Provision record
Duolingo · Duolingo Privacy Policy · View original document ↗

Advertising and Analytics Data Sharing

High severity Medium confidence Explicit document language Common · 290 of 352 platforms
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Document Record

What it is

Duolingo shares your personal information with advertising and analytics companies, including for those companies' own marketing purposes in some cases.

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)

The policy authorizes sharing personal data with third parties for the third parties' own marketing purposes, which in practice may include platforms such as Meta and Google, and which for EU and UK users requires valid consent under GDPR.

Interpretive note: The policy does not enumerate specific advertising and analytics partners by name in the visible text, creating some ambiguity about the full scope of third-party data sharing.

Recent Activity

This document changed recently

Medium May 27, 2026

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 →

Clause Stability Mostly Stable

1
Change
4
Months Monitored
May 12, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 5149 other provisions on other platforms.
This clause has changed once in 4 months of monitoring.

Change history

modified May 27, 2026

Language broadened from specific advertising partners to general third-party vendors/service providers, and added qualifier 'consistent with your consent where required' for marketing purposes sharing.

View full change record →

Consumer impact (what this means for users)

The policy states Duolingo may share personal data with advertising and analytics third parties, potentially including for those parties' own marketing uses, which affects how user data is used beyond Duolingo's own platform.

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
    California residents can opt out of sharing of personal data for advertising by emailing privacy@duolingo.com. EU and UK users can withdraw consent for advertising processing by emailing privacy@duolingo.com or adjusting cookie settings in the app or on duolingo.com.

How other platforms handle this

Glassdoor Medium

We will also provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected.

Square Medium

to request that your data be transferred to a third party (data portability)

Google Cloud Medium

Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
We may share your personal information with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. We also may share your information with third parties for their own marketing purposes, consistent with your consent where required.

Excerpt from Duolingo's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

REGULATORY LANDSCAPE: Sharing personal data with advertising partners for those partners' own marketing purposes implicates GDPR Article 6 lawful basis requirements and, where consent is relied upon, GDPR Article 7 validity requirements for EU and …

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →
  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

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
May 12, 2026
Last verified
May 12, 2026
Record ID
CA-P-011280
Document ID
CA-D-00084
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
2dade822ccc0a9857012fa095dd3b53bfd7ed24f07f06c2c24446c668fae1eea
Analysis generated
May 12, 2026 08:26 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Duolingo
Document: Duolingo Privacy Policy
Record ID: CA-P-011280
Captured: 2026-05-12 08:26:59 UTC
SHA-256: 2dade822ccc0a985…
URL: https://conductatlas.com/platform/duolingo/duolingo-privacy-policy/provision/CA-P-011280/advertising-and-analytics-data-sharing/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Duolingo's Advertising and Analytics Data Sharing clause do?

The policy authorizes sharing personal data with third parties for the third parties' own marketing purposes, which in practice may include platforms such as Meta and Google, and which for EU and UK users requires valid consent under GDPR.

How does this clause affect you?

The policy states Duolingo may share personal data with advertising and analytics third parties, potentially including for those parties' own marketing uses, which affects how user data is used beyond Duolingo's own platform.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.

Is ConductAtlas affiliated with Duolingo?

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