Duolingo transfers your personal data to the United States for processing, regardless of where you are located, meaning your data may be subject to US laws rather than the stronger protections of your home country.
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
The clause establishes the geographic scope of data processing operations and notifies users that their information will be subject to the legal and regulatory frameworks of the jurisdiction where servers are located, rather than remaining under their home jurisdiction's data protection regime.
Interpretive note: The policy does not specify which GDPR-approved transfer mechanism Duolingo relies upon for EU-US data flows, creating uncertainty about the legal basis and whether full GDPR Article 13 disclosure requirements are satisfied.
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 →If you use Duolingo from outside the United States, your personal data including learning behavior and voice recordings will be transferred to and stored in the US, where data protection standards differ from those in your country. EU and UK users should be aware that US government access to data transferred under certain frameworks remains a contested legal area.
How other platforms handle this
Okta operates globally and may transfer your personal data to countries outside of your home country, including the United States, which may not provide the same level of data protection as your home country. Where required by applicable law, we use Standard Contractual Clauses or other appropriate ...
"Your personal information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you are located outside the United States and choose to provide information to us, please note that we transfer the data to the United States and process it there.Excerpt from Duolingo's Privacy Policy
(1) REGULATORY LANDSCAPE: Cross-border data transfers from the EEA to the US are governed by GDPR Chapter V, requiring either an adequacy decision, Standard Contractual Clauses (SCCs), Binding Corporate Rules, or another approved mechanism.
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The clause establishes the geographic scope of data processing operations and notifies users that their information will be subject to the legal and regulatory frameworks of the jurisdiction where servers are located, rather than remaining under their home jurisdiction's data protection regime.
If you use Duolingo from outside the United States, your personal data including learning behavior and voice recordings will be transferred to and stored in the US, where data protection standards differ from those in your country. EU and UK users should be aware that US government access to data transferred under certain frameworks remains a contested legal area.
ConductAtlas has identified this type of provision across 1 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Duolingo.