Duolingo · Duolingo Privacy Policy · View original document ↗

Corporate Transaction Data Sharing

Medium severity High confidence Explicitdocumentlanguage Rare · 2 of 325 platforms
Share 𝕏 Share in Share 🔒 PDF
Recent governance activity Duolingo recorded 3 documented changes in the last 30 days.
Start monitoring updates
Monitor governance changes for Duolingo Create a free account to receive the weekly governance digest and monitor one platform for governance changes.
Create free account No credit card required.
Document Record

What it is

If Duolingo is sold, merged, or involved in a business transaction, your personal data may be transferred to the acquiring or merging company.

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)

The policy reserves the right to transfer all user personal data, including learning history, identifiers, and payment information, to a third party in the context of a corporate transaction, without requiring separate user consent at the time of transfer.

Recent Activity

This document changed recently

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. Duoli…

Consumer impact (what this means for users)

The policy states that user personal data may be shared with acquiring parties during or following a merger, acquisition, or asset sale, potentially subjecting that data to a different organization's privacy practices.

How other platforms handle this

Whatnot Medium

We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Figma Medium

By using our Services, you agree to be bound by this Privacy Policy.

Lime Medium

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...

See all platforms with this clause type →

Monitoring

Duolingo has changed this document before.

Receive same-day alerts, structured change summaries, and monitoring for up to 10 platforms.

Start Watcher free trial Or create a free account →
▸ View Original Clause Language DOCUMENT RECORD
"
We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

— Excerpt from Duolingo's Duolingo Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: Corporate transaction data transfers engage GDPR requirements for lawful processing and notification of data subjects where a change of controller occurs. Under CCPA and CPRA, personal information transferred in a corporate transaction must remain subject to the representations made at the time of collection, unless users are notified and given an opportunity to opt out of material changes. GOVERNANCE EXPOSURE: Medium. This is a standard commercial clause present in most consumer privacy policies. However, for a platform holding detailed learning profiles, behavioral data, and payment information for a large global user base, the volume and sensitivity of data subject to potential transfer warrants monitoring. JURISDICTION FLAGS: EU and UK users benefit from GDPR change-of-controller notification requirements. California users have rights under CPRA to be notified of material changes in data use practices following a corporate transaction. Acquirers operating in regulated industries may face additional obligations. CONTRACT AND VENDOR IMPLICATIONS: Institutional customers and B2B partners should consider whether their agreements with Duolingo include provisions addressing data handling obligations in the event of a corporate transaction, including requirements for notification and continued compliance with agreed data protection standards. COMPLIANCE CONSIDERATIONS: In the event of a corporate transaction, compliance teams should review notification obligations to data subjects under GDPR and CCPA, assess whether the acquiring entity's privacy practices are materially different, and evaluate whether user consent or opt-out mechanisms are required before data is used for new purposes.

Full compliance analysis

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

Track 1 platform — free Try Watcher free for 14 days

Free: track 1 platform + weekly digest. Watcher: 10 platforms + same-day alerts. No credit card required.

Applicable agencies

  • FTC
    The FTC has authority to review corporate transactions involving large consumer data assets and to enforce consumer protection standards in the context of data transfers following mergers or acquisitions.
    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
May 12, 2026
Last verified
May 12, 2026
Record ID
CA-P-011283
Document ID
CA-D-00084
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
2dade822ccc0a9857012fa095dd3b53bfd7ed24f07f06c2c24446c668fae1eea
Analysis generated
May 12, 2026 08:26 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Duolingo
Document: Duolingo Privacy Policy
Record ID: CA-P-011283
Captured: 2026-05-12 08:26:59 UTC
SHA-256: 2dade822ccc0a985…
URL: https://conductatlas.com/platform/duolingo/duolingo-privacy-policy/corporate-transaction-data-sharing/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

Related Analysis

Professional Governance Intelligence

Need to monitor specific governance provisions?

Professional includes provision-level monitoring, governance timelines, regulatory mapping, and audit-ready analysis.

Arbitration clauses AI governance Data rights Indemnification Retention policies
Start Professional free trial

Or start with Watcher →

Built from archived source documents, structured governance mappings, and historical version tracking.

Frequently Asked Questions

What does Duolingo's Corporate Transaction Data Sharing clause do?

The policy reserves the right to transfer all user personal data, including learning history, identifiers, and payment information, to a third party in the context of a corporate transaction, without requiring separate user consent at the time of transfer.

How does this clause affect you?

The policy states that user personal data may be shared with acquiring parties during or following a merger, acquisition, or asset sale, potentially subjecting that data to a different organization's privacy practices.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 2 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.