Duolingo states it does not collect personal data from children under 13 without parental consent, and will delete such data if collected accidentally, but parents must contact the company directly if they believe their child's data was collected without consent.
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 operationalizes Duolingo's compliance with the Children's Online Privacy Protection Act (COPPA) by establishing procedures for parental consent verification, data retention restrictions for minors, and remediation pathways when unauthorized collection occurs. The requirement to delete discovered data and maintain a contact mechanism creates an ongoing operational obligation for the company.
Interpretive note: The adequacy of Duolingo's age verification and parental consent mechanisms is not fully described in the policy text, making it difficult to assess whether the stated COPPA compliance approach satisfies the FTC's verifiable parental consent standard in practice.
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 →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 →Removed mention of separate experience for younger users and family features management, and added specific contact email (privacy@duolingo.com) for parental concerns instead of proactive deletion language.
View full change record →If your child under 13 uses Duolingo without parental consent being properly obtained, their personal data may have been collected; parents must proactively contact Duolingo to request deletion of that data. The policy places the burden of notification on parents rather than providing automatic protections.
How other platforms handle this
Our websites and mobile applications are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13 without parental consent. If we learn that we have collected personal information from a child under 13 without parental consent, we will...
The Services are intended for users who are 13 years of age or older. If you are under 13 years of age, you are not permitted to use the Services. By using the Services, you represent and warrant that you are 13 years of age or older. If you are between 13 and 18 years of age, you may only use the S...
Our Services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13 without verifiable parental consent, we will take steps to delete such info...
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"Duolingo does not knowingly collect personal information from children under 13 without parental consent. If we learn that we have collected personal information from a child under 13 without parental consent, we will delete that information as quickly as possible. If you are a parent or guardian and believe your child has provided us with personal information without your consent, please contact us at privacy@duolingo.com.— Excerpt from Duolingo's Duolingo Privacy Policy
(1) REGULATORY LANDSCAPE: This provision directly engages COPPA, enforced by the FTC, which requires verifiable parental consent before collecting personal information from children under 13 in the US. The UK Children's Code (Age Appropriate Design Code) and GDPR Article 8 impose similar or more stringent requirements in the UK and EEA, including requirements that services likely accessed by minors apply high privacy standards by default. The FTC has brought enforcement actions against app operators for inadequate COPPA compliance, including consent verification failures. (2) GOVERNANCE EXPOSURE: High. Duolingo is a general-audience platform that is demonstrably used by children globally. The policy's 'does not knowingly collect' framing is a standard COPPA formulation, but the platform's design and broad appeal to younger learners may attract regulatory scrutiny regarding whether Duolingo has actual knowledge of child users that would trigger COPPA obligations beyond the stated 'unknowing' standard. The adequacy of age-gating mechanisms is a key question. (3) JURISDICTION FLAGS: United States (COPPA, FTC enforcement), United Kingdom (Children's Code, ICO enforcement), EU/EEA (GDPR Article 8, national supervisory authorities). Educational deployment of Duolingo in US schools may also trigger FERPA considerations and COPPA's school consent exception requirements. (4) CONTRACT AND VENDOR IMPLICATIONS: Schools and educational institutions deploying Duolingo should evaluate whether Duolingo operates as a school official under FERPA's school official exception and whether its data practices are consistent with that designation. Procurement teams should request evidence of COPPA compliance program documentation and assess whether third-party advertising integrations are disabled for verified child accounts. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should verify that age-gating mechanisms are technically effective and not easily circumvented. The policy's reliance on parental self-reporting for remediation (contact us at privacy@duolingo.com) should be assessed against COPPA's requirement for proactive parental consent before collection. Advertising technology integrations should be audited to confirm they are not active for accounts associated with users under 13.
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This provision operationalizes Duolingo's compliance with the Children's Online Privacy Protection Act (COPPA) by establishing procedures for parental consent verification, data retention restrictions for minors, and remediation pathways when unauthorized collection occurs. The requirement to delete discovered data and maintain a contact mechanism creates an ongoing operational obligation for the company.
If your child under 13 uses Duolingo without parental consent being properly obtained, their personal data may have been collected; parents must proactively contact Duolingo to request deletion of that data. The policy places the burden of notification on parents rather than providing automatic protections.
ConductAtlas has identified this type of provision across 9 platforms. See the full comparison.
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