Duolingo may update its privacy policy and will notify users by email or website notice before material changes take effect.
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 policy commits to advance notification of material changes by email or website notice, but does not specify the notice period before changes become effective, and continued use of the service after notification may constitute acceptance.
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 →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 →This new provision establishes Duolingo's commitment to notifying users of material privacy policy changes via email or website notice, supporting user transparency and informed consent.
View full change record →The policy states that material changes will be communicated via email or website notice before they take effect, but does not specify a minimum notice period; users who miss these notifications may be bound by updated terms upon continued use.
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"We may update this privacy policy from time to time. If we make material changes, we will notify you by email or by posting a notice on our website prior to the change becoming effective. We encourage you to review the privacy policy whenever you access our services to stay informed about our information practices.— Excerpt from Duolingo's Duolingo Privacy Policy
REGULATORY LANDSCAPE: GDPR requires that users be informed of material changes to how their personal data is processed, and that a fresh lawful basis may be required where changes affect the purposes or scope of processing. CCPA requires disclosure of the effective date of the policy and that the policy reflect current data practices. The FTC has taken action against companies that materially change privacy practices without adequate notice. GOVERNANCE EXPOSURE: Low. The commitment to notify users of material changes before they take effect is a standard and relatively user-protective practice. The absence of a specified minimum notice period is common in consumer privacy policies. JURISDICTION FLAGS: EU and UK users may require fresh consent for material changes that affect the lawful basis for processing. California users are entitled to be notified of changes to the categories of personal information collected or the purposes for collection. CONTRACT AND VENDOR IMPLICATIONS: Institutional customers relying on specific data protection terms should include provisions in their agreements requiring notification of policy changes that may affect their obligations under applicable law. COMPLIANCE CONSIDERATIONS: Compliance teams should monitor for policy update notifications and assess whether any changes affect the lawful basis for processing, trigger re-consent requirements for EU and UK users, or require updates to vendor agreements or internal data governance documentation.
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The policy commits to advance notification of material changes by email or website notice, but does not specify the notice period before changes become effective, and continued use of the service after notification may constitute acceptance.
The policy states that material changes will be communicated via email or website notice before they take effect, but does not specify a minimum notice period; users who miss these notifications may be bound by updated terms upon continued use.
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