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.
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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 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...
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.
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...
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"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
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.
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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 4 platforms. See the full comparison.
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