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

FullStory and Session Replay Activity Logging

Medium severity Explicit document language Common · 295 of 352 platforms
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Document Record

What it is

This provision discloses that FullStory and a Session Replay service log user activity including clicks, mouse movements, scrolling, typing, browser and device information, IP address, pages visited, and learning activity. Users can disable these services using the Tracking toggle in app Settings; both are disabled by default for Child Users.

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

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 10, 2026
Last Seen
This clause type exists across 4186 other provisions on other platforms.

Consumer impact (what this means for users)

Under this provision, Duolingo logs detailed session activity including typing, mouse movements, and learning answers through FullStory and a Session Replay service by default for non-child users. Users can disable this recording using the Tracking toggle in app Settings.

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.
  • Opt Out of Arbitration
    Open the Duolingo app, navigate to Settings, locate the Tracking toggle, and disable it to stop FullStory and Session Replay from recording your activity.

How other platforms handle this

Baseten Medium

Category F: Internet or other similar network activity. Examples: Interaction with our Service or advertisement. Collected: Yes.

ZipRecruiter Medium

You may give us your Identity Data, Contact Data, Financial Data, Profile Data, and other information by filling in forms or by corresponding with us by post, phone, e-mail or otherwise.

NVIDIA NIM Medium

telemetry information collected includes: (i) microservice settings, (ii) usage data and (iii) hardware environment.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
When you use Duolingo in our app or on our website, some of your activity will be logged by services called FullStory and Session Replay.

Excerpt from Duolingo's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1) REGULATORY LANDSCAPE: Session replay tools that capture keystroke-level typing activity may implicate wiretapping and electronic communications interception statutes, including the California Invasion of Privacy Act and analogous state wiretapping laws, depending on how the …

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
ePrivacy Directive
European Union
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
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-016018
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-016018
Captured: 2026-07-09 09:23:37 UTC
SHA-256: ffd79e13b1f23d8f…
URL: https://conductatlas.com/platform/duolingo/duolingo-privacy-policy/provision/CA-P-016018/fullstory-and-session-replay-activity-logging/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Frequently Asked Questions

What does Duolingo's FullStory and Session Replay Activity Logging clause do?

This provision discloses that FullStory and a Session Replay service log user activity including clicks, mouse movements, scrolling, typing, browser and device information, IP address, pages visited, and learning activity. Users can disable these services using the Tracking toggle in app Settings; both are disabled by default for Child Users.

How does this clause affect you?

Under this provision, Duolingo logs detailed session activity including typing, mouse movements, and learning answers through FullStory and a Session Replay service by default for non-child users. Users can disable this recording using the Tracking toggle in app Settings.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 295 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.