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 updated policy now discloses that audio collection for product improvement applies to all users across all platforms (iOS, Android, and web), whereas previously the policy stated audio was collected only from iOS users. Android and web users are now subject to audio collection for product improvement purposes. All users can opt out of audio sharing within app Settings.
View change record →The updated policy introduces a new Session Replay service that logs user activity alongside FullStory, capturing clicks, mouse movements, scrolling, typing, device information, navigation, and learning activity. Both services can be disabled using the Tracking toggle in app Settings, and both are automatically disabled for child users. The new Math Tutor feature shares audio with Apple for speech recognition and immediate deletion, but retains and shares text transcripts with AI vendors. For payment processing and fraud prevention, Duolingo may retain IP addresses beyond the standard 30-day period. You can disable both FullStory and Session Replay activity recording by toggling the Tracking setting within the app.
View change record →How other platforms handle this
These Cookies enable us and third parties to gain a better understanding of your interests. This allows us to display personalized ads...not only on our Services but also on those of third-party partners.
Ads for products intended for a limited audience should only be targeted to that audience. For example, if a credit card offer is limited to individuals over the age of 18, the offer's ad campaign must be age targeted to 18+.
If you enable location data for the mobile version of our services...we may use your location data to serve you geo-targeted ads for employers and other advertisers that are local to you.
"Users in certain jurisdictions (including the European Union and United Kingdom) are opted out of personalized advertising by default, but may opt in.Excerpt from Duolingo's Privacy Policy
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The clause states: “Users in certain jurisdictions (including the European Union and United Kingdom) are opted out of personalized advertising by default, but may opt in.”
ConductAtlas has identified this type of provision across 140 platforms. See the full comparison.
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