.
This statement is a bit contradictory compared with the previous one above, which says “
you have the right to withdraw from the contract within a period of fourteen (14) days without reason and without bearing any costs, except for the costs of returning the Product, if necessary". Here it’s said they
will reimburse you for all costs, but apparently, that’s not always the case.
TO THE FULLEST EXTENT PERMITTED BY LAW, LEDGER DISCLAIMS ANY AND ALL LIABILITY FOR LOSS OF PROFITS, INCOME, VALUE OR DATA, OR INDIRECT, SPECIAL, CONSEQUENTIAL, EXEMPLARY OR PUNITIVE DAMAGES.
Ledger is not responsible for any losses you incur using their products. That includes the loss of customer data. I wonder if they added this “data” part to the TOS following their data leak fiasco!?
TO THE FULLEST EXTENT PERMITTED BY LAW, LEDGER’S TOTAL LIABILITY FOR ANY CLAIM ARISING FROM THESE TC’s, INCLUDING ANY IMPLIED WARRANTIES, IS LIMITED TO THE AMOUNT YOU PAID TO PURCHASE THE PRODUCT.
If I understood correctly, if you lose all your coins with a Ledger HW, the company is only liable to (maybe) compensate you for the amount you spent to purchase your hardware wallet.
YOU EXPRESSLY RELIEVE LEDGER, ITS AFFILIATES, AGENTS AND EMPLOYEES FROM ANY AND ALL LIABILITY AND GUARANTEE THEM AGAINST ANY CLAIM, PROCEEDINGS OR LEGAL ACTION ARISING FROM OR RELATED TO THE USE OF THE PRODUCTS OR FOLLOWING A BREACH OF THESE TC’s, INCLUDING ANY LIABILITY AND FINANCIAL CHARGE RESULTING FROM CLAIMS, LOSSES OR DAMAGES, PROCEEDINGS AND JUDGMENTS, AND LEGAL AND ATTORNEY’S FEES.
This again confirms that Ledger is not to be held responsible for any losses the customer incurs by using Ledger HWs.
Website Terms of UseThe information included on the Site does not constitute legal, financial or investment advice and is not intended as a recommendation for buying, trading or selling crypto assets. It is recommended to seek advice from legal and financial experts before starting buying, trading or selling crypto assets. Ledger SAS, Ledger Technologies Inc., and all other companies mentioned on the Site will not be responsible for the consequences of reliance upon any opinion or statement contained herein or for any omission.
Additionally:
Any loss of data, crypto assets or profit is your sole responsibility.
No information on the site shall be considered as a recommendation to invest in a particular asset, and Ledger is not responsible for the results of any such actions by the customers.
Ledger Live Terms of UseNo liability... For the avoidance of doubt, and notwithstanding the generality of the Limitation of Liability under these Terms, you hereby agree that Ledger shall have no liability for any loss that incurs as a consequence of the risks highlighted in this section and/or your failure to follow the recommendations herein.
Ledger is not responsible for any losses you incur while using Ledger Live.
Ledger may perform code reviews and conduct security audits of Device Applications available on Ledger Live Manager, which does not constitute any kind of endorsement nor any guarantee that those applications are risk-free. Ledger does not warranty that Device Applications will be maintained over time and reserves the right to restrict or suspend access to them from Ledger Live for any reason for as long as deemed necessary.
This refers more to 3rd-party applications. Ledger does not guarantee they are safe to use, and they have the right to suspend and remove them from the Ledger Live Manager if they see fit.
Ledger is not responsible for the content, accuracy, security, availability, any performance, or failure to perform of the Third Party Services or any issue in relation with the use of Third Party Services. Ledger does not provide any guarantees that access to Third Party Services will not be interrupted or that there will be no delays, failures, errors, omissions, corruption or loss of transmitted information, data or funds, and Ledger shall not be liable for any such Third Party Services. You agree to use the Third Party Services at your own risk. It is your responsibility to review the third party’s terms and policies before using a Third Party Service.
And:
To the extent you choose to use such Third Party Services, you acknowledge that Ledger is not responsible for any issue in relation with the use of such Third Party Services, including any loss of funds.
Ledger is neither responsible nor liable nor guarantees for the 3rd-party services they have partnered with in Ledger Live (swaps, NFTs, buying, selling, exchanging coins, staking, etc.). They should be used at your own risk.
Regarding staking, Ledger Says:
No guarantee of Rewards. LEDGER DOES NOT GUARANTEE THAT YOU WILL RECEIVE STAKING REWARDS OR ANY STAKING REWARD RATES. SUCCESSFUL TRANSFER OF THE REWARDS IS SUBJECT TO THE PROOF-OF-STAKE NETWORKS AND IS NOT UNDER LEDGER’S CONTROL.
And:
No custody. Ledger will never take custody over any of your rewards or assets and Ledger has no responsibility or control over any Proof-of-Stake network on which Ledger may exercise validation rights delegated by you.
Ledger doesn't guarantee nor are they responsible for paying out staking rewards. Ledger also doesn't have custody of staked coins, nor can they take control of them.
YOU EXPRESSLY UNDERSTAND AND AGREE THAT LEDGER AND ITS DIRECTORS AND EMPLOYEES SHALL NOT BE LIABLE TO YOU FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL OR EXEMPLARY DAMAGES, INCLUDING, BUT NOT LIMITED TO, DAMAGES FOR LOSS OF PROFITS, GOODWILL, USE, DATA, COST OF PROCUREMENT OF SUBSTITUTE GOODS OR SERVICES, OR OTHER INTANGIBLE LOSSES…
Ledger states one more time they are not responsible for any losses or damages that could result from the use of Ledger Live.
However, there is also this:
THE ABOVE LIMITATIONS DO NOT APPLY IN RESPECT OF LOSS RESULTING FROM (A) LEDGER’S FRAUD, WILFUL MISCONDUCT OR GROSS NEGLIGENCE, WILFUL MISCONDUCT OR FRAUD; OR (B) DEATH OR PERSONAL INJURY.
I wonder if having their servers hacked or data stolen by their employees and or partner companies can be considered gross negligence? Or if a person gets physically attacked and robbed due to data released about them following Ledger's data leak?
Foundation DevicesFoundation Devices’ TOS can be found below:
Terms of UseFoundation Devices further reserves the right any time after receipt of your order, without prior notice to you, to supply less than the quantity you ordered of any item.
Foundation doesn’t provide additional information for this part. But according to their TOS, if you order 10 devices, they have the right to ship to you only 7, for example, for any reason, and they aren’t required to inform you about this.
IN NO EVENT WILL WE (AND OUR SUPPLIERS) BE LIABLE TO YOU OR ANY THIRD PARTY FOR ANY LOST PROFIT OR ANY INDIRECT, CONSEQUENTIAL, EXEMPLARY, INCIDENTAL, SPECIAL OR PUNITIVE DAMAGES ARISING FROM OR RELATING TO THIS AGREEMENT OR YOUR USE OF, OR INABILITY TO USE, THE SITE, EVEN IF WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. ACCESS TO, AND USE OF, THE SITE ARE AT YOUR OWN DISCRETION AND RISK, AND YOU WILL BE SOLELY RESPONSIBLE FOR ANY DAMAGE TO YOUR COMPUTER SYSTEM OR LOSS OF DATA RESULTING THEREFROM.
And:
You hereby release and forever discharge us (and our officers, employees, agents, successors, and assigns) from, and hereby waive and relinquish, each and every past, present and future dispute, claim, controversy, demand, right, obligation, liability, action and cause of action of every kind and nature (including personal injuries, death, and property damage), that has arisen or arises directly or indirectly out of, or relates directly or indirectly to, any interactions with, or act or omission of, other Service users or Third Party Sites & Advertisements.
Foundation can’t be held responsible for any and all damages caused to you for using their website and services.
NOTWITHSTANDING ANYTHING TO THE CONTRARY CONTAINED HEREIN, OUR LIABILITY TO YOU FOR ANY DAMAGES ARISING FROM OR RELATED TO THIS AGREEMENT (FOR ANY CAUSE WHATSOEVER AND REGARDLESS OF THE FORM OF THE ACTION), WILL AT ALL TIMES BE LIMITED TO THE GREATER OF (A) ONE HUNDRED US DOLLARS ($100) OR (B) AMOUNTS YOU’VE PAID FOUNDATION DEVICES UNDER THIS AGREEMENT IN THE 12 MONTHS PERIOD IMMEDIATELY PRECEDING THE DAY THE CLAIM AROSE (IF ANY). THE EXISTENCE OF MORE THAN ONE CLAIM WILL NOT ENLARGE THIS LIMIT. YOU AGREE THAT OUR SUPPLIERS WILL HAVE NO LIABILITY OF ANY KIND ARISING FROM OR RELATING TO THIS AGREEMENT.
If Foundation is found guilty of any damages caused to the user, said user will be compensated with no more than $100 or the amount they paid for their hardware wallet(s).
Privacy PoliciesWith the TOS agreements out of the way, we can now check out what is stated in the Privacy Policies of the 3 companies.
TrezorTrezor’s Privacy PolicyThe collection of your personal data in connection to the use of the Website and access to and use of the Services is as limited as possible. We usually collect and process only the following personal data:
- your name, email address and any other personal data you provide us with when filling out one of the contact forms on the Website (such as Enterprise solutions, Affiliate and other).
- Information and feedback we receive from you that helps us improve our Website and your user experience.
Trezor collects and stores as little personal data as possible. At a minimum, they collect info such as your name, email address, and any other data you submit through a form on the website or other Trezor services.
In connection with provision of the above support, we collect and process also the following personal data:
- your email address;
- content of the emails you send us and other personal data related to our communication.
In case a customer contacts Trezor support, email addresses and other personal data related to the case will be collected.
When a purchase is made on the Trezor shop, the following data is collected:
- your delivery address to ensure correct delivery of the products;
- your email address and an encrypted version of your user profile password (we do NOT keep any records of the full representation of your password);
- information about the status of your orders, requests under your warranty and refund rights and logs of your bitcoin payments.
Trezor collects and stores your shipping address, email address, your account password in encrypted form, and bitcoin payment info.
Our Website contains links to payment gateways provided by third parties which you may use in order to make payments while using the Services. You will have to fill in your personal data related to the
payment when using the payment gateways.
These data are processed by the respective provider of the payment gateway as a data controller and the data processing is governed by terms and conditions and privacy policy of the payment gateway provider.
If payments are made through a particular payment gateway, that service provider will collect and store your personal data. Trezor has no control over what this 3rd-party collects and/or stores.
In order to fulfill our legal obligations such as those arising out of accounting laws, we may store certain parts of your personal data for various time periods as stated in those laws.
And:
We process and store your personal data only for the time necessary to meet the purposes of its processing specified above, or for the time consented by you, or for the time that is either necessary to comply with our obligations under the applicable law or set forth by the applicable law or in accordance therewith. We comply with the mandatory rules for data archiving.
Depending on the reasons for data storage and applicable laws, your personal data will be stored for various time periods. Exact numbers are not mentioned.
Regarding data storage when ordering from the Trezor shop:
We will process such personal data only for such a period of time that allows us to deliver you the products and fulfill our other legal obligations connected to the sale of the products. We anonymize this data no later than 3 months after the sale of the product to the fullest possible extent and store them only in this anonymized form in case you contact us with an issue so we can verify that the data you provide us with, after anonymization, match the anonymized database inputs. After the expiry of the warranty period, we delete the data altogether.
Customer data of those buying from the official shop is stored up to 3 months. After that, the information gets anonymized and stored in anonymous form for the duration of the warranty (2 years). After the warranty expires, Trezor deletes customer data.
We take care of your personal data security and so we choose the partners to whom we entrust your personal data very carefully.
Trezor shares your personal data with partners they see fit.
The following parties can get access to customer data:
- persons who provide us with the technological services or technology operators that we use to
provide our services;
- persons who provide our services and websites with security and integrity and who regularly test such security and integrity;
- providers of accounting, legal and administrative services;
- our staff
The third point refers to government agencies and tax offices, for example. No information about which staff members can access customer data or why is available.
Another possible recipient of your personal data, who may receive your personal data from us mainly in connection with the cryptocurrency buy, sell and exchange services is a company of the SatoshiLabs Group group of companies, the commercial company Invity.io s.r.o.
Invity.io is a service for rating and comparing crypto exchanges and their exchange rates. This is another company that can receive the personal data of Trezor users who use the in-app exchange service. Trezor’s wording is “mainly,” not “exclusively” or “solely.”
When collecting, storing and processing personal data we sometimes may use personal data processors such as Google, which under some circumstances transmit your personal data to third countries. In such an event we always make sure such transmission is compliant with the Regulation. In particular, we specify that the personal data may be transmitted to the United States of America and in such event the transmission is compliant with the “Privacy Shield” program.
Trezor may use the services of Google or other companies in connection with data storage. One of the countries this data may be sent to is the United States.
On our Website we use cookies to analyze traffic and to personalize content and ads. We also use cookies for other purposes, such as to enable us to simplify the logging on process for registered users, to help ensure the security and authenticity of registered users, to provide mechanisms for online shopping and to enable traffic monitoring under our Affiliate Program. We will, as a data controller, collect, store and process any personal data collected by such cookies (the personal data may include your IP address, information about your activity on our website, information about your advertisement preferences etc.)
Trezor uses cookies on its website for various reasons: website traffic analysis and monitoring, personalized ads, simpler login process, etc. The data collected through these cookies are also stored, including IP addresses and ad preferences.
In relation to the personal data you shall have in particular the following rights:
- a right to withdraw your consent at any time;
- a right to correct or make additions to the personal data;
- a right to request restrictions to processing of your personal data;
- a right to object or complain against processing of your personal data under certain circumstances;
- a right to request transfer of your personal data;
- a right to access your personal data;
- a right to be informed of the personal data security breach under certain circumstances;
- a right to request deletion of your personal data (a right to be „forgotten“) under certain circumstances; and
- other rights set forth in Act No. 110/2019 Coll., on personal data processing (Personal Data Protection Act) and the Regulation.
Customers can request to have their personal data deleted, corrected, restricted, etc. They have the right to access their own data and be informed of data breaches and leaks. Some of these actions depend on the circumstances.
LedgerLedger’s Privacy PolicyWe 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.
Ledger stores customer data for as long as it is required for normal operations or legal rights. Once the objectives have been achieved, the data is deleted or anonymized.
This is the type of data collected and stored in connection to purchasing on the Ledger store:
Name, email address, delivery and billing address, phone number, company name, intra-community VAT number, product bought, delivery method and payment, order amount, currency.
Retention period:
Active database: 3 months from delivery of the product Archive: 10 years (tax and accounting obligations).
This data is stored for 3 months in one database. After that, it gets moved to an archive and held there for 10 years.
The following data is collected and stored for 5 years after making contact with Ledger support via the official site or 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).
Personal data is also collected and stored for various periods for marketing emails, website browsing, referral program, affiliate program, etc.
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.
Payment information is collected by the payment providers. Ledger can only access a small part of this data.
Ledger also collects user information through its Ledger Live application. This is the data that is collected:
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).
As reasons for collecting all this data, they state:
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).
This data is stored in Ledger servers for 5 years from collection.
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.
Ledger says they don’t collect or store identifying information. The collected IP addresses are provided to third parties who offer various services within Ledger Live.
If you use partner services within Ledger live, then:
…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.
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:
o Services accessible from Ledger Live, or
o 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.
Ledger can share your data with government and tax agencies. And “other companies” could also obtain your data without providing more information on the type of other companies.
Additionally:
Ledger never sells your Data to third parties and we prohibit our service providers from re-using it for their own behalf.
Your Data is stored in France, but we might have to transfer it to countries located outside of the European Economic Area.
Foundation Devices Foundation Privacy PolicyPersonal information that is collected by Foundation includes:
…your first and last name, email and mailing addresses, phone number, credit card information, products purchased and, if purchasing using Bitcoin, the information collected in connection with such payment.
…information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
… your city, state, country of residence, and postal code.
… information about payments to and from you and other details of products or services you have purchased from us.
Information we obtain from social media platforms. We may maintain pages for our Company on social media platforms, such as Facebook, LinkedIn, Twitter, Google, YouTube, Instagram, and other third party platforms.
Information we obtain from other third parties. We may receive personal information about you from third-party sources.
Personal information is also collected through cookies, namely:
We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Service, including but not limited, your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area; information about your use of and actions on the Service, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access; and other personal information. Our service providers and business partners may collect this type of information over time and across third-party websites and mobile applications.
This data includes the type of device you use, your operating system, device model, IP address, location information, etc.
The collected information is used in various ways. Some of the interesting points include:
We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate...
And:
We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
Your personal information could be shared with government agencies, police, tax authorities, etc. The data is anonymized and shared with 3rd-parties.
We do not share your personal information with third parties without your consent…
But:
except in the following circumstances…
We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate the Service…
We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers…
We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
Foundation needs your consent to share your personal data, but not in all instances. They are free to share your data with 3rd-party service providers, partners, individuals, etc. Your data can also be sold together with other company assets in case of bankruptcy, mergers, and similar business deals.
We are headquartered in the United States and have service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country.
Customer information is stored in the USA but can also be transferred to other countries and territories.
SourcesAll information was obtained from the following official sources:
https://shop.trezor.io/static/shared/about/terms-of-use.pdfhttps://shop.trezor.io/static/shared/about/terms-conditions.pdfhttps://data.trezor.io/legal/wallet-terms.pdfhttps://shop.ledger.com/pages/terms-and-conditionshttps://shop.ledger.com/pages/website-terms-of-usehttps://shop.ledger.com/pages/ledger-live-terms-of-usehttps://foundationdevices.com/terms/https://shop.trezor.io/static/shared/privacy-policy.pdfhttps://www.ledger.com/privacy-policyhttps://foundationdevices.com/privacy/
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