Change record
CA-X-001357
Duolingo Privacy Policy
Entity
Date detected
April 21, 2026
Effective date
April 20, 2026
Severity
Direction
Neutral
Taxonomy
Data collection expansion
Changes
+5 sentences added · 12 sentences modified

Impact Summary

Generated by a model from the captured document; not read by a person
Medium Neutral for users
Affected users
All users Premium subscribers Users in regions with GDPR/CCPA protections

Duolingo expanded its AI-powered conversation features to include a new Math Tutor feature alongside the existing Video Call feature, and introduced a new Session Replay service alongside FullStory for activity logging. For the Math Tutor feature, audio is shared with Apple for speech recognition and immediately deleted, while text transcripts may be retained and shared with AI vendors. The policy also clarified that FullStory and Session Replay can be disabled via the Tracking toggle, and added that Session Replay does not record email addresses, phone numbers, profile images, or passwords. Additionally, Duolingo extended IP address retention for payment processing and fraud prevention beyond the standard 30-day limit, and updated its list of advertising partners to include LiftOff, Pangle, and Moloco.

2 new obligations 1 obligation expanded

Consumers: A new service called Session Replay now logs your clicks, movements, typing, and device information, similar to FullStory, but you can disable it in Settings.

Consumers: When you use Math Tutor, your audio is sent to Apple to convert to text, then deleted, but the text transcript may be kept and shared with AI companies.

Consumers: If you have a paid subscription, Duolingo may keep your IP address longer than 30 days to process payments and prevent fraud.

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What this means for you

Generated by a model from the captured document; not read by a person

The updated policy introduces a new Session Replay service that logs user activity alongside FullStory, capturing clicks, mouse movements, scrolling, typing, device information, navigation, and learning activity. Both services can be disabled using the Tracking toggle in app Settings, and both are automatically disabled for child users. The new Math Tutor feature shares audio with Apple for speech recognition and immediate deletion, but retains and shares text transcripts with AI vendors. For payment processing and fraud prevention, Duolingo may retain IP addresses beyond the standard 30-day period. You can disable both FullStory and Session Replay activity recording by toggling the Tracking setting within the app.

What you can do

→ Disable FullStory and Session Replay activity recording by toggling the Tracking setting in app Settings if you prefer not to be logged.

→ Review the Math Tutor feature privacy practices before using it, as audio and transcripts are processed by third parties.

Key Clauses Affected

Generated by a model from the captured document; not read by a person
Math Tutor audio and transcript handling

Audio is shared with Apple for speech recognition and immediately deleted; text transcripts are retained and shared with AI vendors.

Session Replay activity logging

New service introduced to capture user activity; can be disabled via Tracking toggle and is disabled for child users.

Extended IP retention for payment processing

IP address retention extended beyond 30 days for payment processing and fraud prevention for premium subscribers.

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
c78a2acf11410ac8a367b2448d67b273d581a60ad72acd5db63fc9d944bd1415
April 18, 2026 07:48 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
Record history

Wording edits to this record that do not change what it claims. Changes to a claim are published as corrections.

2026-10-11 · Feed summary edited · summary regenerated by summarize_events
Previous text
Adds Math Tutor AI feature with Apple audio processing; discloses longer IP retention for paying subscribers; text transcripts may be shared with AI vendors.
2026-10-11 · Impact summary edited · summary regenerated by summarize_events
Previous text
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.
2026-10-11 · Summary edited · summary regenerated by summarize_events
Previous text
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.
2026-10-07 · Change line edited · change line rewritten to the 2026-10-07 template: no detection date, no sentence counts
Previous text
Duolingo updated their Duolingo Privacy Policy on April 21, 2026. Change detected: 5 sentence(s) added, 12 sentence(s) modified. Document contained 219 sentences after update.
Citation Record
Entity: Duolingo
Document: Duolingo Privacy Policy
Record ID: CA-X-001357
Version: CA-V-001895
Captured: 2026-04-21 06:05:19 UTC
URL: https://conductatlas.com/change/2026-04-21-duolingo-duolingo-privacy-policy-1357/
Accessed: Nov. 1, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
For legal and compliance teams

Institutional Analysis

Generated by a model from the captured document; not read by a person
Assessment

Duolingo introduced a new Session Replay activity logging service and expanded its Math Tutor AI feature with specific data handling practices. The Math Tutor feature involves audio sharing with Apple and transcript retention with AI …

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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-X-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
Other changes to Duolingo Privacy Policy
Next change May 27, 2026
Duolingo removed a statement that it does not collect audio from Android and website users for product improvement, and broadened …
Medium Negative
View full version history →
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