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

Anonymized Data Use for Any Purpose Including AI Training

Medium severity Medium confidence Explicit document language Unique · 0 of 352 platforms
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Document Record

What it is

This provision states that Duolingo may anonymize personal information and use the resulting de-identified data for any purpose, including AI model training, asserting that such data falls outside the definition of personal information because it cannot identify individuals.

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)

This provision reserves broad secondary use rights over de-identified data derived from user activity. The practical scope of this authorization depends on the robustness of the anonymization method applied, which the policy does not describe in technical detail; applicable law in some jurisdictions may impose standards for what constitutes adequate de-identification.

Interpretive note: The enforceability of the 'for any purpose' authorization depends on the robustness of the anonymization method applied, which the policy does not describe; applicable law in some jurisdictions may evaluate de-identification adequacy differently.

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 Stable

0
Changes
4
Months Monitored
Jul 9, 2026
First Seen
Jul 9, 2026
Last Seen

Consumer impact (what this means for users)

Under this provision, Duolingo may derive anonymized datasets from user personal information and use those datasets without stated purpose restriction, including for AI training. The policy asserts that anonymized data is not personal information, though applicable law in certain jurisdictions may evaluate de-identification adequacy differently.

Cross-platform context

See how other platforms handle Anonymized Data Use for Any Purpose Including AI Training and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
Duolingo may anonymize your personal information, and use this de-identified data for any purpose, such as better understanding learning trends and training artificial intelligence models. Such information is not considered personal information since it cannot identify any individual.

Excerpt from Duolingo's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1) REGULATORY LANDSCAPE: GDPR Recital 26 and applicable guidance from EU data protection authorities establish that de-identification must be robust and irreversible to remove data from GDPR scope; pseudonymized data does not qualify.

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 →

Provision details

Document information
Document
Duolingo Privacy Policy
Entity
Duolingo
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-016017
Document ID
CA-D-00084
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
ffd79e13b1f23d8f50cc63af7c7e06fe3d89fe994f3f6c441c5f01a292a571ad
Analysis generated
July 9, 2026 09:23 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Duolingo
Document: Duolingo Privacy Policy
Record ID: CA-P-016017
Captured: 2026-07-09 09:23:37 UTC
SHA-256: ffd79e13b1f23d8f…
URL: https://conductatlas.com/platform/duolingo/duolingo-privacy-policy/provision/CA-P-016017/anonymized-data-use-for-any-purpose-including-ai-training/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Duolingo's Anonymized Data Use for Any Purpose Including AI Training clause do?

This provision reserves broad secondary use rights over de-identified data derived from user activity. The practical scope of this authorization depends on the robustness of the anonymization method applied, which the policy does not describe in technical detail; applicable law in some jurisdictions may impose standards for what constitutes adequate de-identification.

How does this clause affect you?

Under this provision, Duolingo may derive anonymized datasets from user personal information and use those datasets without stated purpose restriction, including for AI training. The policy asserts that anonymized data is not personal information, though applicable law in certain jurisdictions may evaluate de-identification adequacy differently.

Is ConductAtlas affiliated with Duolingo?

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