What can I do about this clause?

{'method': 'IN_APP', 'recipient': 'https://www.duolingo.com/settings', 'difficulty': 'EASY', 'action_type': 'CLOSE_ACCOUNT', 'instructions': 'Go to Duolingo Settings > Account > Delete Account to initiate account deletion. You can also email privacy@duolingo.com to request data export before deletion.', 'deadline_days': None, 'deadline_hours': None} {'method': 'EMAIL', 'recipient': 'privacy@duolingo.com', 'difficulty': 'EASY', 'action_type': 'EXPORT_DATA', 'instructions': 'Email privacy@duolingo.com requesting a copy of your personal data in a machine-readable format. Under GDPR Art. 20, EU users are entitled to receive this data within 30 days.', 'deadline_days': 30, 'deadline_hours': None}

Which regulatory agencies enforce this type of clause?

{'agency': 'FTC', 'reason': 'The FTC has authority to act against companies that make misleading representations about data deletion practices under FTC Act Section 5.', 'complaint_url': 'https://reportfraud.ftc.gov/'}

What is the severity of this clause?

ConductAtlas classifies this Account Deletion and Data Portability clause as medium severity. Severity reflects the magnitude of rights affected, the breadth of users impacted, and the degree of discretion the platform retains.

Account Deletion and Data Portability — Duolingo

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What it is

You can delete your Duolingo account at any time and request a copy of your data. Duolingo will remove your information unless it has a legal or business reason to keep it.

Consumer impact (what this means for users)

While you can request account deletion and data export, the 'business purposes' exception means some of your data may be retained by Duolingo even after you delete your account, reducing the completeness of deletion.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.

Close Your Account

Go to Duolingo Settings > Account > Delete Account to initiate account deletion. You can also email privacy@duolingo.com to request data export before deletion.
Export Your Data
Within 30 days
Email privacy@duolingo.com requesting a copy of your personal data in a machine-readable format. Under GDPR Art. 20, EU users are entitled to receive this data within 30 days.

Cross-platform context

See how other platforms handle Account Deletion and Data Portability and similar clauses.

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Why it matters (compliance & risk perspective)

The exception for 'business purposes' to retain data post-deletion is broad and could limit the practical effectiveness of account deletion, meaning your data may persist longer than expected.

View original clause language

You may request to delete your Duolingo account at any time. Upon deletion, we will delete or anonymize your personal information, unless we need to retain it for legal, business, or security purposes. You may also request a copy of your personal data in a commonly used, machine-readable format.

Institutional analysis (Compliance & legal intelligence)

REGULATORY FRAMEWORK: GDPR Art. 17 (right to erasure) with exceptions under Art. 17(3) for legal obligations; CCPA §1798.105 (right to delete) with statutory exceptions for legal compliance and security; CPRA requires disclosure of retention practices. FTC Act Section 5 applies to misleading deletion representations. Primary enforcers: EU DPAs, CPPA, FTC.

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Applicable agencies

FTC

The FTC has authority to act against companies that make misleading representations about data deletion practices under FTC Act Section 5.
File a complaint →

Provision details

Document information

Document

Duolingo Privacy Policy

Entity

Duolingo

Document last updated

April 29, 2026

Tracking information

First tracked

April 18, 2026

Last verified

April 18, 2026

Record ID

CA-P-002771

Document ID

CA-D-00084

Evidence Provenance

Source URL

https://www.duolingo.com/privacy

Wayback Machine

View archived versions →

SHA-256

18dc44f61316909c4efd9113eadb61be0022e2b5dce55feb464c0f8eb1b08ef1

Verified

✓ Snapshot stored ✓ Change verified

How to Cite

ConductAtlas Policy Archive
Entity: Duolingo | Document: Duolingo Privacy Policy | Record: CA-P-002771
Captured: 2026-04-18 09:22:23 UTC | SHA-256: 18dc44f61316909c…
URL: https://conductatlas.com/platform/duolingo/duolingo-privacy-policy/account-deletion-and-data-portability/
Accessed: May 2, 2026

Classification

Severity

Medium

Account Deletion and Data Portability