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 the event you still have unresolved concerns, you also have the right to lodge a complaint with a supervisory authority, in particular to the data protection authority in the country of your habitual residence or place of work.
If the EU or UK General Data Protection Regulation applies to our processing of your personal data, you have the right to lodge a complaint in the Member State of the European Union of your habitual residence, place of work, or the alleged violation of the GDPR.
"You may also have the right to make a GDPR complaint to the relevant Supervisory Authority.Excerpt from Duolingo's Privacy Policy
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
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The clause states: “You may also have the right to make a GDPR complaint to the relevant Supervisory Authority.”
ConductAtlas has identified this type of provision across 277 platforms. See the full comparison.
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