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
Our AI Companion, Ebb, is intended to be used only by individuals 18 years or older.
They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser...
Teen Accounts will also be restricted from transacting with certain merchants and/or merchant categories, and we reserve the right to add further restrictions to, or close, Teen Accounts in our sole discretion.
"Child Users can search for other users, or be searched for by other users, but only by providing an exact username or a referral link.Excerpt from Duolingo's Privacy Policy
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The clause states: “Child Users can search for other users, or be searched for by other users, but only by providing an exact username or a referral link.”
ConductAtlas has identified this type of provision across 140 platforms. See the full comparison.
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