Provision record
Duolingo · Duolingo Privacy Policy · View original document ↗

Data Retention Discretion

Medium severity High confidence Explicit document language Common · 274 of 352 platforms
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Document Record

What it is

Duolingo keeps your personal data for as long as it decides is necessary for its services, with no specific time limits stated, unless law requires otherwise.

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)

This clause allocates discretion to Duolingo to determine retention duration based on operational necessity and legal compliance obligations. It establishes a standards-based retention framework rather than specifying defined retention windows, which affects how long user data remains in the company's systems.

Recent Activity

This document changed recently

Medium May 27, 2026

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 →

Clause Stability Stable

0
Changes
4
Months Monitored
May 10, 2026
First Seen
May 11, 2026
Last Seen
This clause type exists across 1630 other provisions on other platforms.

Consumer impact (what this means for users)

Duolingo does not commit to a specific retention period for most categories of personal data, meaning your voice recordings, learning history, and behavioral data may be kept indefinitely as long as Duolingo determines there is a service-related purpose. EU users may have stronger rights to challenge retention duration under GDPR.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    Submit a data deletion or erasure request to privacy@duolingo.com, specifying your account and the categories of data you want deleted. EU users can invoke GDPR Article 17 erasure rights in their request.

How other platforms handle this

Palantir Medium

We collect and keep personal data only as needed or allowed for the purposes set out in this Statement, based on the reason we collected the personal data in the first instance and what is permitted under the laws that apply to the processing.

Affirm Medium

Affirm will retain your information in accordance with our Privacy Policy and any applicable state or federal law, rule or regulation.

Mistral AI Medium

Mistral AI shall retain the Customer Exportable Data and Assets for a period of thirty (30) days from the earlier between (a) the expiration of the Transitional Period or (b) Customer's notification under Section 2.2.2 (b) of these Additional Terms.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
We retain your personal information for as long as necessary to provide our Services and fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Excerpt from Duolingo's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: GDPR Article 5(1)(e) establishes the storage limitation principle, requiring that personal data be kept no longer than necessary for the purposes for which it is processed.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →

Applicable regulations

CCPA/CPRA
California, USA
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
UK GDPR
United Kingdom

Provision details

Document information
Document
Duolingo Privacy Policy
Entity
Duolingo
Document last updated
May 5, 2026
Tracking information
First tracked
May 10, 2026
Last verified
May 10, 2026
Record ID
CA-P-008882
Document ID
CA-D-00084
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
0e272c40f8dab9b0ecb7e9d9d71e56883e23c7aa9adb6049c8631ca5c9147456
Analysis generated
May 10, 2026 12:08 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Duolingo
Document: Duolingo Privacy Policy
Record ID: CA-P-008882
Captured: 2026-05-10 12:08:13 UTC
SHA-256: 0e272c40f8dab9b0…
URL: https://conductatlas.com/platform/duolingo/duolingo-privacy-policy/provision/CA-P-008882/data-retention-discretion/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Duolingo's Data Retention Discretion clause do?

This clause allocates discretion to Duolingo to determine retention duration based on operational necessity and legal compliance obligations. It establishes a standards-based retention framework rather than specifying defined retention windows, which affects how long user data remains in the company's systems.

How does this clause affect you?

Duolingo does not commit to a specific retention period for most categories of personal data, meaning your voice recordings, learning history, and behavioral data may be kept indefinitely as long as Duolingo determines there is a service-related purpose. EU users may have stronger rights to challenge retention duration under GDPR.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 274 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.