CA-C-002358
Duolingo — Duolingo Privacy Policy
Entity
Date detected
May 27, 2026
Effective date
May 27, 2026
Severity
Direction
Negative
Affected users
all users ios users android users website users
Taxonomy
Data collection expansion
Changes
−1 sentence removed · 3 sentences modified
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Event Summary

Duolingo modified its audio collection and sharing policy on May 27, 2026. Previously, the policy stated that audio sharing for product improvement could be declined on iOS devices specifically, and that Android users and website users were not subject to audio collection for this purpose. The updated policy removes the device-specific distinction and the explicit statement that Android and website users are excluded, stating instead that all users may choose not to share audio for product improvement within app Settings. This change broadens the stated scope of audio collection to potentially include all platforms, while simultaneously offering a uniform opt-out mechanism.

MEDIUM

Consumer Impact

The updated policy removes explicit language stating that Android users and website users are not subject to audio collection for product improvement purposes. Previously, the policy authorized audio collection only from iOS users, with an explicit carve-out for Android and web users. The revised language now states that all users may choose not to share audio within app Settings, suggesting audio collection may now occur across all platforms unless the opt-out mechanism is used. The practical operational effect of this change depends on whether Duolingo implements audio collection on Android and web platforms, which the policy change does not explicitly confirm. You can decline audio sharing for product improvement by adjusting the setting within the app.

Governance Analysis

The updated policy removes explicit language that previously protected Android and web users from audio collection, replacing it with language that allows all users to opt out within app Settings. This change expands the stated scope of audio collection authorization and removes contractual certainty about which platforms are subject to collection. Organizations incorporating Duolingo's services into privacy compliance frameworks should clarify whether this policy change reflects a shift in actual collection practices or simply a clarification of existing practices.

Available Actions

Review your app Settings to confirm the audio sharing opt-out option is available and configured according to your preferences

If you do not wish to have audio collected for product improvement, select the opt-out option in app Settings

If No Action Is Taken

If you do not affirmatively opt out, audio collection for product improvement may occur on your device as permitted under the updated terms

Historical Context

ConductAtlas has recorded 2 material changes to this document over 35 days of monitoring (since April 2026). An additional minor or cosmetic changes were excluded.

2 of Duolingo's significant changes have been classified as negative for consumers.

Key Clauses Affected

audio collection and opt-out provision

Removed device-specific exclusions for Android and web; established unified opt-out mechanism across all platforms

Full clause-by-clause analysis available with Compliance.
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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
ffd79e13b1f23d8f50cc63af7c7e06fe3d89fe994f3f6c441c5f01a292a571ad
May 27, 2026 00:13 UTC
✓ Verified
Change Detected
May 27, 2026 00:13 UTC
Analysis Methodology
✓ Verified
Source Document
https://www.duolingo.com/privacy
Citation Record
Entity: Duolingo
Document: Duolingo Privacy Policy
Record ID: CA-C-002358
Captured: 2026-05-27 00:13:09 UTC
URL: https://conductatlas.com/change/2026-05-27-duolingo-duolingo-privacy-policy-2358/
Accessed: July 12, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.

Impact Summary

1
Expanded
1
Protection removed
Consumers Expanded

Audio collection for product improvement may now apply to Android and web users if Duolingo implements collection on those platforms

Consumers Removed

Users on Android and web no longer have an explicit policy statement protecting them from audio collection

For legal and compliance teams

Institutional Analysis

Assessment

Duolingo removed platform-specific exclusions from its audio collection policy, replacing them with a unified opt-out mechanism applicable to all users. The prior policy explicitly stated Android users and website users were not subject to audio collection for product improvement; the updated policy no longer contains these exclusions. This change expands the stated scope of permitted audio collection but does not confirm that collection will be implemented on these platforms. Organizations using Duolingo as a vendor or relying on its privacy practices for compliance purposes may need to evaluate whether this change affects privacy notice obligations, DPA terms, or vendor assessment frameworks. The change may engage GDPR lawfulness requirements if Duolingo operates in the EEA, and state privacy laws (CCPA, CPA, etc.) if Duolingo has California or other state residents in its user base.

Regulatory Exposure

GDPR (lawfulness of processing, consent requirements), CCPA (consumer rights to opt-out), state privacy laws (CPA, UCPA, etc.), FTC Act Section 5 (unfair or deceptive practices if prior representations about platform-specific exclusions are relied upon by consumers)

Full compliance analysis

Obligation analysis, escalation trigger, board language, and recommended action.

Monitor $19/mo Compliance $249/mo

Monitor: regulatory citations + obligations. Compliance: full compliance memo.

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-002358.

Full Changes

View complete diff →

Document Context

Version history → Policy drift analysis → Document page →
Document
Duolingo Privacy Policy
Entity
Duolingo
Captured
May 27, 2026
Source URL
https://www.duolingo.com/privacy
Other changes to Duolingo Privacy Policy
Previous change May 5, 2026
Duolingo added three sentences to its privacy policy on May 5, 2026, disclosing that the website uses cookies to enhance …
Low Positive
Next change May 27, 2026
Duolingo removed three sentences from its privacy policy on May 27, 2026. The removed language disclosed that the website uses …
Medium Negative
View full version history →
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