This provision authorizes Duolingo to record and store audio and text submitted through AI-powered features including Video Call, and to use those recordings and transcripts for product improvement and AI model training. The text and audio may also be shared with vendors including OpenAI and Google, subject to contractual restrictions on those vendors' independent use of the data.
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 authorizes Duolingo to retain AI interaction content and use it for AI model training purposes, and to share that content with named third-party AI vendors. The adequacy of the vendor contractual restrictions on secondary use may warrant independent compliance review, particularly under GDPR data minimization and purpose limitation principles.
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 →Under this provision, audio and text submitted during Video Call and other AI features may be shared with OpenAI and Google and stored by Duolingo for product improvement and AI model training. The policy advises users not to submit personal, sensitive, or confidential information in these interactions.
Cross-platform context
See how other platforms handle AI Audio Recording and Model Training and similar clauses.
Compare across platforms →"When you interact with Video Call or other AI-enabled features, the text and audio you submit may be shared with AI vendors such as OpenAI and Google. Duolingo's agreements with these AI vendors mean they are not permitted to use any personal information for their own purposes. Additionally, Duolingo may generate, record, and store audio recordings or transcripts of the text and audio you submit, and use these recordings or transcripts for product improvement and personalization purposes, including training and running Duolingo's own artificial intelligence models. Please do not submit any personal, sensitive, or confidential information when using Video Call or other AI features.Excerpt from Duolingo's Privacy Policy
1) REGULATORY LANDSCAPE: This provision implicates GDPR purpose limitation and data minimization principles, particularly regarding the retention and secondary use of audio recordings for AI training.
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This provision authorizes Duolingo to retain AI interaction content and use it for AI model training purposes, and to share that content with named third-party AI vendors. The adequacy of the vendor contractual restrictions on secondary use may warrant independent compliance review, particularly under GDPR data minimization and purpose limitation principles.
Under this provision, audio and text submitted during Video Call and other AI features may be shared with OpenAI and Google and stored by Duolingo for product improvement and AI model training. The policy advises users not to submit personal, sensitive, or confidential information in these interactions.
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