Duolingo · Duolingo Privacy Policy · View original document ↗

Advertising and Analytics Data Sharing

High severity Medium confidence Explicitdocumentlanguage Rare · 4 of 325 platforms
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Recent governance activity Duolingo recorded 3 documented changes in the last 30 days.
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Document Record

What it is

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

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.

Recent Activity

This document changed recently

Medium Apr 21, 2026

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. Duoli…

Consumer impact (what this means for users)

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.

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.
  • Delete Your Data
    California residents can opt out of sharing of personal data for advertising by emailing privacy@duolingo.com. EU and UK users can withdraw consent for advertising processing by emailing privacy@duolingo.com or adjusting cookie settings in the app or on duolingo.com.

How other platforms handle this

Lime Medium

We may share your information with third-party advertising partners to provide you with targeted advertising. We also work with third-party analytics providers who help us understand how users interact with our Services. These third parties may use cookies, web beacons, and similar tracking technolo...

Zoom Medium

We work with third-party advertising partners to market our Products, and we share personal data with advertising networks and social media companies to serve ads. We also use analytics providers to help us understand how users interact with our Products.

Notion Medium

We may share your personal information with third-party vendors and service providers that perform services on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. We may also share your personal information with busines...

See all platforms with this clause type →

Monitoring

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▸ View Original Clause Language DOCUMENT RECORD
"
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 Duolingo Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

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 UK users. Under CCPA and CPRA, sharing personal information for cross-context behavioral advertising constitutes a 'share' under California law, triggering opt-out rights. The FTC Act applies to any material misrepresentation about the scope of third-party data sharing. GOVERNANCE EXPOSURE: High. The authorization to share personal data with third parties for those parties' own marketing purposes, combined with the advertising technology infrastructure embedded in the platform (Meta Pixel, Google Analytics, Google Tag Manager), creates significant regulatory exposure under GDPR consent requirements and CCPA opt-out obligations. The policy's language is relatively general and may not fully satisfy GDPR transparency requirements regarding specific recipients and purposes. JURISDICTION FLAGS: EU and UK users require specific, informed, and freely given consent before their data is shared with advertising partners for marketing purposes. California residents must be provided a clear opt-out mechanism. Users in other jurisdictions may have limited recourse depending on local law. CONTRACT AND VENDOR IMPLICATIONS: Each advertising and analytics partner receiving personal data should be subject to a data processing agreement or, where acting as an independent controller, appropriate controller-to-controller terms. The presence of Meta Pixel and Google Analytics scripts on the policy page itself suggests data is transmitted to these platforms upon page load, which may warrant review of consent sequencing. COMPLIANCE CONSIDERATIONS: Compliance teams should audit the list of advertising and analytics partners receiving personal data and verify that disclosures in the policy accurately reflect current data flows. For EU and UK users, consent management platform configuration should be reviewed to ensure advertising cookies and tracking pixels are not activated prior to valid consent.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC has authority over unfair or deceptive practices related to data sharing with advertising partners under the FTC Act.
    File a complaint →
  • State AG
    California's Attorney General and California Privacy Protection Agency enforce CCPA and CPRA opt-out rights for sharing of personal data for advertising.
    File a complaint →

Applicable regulations

CCPA/CPRA
California, USA
COPPA
United States Federal
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Duolingo Privacy Policy
Entity
Duolingo
Document last updated
May 5, 2026
Tracking information
First tracked
May 12, 2026
Last verified
May 12, 2026
Record ID
CA-P-011280
Document ID
CA-D-00084
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
2dade822ccc0a9857012fa095dd3b53bfd7ed24f07f06c2c24446c668fae1eea
Analysis generated
May 12, 2026 08:26 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Duolingo
Document: Duolingo Privacy Policy
Record ID: CA-P-011280
Captured: 2026-05-12 08:26:59 UTC
SHA-256: 2dade822ccc0a985…
URL: https://conductatlas.com/platform/duolingo/duolingo-privacy-policy/advertising-and-analytics-data-sharing/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

Other risks in this policy

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Frequently Asked Questions

What does Duolingo's Advertising and Analytics Data Sharing clause do?

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.

How does this clause affect you?

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 many platforms have this type of clause?

ConductAtlas has identified this type of provision across 4 platforms. See the full comparison.

Is ConductAtlas affiliated with Duolingo?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Duolingo.