This provision establishes that Child Users under 13 (or applicable local age of digital consent) are registered without name, email, or phone number, using only a non-identifying username. The policy asserts COPPA compliance by limiting collection to what is necessary for internal service operations and committing to delete inadvertently collected additional data.
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 establishes the operational framework for COPPA compliance, including the categories of data excluded from collection for Child Users and the parental notification mechanism triggered at first logout. The policy separately states that all users under 16 receive additional protections including non-personalized advertising and disabled third-party behavioral tracking.
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, Child Users under 13 are enrolled with minimal data collection and receive non-personalized advertising, disabled third-party behavioral tracking, and restricted social features. Parents receive a notification email at first logout describing Duolingo's privacy practices for Child Users and the mechanisms available to access, change, or delete their child's information.
Cross-platform context
See how other platforms handle Child User Data Collection and COPPA Compliance and similar clauses.
Compare across platforms →"Duolingo treats Child Users (meaning users under the age of 13 in the United States or another age of digital consent in their country) differently to ensure their parents are in control and we only collect the bare minimum information we need to make Duolingo work. Child Users are permitted to create a Duolingo account, but instead of using an email address, we ask them to register using a username that is not tied to their real name. We do not collect their name, email address, phone number, or any other personal information. With regards to the Children's Online Privacy Protection Act ('COPPA'), Duolingo collects personal information from children under the age of 13 for the sole purpose of performing internal operations of the Service. If we discover that we have unknowingly collected additional personal information from these children, we will delete it.Excerpt from Duolingo's Privacy Policy
1) REGULATORY LANDSCAPE: This provision directly addresses COPPA, which is enforced by the FTC and requires verifiable parental consent before collecting personal information from children under 13.
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This provision establishes the operational framework for COPPA compliance, including the categories of data excluded from collection for Child Users and the parental notification mechanism triggered at first logout. The policy separately states that all users under 16 receive additional protections including non-personalized advertising and disabled third-party behavioral tracking.
Under this provision, Child Users under 13 are enrolled with minimal data collection and receive non-personalized advertising, disabled third-party behavioral tracking, and restricted social features. Parents receive a notification email at first logout describing Duolingo's privacy practices for Child Users and the mechanisms available to access, change, or delete their child's information.
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