Duolingo transfers and stores user data in the United States, where privacy protections may differ from those in a user's home country.
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 states that by using the service, users consent to data transfer to the US, which for EU and UK users intersects with GDPR requirements for lawful international data transfer mechanisms that go beyond consent alone.
Interpretive note: The policy does not specify which GDPR-compliant transfer mechanisms Duolingo relies upon beyond referencing user consent, creating ambiguity about the adequacy of international transfer protections for EU and UK users.
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 →This new provision explicitly discloses international data transfer practices and obtains user consent for processing in the U.S., with notice that users may have fewer protections than under local law.
View full change record →The policy states that personal data is transferred to and stored in the United States, potentially under legal frameworks with different privacy protections than those applicable in EU, UK, or other jurisdictions.
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Further, you may take legal actions in relation to any potential breach of your rights regarding the processing of your Personal Information, as well as to lodge complaints before the competent data prot...
"Duolingo is based in the United States and the information we collect is governed by U.S. law. By accessing or using our services or otherwise providing information to us, you consent to the processing, transfer, and storage of information in and to the U.S. and other countries, where you may not have the same rights and protections as you do under local law.Excerpt from Duolingo's Privacy Policy
REGULATORY LANDSCAPE: International transfers of personal data from the EU and UK to the United States engage GDPR Chapter V and UK GDPR transfer provisions.
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The policy states that by using the service, users consent to data transfer to the US, which for EU and UK users intersects with GDPR requirements for lawful international data transfer mechanisms that go beyond consent alone.
The policy states that personal data is transferred to and stored in the United States, potentially under legal frameworks with different privacy protections than those applicable in EU, UK, or other jurisdictions.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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