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.
If you are located in the European Union, we will not send promotional emails without your consent.
If you are 'opted out' of tailored advertising, you will receive less relevant advertising, including on our free Service Option, as well as our paid Service Option, as applicable (for example, advertising in podcasts).
"non-Child Users will not be suggested to Child Users, and Child Users will not be suggested to non-Child Users.Excerpt from Duolingo's Privacy Policy
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The clause states: “non-Child Users will not be suggested to Child Users, and Child Users will not be suggested to non-Child Users.”
ConductAtlas has identified this type of provision across 140 platforms. See the full comparison.
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