Duolingo states it does not collect personal data from children under 13 without parental consent, and will delete such data if collected accidentally, but parents must contact the company directly if they believe their child's data was collected without consent.
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 operationalizes Duolingo's compliance with the Children's Online Privacy Protection Act (COPPA) by establishing procedures for parental consent verification, data retention restrictions for minors, and remediation pathways when unauthorized collection occurs. The requirement to delete discovered data and maintain a contact mechanism creates an ongoing operational obligation for the company.
Interpretive note: The adequacy of Duolingo's age verification and parental consent mechanisms is not fully described in the policy text, making it difficult to assess whether the stated COPPA compliance approach satisfies the FTC's verifiable parental consent standard in practice.
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 →Removed mention of separate experience for younger users and family features management, and added specific contact email (privacy@duolingo.com) for parental concerns instead of proactive deletion language.
View full change record →If your child under 13 uses Duolingo without parental consent being properly obtained, their personal data may have been collected; parents must proactively contact Duolingo to request deletion of that data. The policy places the burden of notification on parents rather than providing automatic protections.
How other platforms handle this
You must be at least 13 years old to use our Services. If you are under 18, you must have your parent or guardian's permission to use our Services. Certain Services or features may have higher age requirements.
Without limiting the generality of the foregoing, any access to, or use of, the Service by anyone who is a minor (which is under the age of 18 in most jurisdictions) in any applicable jurisdiction (a "Minor") is strictly prohibited and in violation of these Terms, unless such access and/or use is su...
"Duolingo does not knowingly collect personal information from children under 13 without parental consent. If we learn that we have collected personal information from a child under 13 without parental consent, we will delete that information as quickly as possible. If you are a parent or guardian and believe your child has provided us with personal information without your consent, please contact us at privacy@duolingo.com.Excerpt from Duolingo's Privacy Policy
(1) REGULATORY LANDSCAPE: This provision directly engages COPPA, enforced by the FTC, which requires verifiable parental consent before collecting personal information from children under 13 in the US.
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This provision operationalizes Duolingo's compliance with the Children's Online Privacy Protection Act (COPPA) by establishing procedures for parental consent verification, data retention restrictions for minors, and remediation pathways when unauthorized collection occurs. The requirement to delete discovered data and maintain a contact mechanism creates an ongoing operational obligation for the company.
If your child under 13 uses Duolingo without parental consent being properly obtained, their personal data may have been collected; parents must proactively contact Duolingo to request deletion of that data. The policy places the burden of notification on parents rather than providing automatic protections.
ConductAtlas has identified this type of provision across 2 platforms. See the full comparison.
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