If Duolingo is sold, merged, or involved in a business transaction, your personal data may be transferred to the acquiring or merging company.
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 reserves the right to transfer all user personal data, including learning history, identifiers, and payment information, to a third party in the context of a corporate transaction, without requiring separate user consent at the time of transfer.
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 provision notifies users that their personal data may be shared or transferred in corporate transactions including mergers and acquisitions, a significant privacy scenario not previously disclosed.
View full change record →The policy states that user personal data may be shared with acquiring parties during or following a merger, acquisition, or asset sale, potentially subjecting that data to a different organization's privacy practices.
How other platforms handle this
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.
to request that your data be transferred to a third party (data portability)
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.
"We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.Excerpt from Duolingo's Privacy Policy
REGULATORY LANDSCAPE: Corporate transaction data transfers engage GDPR requirements for lawful processing and notification of data subjects where a change of controller occurs.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
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The policy reserves the right to transfer all user personal data, including learning history, identifiers, and payment information, to a third party in the context of a corporate transaction, without requiring separate user consent at the time of transfer.
The policy states that user personal data may be shared with acquiring parties during or following a merger, acquisition, or asset sale, potentially subjecting that data to a different organization's privacy practices.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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