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 provision establishes the procedural framework governing policy modifications and defines when users receive notice of changes to data practices. It creates a distinction between material changes (which require advance notice) and other updates (which may not require the same notice mechanism).
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 →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.
How other platforms handle this
We may update these Terms from time to time. If we make changes that we believe will materially affect your rights or obligations, we will notify you by email or through our developer channels. Your continued use of the Platform after we post updated Terms constitutes your acceptance of those change...
Shopify reserves the right to modify this Acceptable Use Policy at any time. Changes will be effective upon posting to the website. Your continued use of the Shopify Services following the posting of changes will constitute your acceptance of such changes.
We will tell you about any changes to these Terms at least 2 months before they take effect by sending you a notification in the Revolut app. If you don't tell us that you disagree with the changes before they take effect, you'll be treated as accepting them. If you do tell us you disagree, we will ...
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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 provision establishes the procedural framework governing policy modifications and defines when users receive notice of changes to data practices. It creates a distinction between material changes (which require advance notice) and other updates (which may not require the same notice mechanism).
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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