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
we will delete your account data after three years of inactivity.
We will retain your Data for as long as necessary: (i) to achieve the purposes as set out in this Policy; (ii) as required by applicable laws and regulations, including any mandated retention periods...
When Personal Information is no longer needed for the purposes for which it was collected, we securely delete, anonymize, or put it beyond use.
"If we discover that we have unknowingly collected additional personal information from these children, we will delete it.Excerpt from Duolingo's Privacy Policy
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The clause states: “If we discover that we have unknowingly collected additional personal information from these children, we will delete it.”
ConductAtlas has identified this type of provision across 267 platforms. See the full comparison.
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