Duolingo · Duolingo Privacy Policy · View original document ↗

Advertising Data Sharing with Third Parties

High severity Rare · 1 of 343 platforms
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Document Record

What it is

Duolingo shares your personal data with advertising companies like Google and Meta so they can show you targeted ads both on Duolingo and on other websites and apps.

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)

This provision establishes the operational scope of data sharing for advertising purposes and identifies the categories of third parties who receive access to user information. It defines a core data flow mechanism within Duolingo's business model.

Recent Activity

This document changed recently

Medium May 27, 2026

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.

View change record →
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. Duolingo also clarified that IP addresses may be retained longer than 30 days for paying subscribers specifically for payment processing and fraud prevention. The policy changed the Video Call feature from 'Duolingo offers' to 'Duolingo may offer', clarifying it is optional. You can disable FullStory and Session Replay activity recording using the Tracking toggle in app Settings.

View change record →

Change history

modified May 27, 2026

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 →

Consumer impact (what this means for users)

Your learning behavior, device identifiers, and potentially purchase history are shared with advertising partners, enabling cross-platform behavioral profiling that goes well beyond the Duolingo app itself.

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.
  • Export Your Data
    Within 30 days
    Visit duolingo.com/privacy and use the privacy request portal to opt out of data sale/sharing (California) or withdraw consent for advertising processing (EU). Select 'Do Not Sell or Share My Personal Information' if available.

How other platforms handle this

Affirm Medium

By using the Services, you authorize Affirm to share your information, including personal information and information related to your transactions and use of the Services, with merchants, service providers, and other third parties as further described in our Privacy Policy.

Skillshare Medium

We may share your 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 information with third-party advertising p...

Adobe Medium

Sending you information about Adobe products and services, special offers and similar information, and sharing your information with third parties for their own marketing purposes, where your consent is not required; In some cases, in order to show you more relevant ads, we disclose with social medi...

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▸ View Original Clause Language DOCUMENT RECORD
"
We may share your information with advertising partners to show you ads that are relevant to you. These partners may use your data to show you targeted advertisements on other platforms and services.

— Excerpt from Duolingo's Duolingo Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY FRAMEWORK: CCPA §1798.120 grants California residents the right to opt out of the 'sale' or 'sharing' of personal information for cross-context behavioral advertising. GDPR Art. 6(1)(a) requires explicit consent for advertising-based processing in the EU; recital 47 does not support advertising as a legitimate interest. FTC Act Section 5 applies to undisclosed or deceptive data sharing. ePrivacy Directive Art. 5(3) requires prior consent for tracking cookies. Primary enforcers: CPPA (California), EU DPAs, FTC.

Full compliance analysis

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

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Applicable agencies

  • FTC
    The FTC has authority under Section 5 to act against unfair or deceptive advertising data sharing practices and has signaled aggressive enforcement of privacy violations involving third-party ad networks.
    File a complaint →
  • State AG
    California's AG and Privacy Protection Agency enforce CCPA/CPRA opt-out rights for data sharing with advertising partners; other state AGs enforce analogous state privacy laws.
    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
April 18, 2026
Last verified
April 18, 2026
Record ID
CA-P-002765
Document ID
CA-D-00084
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
18dc44f61316909c4efd9113eadb61be0022e2b5dce55feb464c0f8eb1b08ef1
Analysis generated
April 18, 2026 09:22 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Duolingo
Document: Duolingo Privacy Policy
Record ID: CA-P-002765
Captured: 2026-04-18 09:22:23 UTC
SHA-256: 18dc44f61316909c…
URL: https://conductatlas.com/platform/duolingo/duolingo-privacy-policy/advertising-data-sharing-with-third-parties/
Accessed: June 17, 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 Data Sharing with Third Parties clause do?

This provision establishes the operational scope of data sharing for advertising purposes and identifies the categories of third parties who receive access to user information. It defines a core data flow mechanism within Duolingo's business model.

How does this clause affect you?

Your learning behavior, device identifiers, and potentially purchase history are shared with advertising partners, enabling cross-platform behavioral profiling that goes well beyond the Duolingo app itself.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 1 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.