This provision states that Duolingo may anonymize personal information and use the resulting de-identified data for any purpose, including AI model training, asserting that such data falls outside the definition of personal information because it cannot identify individuals.
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
This provision reserves broad secondary use rights over de-identified data derived from user activity. The practical scope of this authorization depends on the robustness of the anonymization method applied, which the policy does not describe in technical detail; applicable law in some jurisdictions may impose standards for what constitutes adequate de-identification.
Interpretive note: The enforceability of the 'for any purpose' authorization depends on the robustness of the anonymization method applied, which the policy does not describe; applicable law in some jurisdictions may evaluate de-identification adequacy differently.
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 →Under this provision, Duolingo may derive anonymized datasets from user personal information and use those datasets without stated purpose restriction, including for AI training. The policy asserts that anonymized data is not personal information, though applicable law in certain jurisdictions may evaluate de-identification adequacy differently.
Cross-platform context
See how other platforms handle Anonymized Data Use for Any Purpose Including AI Training and similar clauses.
Compare across platforms →"Duolingo may anonymize your personal information, and use this de-identified data for any purpose, such as better understanding learning trends and training artificial intelligence models. Such information is not considered personal information since it cannot identify any individual.Excerpt from Duolingo's Privacy Policy
1) REGULATORY LANDSCAPE: GDPR Recital 26 and applicable guidance from EU data protection authorities establish that de-identification must be robust and irreversible to remove data from GDPR scope; pseudonymized data does not qualify.
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This provision reserves broad secondary use rights over de-identified data derived from user activity. The practical scope of this authorization depends on the robustness of the anonymization method applied, which the policy does not describe in technical detail; applicable law in some jurisdictions may impose standards for what constitutes adequate de-identification.
Under this provision, Duolingo may derive anonymized datasets from user personal information and use those datasets without stated purpose restriction, including for AI training. The policy asserts that anonymized data is not personal information, though applicable law in certain jurisdictions may evaluate de-identification adequacy differently.
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