As long as you have access to your keys, and you are the only one with such access, and can import them properly elsewhere, it's a non-custodial wallet.
But you have to use Ledger Live to add or update apps on your Ledger hardware, at which point you're at the mercy of Ledger's tracking. A smarter idea is to stop using Ledger hardware entirely.
However, even if the user turns off that option, can we say with certainty that the app still does not (secretly) collect data and send it to someone for analysis?
Someone should prove it then.
Better yet, it's time for Ledger to prove the firmware on their hardware is safe AND HAS ABSOLUTELY NO ABILITY TO EXPORT THE USER'S KEYS.
Ledger hardware isn't safe anymore.
Ledger's security was breached in 2020, leading to users names and home addresses being leaked. That's ironic since Ledger's entire job is SECURITY.
Ledger's code has now been hacked. And worse, Ledger blames a previous employee getting phished! That's a double-whammy of inexcusable ineptness from a company who's entire job is SECURITY. And it's even worse since Ledger hardware now runs firmware with key extraction APIs.
It's time for Ledger to prove the firmware on their hardware is safe. They've been lying to their customers for a long time, so their word is no longer good enough.