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

Duolingo May Refuse Data Subject Rights Requests

Common · 250 of 343 platforms
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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 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 →
Medium Apr 21, 2026

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

Canva

In some circumstances Canva will not be able to comply with your request regarding your personal data. If we are unable to remove any of your information, we will explain why.

Patreon

In order to prevent an unauthorized takeover of your account or unauthorized access to your personal data, we may decline deletion of, access to, or recovery of your account via an authorized agent at our sole discretion.

RunPod

Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make...we will let you know our grounds...

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
these rights are not absolute and Duolingo may refuse requests to exercise data subject rights if there is a legitimate reason, such as if we cannot authenticate your identity, if the request could violate the rights of a third party or applicable law...

Excerpt from Duolingo's Privacy Policy

Provision details

Document information
Document
Duolingo Privacy Policy
Entity
Duolingo
Date stated by the document
May 26, 2026
As printed in Duolingo’s text (version CA-V-002995), not a ConductAtlas date.
Tracking information
First captured by ConductAtlas
April 18, 2026
Text quoted from version
CA-V-002995, captured May 27, 2026
Record ID
CA-P-022483
Document ID
CA-D-000084
Evidence Provenance
Source URL
Wayback Machine
Extracted-text SHA-256 (version CA-V-002995)
a2db150d3f64492424b4ebfc2ae932cff447143156401a12de97216813157c2a
Analysis generated
July 9, 2026 09:23 UTC
Methodology
Evidence
✓ Excerpt found in version CA-V-002995, captured May 27, 2026 (checked Oct. 5, 2026)
Citation Record
Entity: Duolingo
Document: Duolingo Privacy Policy
Record ID: CA-P-022483
Version: CA-V-002995
Captured: 2026-05-27 00:13:09 UTC
SHA-256: a2db150d3f644924…
URL: https://conductatlas.com/platform/duolingo/duolingo-privacy-policy/provision/CA-P-022483/duolingo-may-refuse-data-subject-rights-requests/
Accessed: Nov. 2, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Categories

Other risks in this policy

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Frequently Asked Questions

What does Duolingo's Duolingo May Refuse Data Subject Rights Requests clause do?

The clause states: “these rights are not absolute and Duolingo may refuse requests to exercise data subject rights if there is a legitimate reason, such as if we cannot authenticate your identity, if the request could violate the rights of a third party or applicable law...”

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 250 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.