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
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.
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.
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...
"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
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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...”
ConductAtlas has identified this type of provision across 250 platforms. See the full comparison.
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