Duolingo shares your personal information with advertising and analytics companies, including for those companies' own marketing purposes in some cases.
This analysis describes what Duolingo's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
The policy authorizes sharing personal data with third parties for the third parties' own marketing purposes, which in practice may include platforms such as Meta and Google, and which for EU and UK users requires valid consent under GDPR.
Interpretive note: The policy does not enumerate specific advertising and analytics partners by name in the visible text, creating some ambiguity about the full scope of third-party data sharing.
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.
View change record →Language broadened from specific advertising partners to general third-party vendors/service providers, and added qualifier 'consistent with your consent where required' for marketing purposes sharing.
View full change record →The policy states Duolingo may share personal data with advertising and analytics third parties, potentially including for those parties' own marketing uses, which affects how user data is used beyond Duolingo's own platform.
How other platforms handle this
We will also provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected.
to request that your data be transferred to a third party (data portability)
Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.
"We may share your personal information with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. We also may share your information with third parties for their own marketing purposes, consistent with your consent where required.Excerpt from Duolingo's Privacy Policy
REGULATORY LANDSCAPE: Sharing personal data with advertising partners for those partners' own marketing purposes implicates GDPR Article 6 lawful basis requirements and, where consent is relied upon, GDPR Article 7 validity requirements for EU and …
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The policy authorizes sharing personal data with third parties for the third parties' own marketing purposes, which in practice may include platforms such as Meta and Google, and which for EU and UK users requires valid consent under GDPR.
The policy states Duolingo may share personal data with advertising and analytics third parties, potentially including for those parties' own marketing uses, which affects how user data is used beyond Duolingo's own platform.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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