Change record
CA-C-001357
Duolingo Privacy Policy
Entity
Date detected
April 21, 2026
Effective date
April 21, 2026
Severity
Direction
Negative
Taxonomy
Retention change
Changes
−3 sentences removed

Impact Summary

Medium Negative for users
Affected users
All users Premium subscribers

Duolingo updated its privacy policy on April 21, 2026 to add details about a new Math Tutor AI feature and to modify how audio and transcript data are handled. For Math Tutor, audio is shared with Apple for speech recognition and then deleted, while text transcripts may be retained and shared with AI vendors. The policy also added language clarifying that IP addresses may be retained longer for payment processing and fraud prevention when users have paid subscriptions.

1 obligation expanded

Consumers: If you pay for Duolingo, your IP address may be kept longer than the standard 30 days for handling payments and preventing fraud.

Consumers: When you use Math Tutor, your spoken audio goes to Apple to be converted to text; the audio is then deleted but Duolingo may keep and share the written transcript with AI vendors.

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What this means for you

The updated policy now discloses a new Math Tutor feature that processes audio through Apple for transcription; audio is deleted but text transcripts may be retained and shared with AI vendors. Duolingo also clarified that IP addresses may be retained longer than 30 days for paying subscribers specifically for payment processing and fraud prevention. The policy changed the Video Call feature from 'Duolingo offers' to 'Duolingo may offer', clarifying it is optional. You can disable FullStory and Session Replay activity recording using the Tracking toggle in app Settings.

What you can do

Review the updated privacy policy, especially the Math Tutor and IP retention sections if you are a paying subscriber or plan to use Math Tutor

Disable FullStory and Session Replay recording by toggling the Tracking option in app Settings if you wish to limit activity logging

Key Clauses Affected

Math Tutor audio and transcript handling

Audio is shared with Apple for transcription and deleted; text transcripts may be retained and shared with AI vendors

Extended IP retention for subscribers

IP addresses may be retained longer than 30 days for paying subscribers for payment processing and fraud prevention

FullStory and Session Replay tracking controls

Users can now disable both FullStory and Session Replay recording via the Tracking toggle in Settings

Full clause-by-clause analysis available with Insight.

This change record describes what was added, removed, or modified in the document. Analysis reflects what the updated agreement states or permits. It does not constitute a legal determination about enforceability. Applicability may vary by jurisdiction. Methodology

Evidence Verification

✓ Verified
Previous Version
a096fd79730abd902159118bbeed45ddf75b93071e09cafe1012b20077064d43
May 5, 2026 14:59 UTC
✓ Verified
Current Version
cdb1aa0d3bfd4be264e86c80c3c612593edeebe1fad643a91ca3dd3b93e33ae8
April 21, 2026 06:05 UTC
✓ Verified
Change Detected
April 21, 2026 06:05 UTC
Analysis Methodology
✓ Verified
Source Document
https://www.duolingo.com/privacy
Citation Record
Entity: Duolingo
Document: Duolingo Privacy Policy
Record ID: CA-C-001357
Captured: 2026-04-21 06:05:19 UTC
URL: https://conductatlas.com/change/2026-04-21-duolingo-duolingo-privacy-policy-1357/
Accessed: Sept. 10, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
For legal and compliance teams

Institutional Analysis

Assessment

This change adds disclosures for a new AI feature (Math Tutor) that routes audio through Apple and retains text transcripts for AI vendor use, and expands the circumstances under which IP addresses may be retained …

🔒 Full institutional analysis

Regulatory exposure, obligation change, escalation trigger, board-ready language, and recommended action for legal and compliance teams.

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ConductAtlas provides verified policy intelligence sourced directly from platform documents. All analysis is intended to support, not replace, legal and compliance review. Record CA-C-001357.

Full Changes

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Document Context

Version history → Policy drift analysis → Document page →
Document
Duolingo Privacy Policy
Entity
Duolingo
Captured
April 21, 2026
Source URL
https://www.duolingo.com/privacy
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