I guess one can't stake ARK if it's locked up in ledger?

nothing is locked in ledger, even bitcoin. all coins/tokens are on the blockchain. The only thing that the ledger does is keep your private keys secure and requires a physical 2fa to sign transactions (pressing the button on the ledger to confirm).
You won't be using the Chrome app, but rather using the Ledger with the ARK desktop wallet thus staking by voting for forging delegate pools will be exactly the same.
Consider it like using ledger with the Mycelium bitcoin android wallet. But replace Mycelium with the ARK desktop wallet.