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This provision authorizes Duolingo to share personal information with named advertising networks including Unity, Meta, LiftOff, Pangle, Moloco, and Google for personalized advertising purposes. EU and UK users are opted out by default; all other users may opt out through app Settings.
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 discloses that personal information is shared with six named advertising network vendors and unspecified additional marketing analytics and website analysis providers for cross-site advertising and market research purposes. The default opt-out for EU and UK users reflects applicable regulatory requirements in those jurisdictions.
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 →Under this provision, personal information about Duolingo usage and other website activity may be shared with advertising networks including Unity, Meta, LiftOff, Pangle, Moloco, and Google for personalized advertising. Users can opt out of personalized advertising in app Settings; EU and UK users are opted out by default.
Cross-platform context
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"Duolingo may process and share your personal information for the purpose of providing you with personalized advertising. To provide personalized advertising, we may work with a variety of marketing analytics service providers, website analysis firms, and third-party advertising networks, such as Unity, Meta, LiftOff, Pangle, Moloco, and Google. These third-party advertising service providers collect and use personal information about your visits to and use of the Service, as well as other websites, in order to serve you with advertisements and content tailored to meet your preferences and likely interests, better understand ad effectiveness, and for market research purposes. Users in certain jurisdictions (including the European Union and United Kingdom) are opted out of personalized advertising by default, but may opt in.Excerpt from Duolingo's Privacy Policy
1) REGULATORY LANDSCAPE: This provision engages GDPR Article 6 lawful basis requirements for advertising-related personal data processing, GDPR Article 28 for data processor relationships with named vendors, and the ePrivacy Directive for behavioral advertising using cookies. CCPA and CPRA define sharing personal information with third parties for cross-context behavioral advertising as a 'sale' or 'sharing' requiring opt-out disclosure. The FTC Act applies to the accuracy of opt-out mechanism representations. 2) GOVERNANCE EXPOSURE: Medium. The disclosure of six specific advertising network vendors provides transparency about the scope of data sharing. However, the reference to 'a variety of' additional unnamed marketing analytics and website analysis providers means the complete list of recipients is not fully disclosed in the policy. CCPA's opt-out requirements and GDPR's transparency obligations may require more granular vendor disclosure. 3) JURISDICTION FLAGS: EU and EEA users require affirmative consent for behavioral advertising under GDPR and ePrivacy; the default opt-out stated in the policy addresses this requirement. UK users are subject to equivalent PECR requirements. California users have CCPA opt-out rights for sale or sharing of personal information with advertising third parties. The policy's reference to users in 'certain jurisdictions' being opted out by default does not specify all jurisdictions where this treatment applies. 4) CONTRACT AND VENDOR IMPLICATIONS: Each named advertising vendor (Unity, Meta, LiftOff, Pangle, Moloco, Google) operates its own data processing terms. Organizations concerned about downstream data use by these vendors should review each vendor's data processing policies independently. Duolingo's data processing agreements with these vendors should include GDPR Article 28 compliant terms for EU user data. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should verify that the opt-out mechanism in app Settings is fully effective in preventing data transmission to all named and unnamed advertising vendors. The CCPA 'Do Not Sell My Personal Information' link visible on the Duolingo website footer should be evaluated for compliance with CCPA opt-out requirements. EU and UK consent audit trails should confirm that the default opt-out is implemented at the data-transmission level, not merely at the advertising-display level.
This provision discloses that personal information is shared with six named advertising network vendors and unspecified additional marketing analytics and website analysis providers for cross-site advertising and market research purposes. The default opt-out for EU and UK users reflects applicable regulatory requirements in those jurisdictions.
Under this provision, personal information about Duolingo usage and other website activity may be shared with advertising networks including Unity, Meta, LiftOff, Pangle, Moloco, and Google for personalized advertising. Users can opt out of personalized advertising in app Settings; EU and UK users are opted out by default.
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