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.
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.
The updated policy establishes new data flows (Math Tutor audio to Apple, transcripts to AI vendors) and extends IP retention timelines for paying customers, creating expanded visibility into how Duolingo processes and shares educational interaction data. For organizations relying on Duolingo as a vendor, these changes may require updates to data processing agreements and vendor control documentation, particularly regarding third-party processors and retention practices.
→ 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
→ If you use Math Tutor, your audio will be processed by Apple and text transcripts will be retained and may be shared with AI vendors as stated in the policy
→ If you maintain a paid subscription, your IP address may be retained longer than 30 days for payment and fraud prevention purposes as authorized by the updated terms
Audio is shared with Apple for transcription and deleted; text transcripts may be retained and shared with AI vendors
IP addresses may be retained longer than 30 days for paying subscribers for payment processing and fraud prevention
Users can now disable both FullStory and Session Replay recording via the Tracking toggle in Settings
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
If you pay for Duolingo, your IP address may be kept longer than the standard 30 days for handling payments and preventing fraud.
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.
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 beyond the stated 30-day default. For organizations that include Duolingo in their vendor stack or conduct customer due diligence on education technology vendors, this creates new questions about data handling procedures, third-party processor involvement (Apple), and retention practices for paying customers. The change may require updates to data processing addendums (DPAs) or vendor assessment documentation if those agreements reference specific retention timelines. No explicit regulatory non-compliance is apparent, but the longer IP retention for payment/fraud purposes may engage GDPR proportionality analysis and CCPA vendor disclosure requirements depending on jurisdiction.
GDPR (data processing, storage limitation, third-party processor involvement, lawful basis for extended retention), CCPA (vendor disclosure, data retention), FTC Act Section 5 (unfairness/deception in data practices if practices diverge materially from disclosures)
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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.
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