Ledger Recovery Key stores private keys offline and operates without user identification, utilizing the same secure element technology as Ledger wallets

Quotes that support claims

Ledger Recovery Key is built with Secure Element, the main security layer and the same technology applied by Ledger wallet devices.

Recovery Key is designed to make recovering access to assets as easy as tapping a card and entering a PIN — using the same secure element technology that powers Ledger's crypto wallet devices

the new Ledger Recovery Key is always offline and doesn’t require identification.