CA-C-002381
Duolingo — Duolingo Privacy Policy
Entity
Date detected
May 27, 2026
Effective date
May 27, 2026
Severity
Direction
Negative
Affected users
all users california residents
Taxonomy
Transparency removal
Changes
−3 sentences removed
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Event Summary

Duolingo removed three sentences from its privacy policy on May 27, 2026. The removed language disclosed that the website uses cookies to enhance user experience and analyze performance, that Duolingo shares user information with social media, advertising, and analytics partners, and a button labeled 'Do Not Sell My Personal Information'. The removal of these explicit disclosures means the policy no longer contains these particular statements about cookie use and data sharing partnerships.

MEDIUM

Consumer Impact

The updated privacy policy no longer contains explicit language stating that Duolingo uses cookies to enhance user experience and analyze performance, or that it shares user information with social media, advertising, and analytics partners. The policy also no longer displays a 'Do Not Sell My Personal Information' button. These removals may affect the transparency of Duolingo's practices as disclosed in the policy document itself, though actual data practices may remain unchanged. Users should review the complete updated privacy policy to understand current disclosures about data collection and sharing.

Governance Analysis

The removal of explicit disclosures about cookie use and data sharing partnerships reduces the transparency statements previously made in Duolingo's policy. The removal of the Do Not Sell button is operationally significant because CCPA and similar state laws may require companies to provide consumers with an opt-out mechanism. The absence of these disclosures in the updated policy creates potential compliance questions depending on whether replacement language exists elsewhere and whether actual data practices have changed.

Available Actions

Review Duolingo's complete updated privacy policy to locate any replacement disclosures about cookie use and data sharing

Search for alternative opt-out mechanisms or Do Not Sell functionality that may appear in a different section of the policy or on Duolingo's settings pages

If No Action Is Taken

Users will not see the explicit disclosure that their information is shared with advertising and analytics partners in the privacy policy.

California residents may not have clear visibility into a Do Not Sell mechanism if no replacement was provided in the updated policy.

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

Cookie disclosure removal

Policy no longer explicitly states that cookies are used for user experience and performance analysis.

Data sharing disclosure removal

Policy no longer explicitly discloses sharing of user information with social media, advertising, and analytics partners.

Do Not Sell button removal

The policy no longer displays a mechanism for users to opt out of sale or sharing of personal information.

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
ffd79e13b1f23d8f50cc63af7c7e06fe3d89fe994f3f6c441c5f01a292a571ad
May 27, 2026 00:13 UTC
✓ Verified
Current Version
91d83dbbd128c031c40ce5c773a5ceb9d35613621eaf32df5deedccd07def729
May 27, 2026 02:14 UTC
✓ Verified
Change Detected
May 27, 2026 02:14 UTC
Analysis Methodology
✓ Verified
Source Document
https://www.duolingo.com/privacy
Citation Record
Entity: Duolingo
Document: Duolingo Privacy Policy
Record ID: CA-C-002381
Captured: 2026-05-27 02:14:36 UTC
URL: https://conductatlas.com/change/2026-05-27-duolingo-duolingo-privacy-policy-2381/
Accessed: May 28, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.

Impact Summary

3
Protections removed
Consumers Removed

The policy no longer states that cookies are used to enhance your experience and analyze site performance.

Consumers Removed

The policy no longer explicitly states that Duolingo shares your information with advertising and analytics partners.

+ 1 more obligation changes. Full breakdown available with Monitor.

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For legal and compliance teams

Institutional Analysis

Assessment

Duolingo removed three sentences disclosing cookie use, advertising partner data sharing, and a Do Not Sell button from its privacy policy on May 27, 2026. This change may create compliance exposure under CCPA (California Consumer Privacy Act), which requires California consumers to have the ability to opt out of the sale or sharing of personal information. The removal of explicit disclosures without replacement language warrants review by legal and privacy teams to determine whether the policy remains compliant with applicable data protection laws and whether actual practices have changed. The operative question is whether these disclosures were required by law or contractually necessary, and whether their removal violates regulatory expectations in jurisdictions where Duolingo operates.

Regulatory Exposure

CCPA (California Consumer Privacy Act), GDPR (General Data Protection Regulation), state privacy laws

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-002381.

Full Changes

See the full side-by-side comparison of every sentence added, removed, and modified.

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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 27, 2026
Duolingo updated their Duolingo Privacy Policy on May 27, 2026. Change detected: 1 sentence(s) removed, 3 sentence(s) modified. Document contained …
View full version history →
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