“Duolingo collects personal information from children under the age of 13 for the sole purpose of performing internal operations of the Service.”
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 clause limits the permissible use of personal information collected from children under 13 to internal operations, excluding other uses such as advertising or third-party sharing.
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 →If your child is under 13, Duolingo's collection of their personal information is restricted to the sole purpose of performing the Service's internal operations.
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"Duolingo collects personal information from children under the age of 13 for the sole purpose of performing internal operations of the Service.Excerpt from Duolingo's Privacy Policy
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The clause limits the permissible use of personal information collected from children under 13 to internal operations, excluding other uses such as advertising or third-party sharing.
If your child is under 13, Duolingo's collection of their personal information is restricted to the sole purpose of performing the Service's internal operations.
ConductAtlas has identified this type of provision across 285 platforms. See the full comparison.
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