Duolingo · Duolingo Privacy Policy · View original document ↗

EU/EEA User Rights under GDPR

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Document Record

What it is

If you are in the EU, UK, or Switzerland, you have strong legal rights to access, correct, delete, and transfer your data, and can complain to your national data protection authority if you feel your rights have been violated.

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 provision operationalizes Duolingo's compliance obligations under GDPR and related data protection regimes by explicitly acknowledging and authorizing the exercise of statutory rights by a defined user population, establishing the procedural basis for data subject requests and regulatory complaints.

Recent Activity

This document changed recently

Medium May 27, 2026

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 →
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. 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 →

Change history

modified May 27, 2026

Removed Switzerland from scope, removed 'update' right, changed 'data protection authority' to 'supervisory authority', and softened language from 'you have the right' to 'you have certain rights.'

View full change record →

Consumer impact (what this means for users)

EU, UK, and Swiss users can request a full export of their personal data, demand deletion, or object to advertising processing at any time, and have a legal right to escalate complaints to their national DPA if Duolingo does not respond adequately within 30 days.

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
    Within 30 days
    EU/UK/Swiss users can email privacy@duolingo.com to submit a Data Subject Access Request (DSAR), request data deletion, or object to processing. Duolingo must respond within 30 days under GDPR Art. 12.

How other platforms handle this

Garmin Medium

If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to access, correct, or erase your personal data; the right to restrict or object to our processing of your personal data; the right to data portability; and, where our processing is based on your...

Grindr Medium

Depending on where you are located, you may have certain rights regarding your personal information, including the right to access, correct, delete, or restrict processing of your personal information, the right to data portability, and the right to object to or withdraw consent for certain processi...

Strava Medium

For individuals in the United States, please also refer to our Notice For Individuals Residing In Certain US States below and the Consumer Health Data Policy.

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▸ View Original Clause Language DOCUMENT RECORD
"
If you are located in the European Economic Area, United Kingdom, or Switzerland, you have the right to access, correct, update, or request deletion of your personal information. You also have the right to object to processing, restrict processing, and request portability of your data. You may also have the right to lodge a complaint with your local data protection authority.

— Excerpt from Duolingo's Duolingo Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY FRAMEWORK: GDPR Art. 15 (right of access), Art. 16 (rectification), Art. 17 (erasure), Art. 18 (restriction), Art. 20 (portability), Art. 21 (objection), Art. 77 (right to lodge complaint with supervisory authority). UK GDPR mirrors these rights post-Brexit. Swiss Federal Act on Data Protection (revDSG) effective September 2023 provides comparable rights. Enforced by national DPAs (lead authority for Duolingo likely Irish DPC given EU establishment).

Full compliance analysis

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

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Applicable agencies

  • State AG
    EU/EEA users should contact their national Data Protection Authority (DPA) — equivalent to a state AG for privacy matters — if Duolingo fails to honor GDPR rights. The Irish DPC may be the lead supervisory authority.
    File a complaint →

Applicable regulations

EU AI Act
European Union
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
April 18, 2026
Last verified
April 18, 2026
Record ID
CA-P-002770
Document ID
CA-D-00084
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
18dc44f61316909c4efd9113eadb61be0022e2b5dce55feb464c0f8eb1b08ef1
Analysis generated
April 18, 2026 09:22 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Duolingo
Document: Duolingo Privacy Policy
Record ID: CA-P-002770
Captured: 2026-04-18 09:22:23 UTC
SHA-256: 18dc44f61316909c…
URL: https://conductatlas.com/platform/duolingo/duolingo-privacy-policy/eueea-user-rights-under-gdpr/
Accessed: June 17, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Frequently Asked Questions

What does Duolingo's EU/EEA User Rights under GDPR clause do?

This provision operationalizes Duolingo's compliance obligations under GDPR and related data protection regimes by explicitly acknowledging and authorizing the exercise of statutory rights by a defined user population, establishing the procedural basis for data subject requests and regulatory complaints.

How does this clause affect you?

EU, UK, and Swiss users can request a full export of their personal data, demand deletion, or object to advertising processing at any time, and have a legal right to escalate complaints to their national DPA if Duolingo does not respond adequately within 30 days.

Is ConductAtlas affiliated with Duolingo?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Duolingo.