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 removes explicit language stating that Android users and website users are not subject to audio collection for product improvement purposes. Previously, the policy authorized audio collection only from iOS users, with an explicit carve-out for Android and web users. The revised language now states that all users may choose not to share audio within app Settings, suggesting audio collection may now occur across all platforms unless the opt-out mechanism is used. The practical operational effect of this change depends on whether Duolingo implements audio collection on Android and web platforms, which the policy change does not explicitly confirm. You can decline audio sharing for product improvement by adjusting the setting within the app.
View change record →The updated policy now discloses a new Math Tutor feature that processes audio through Apple for transcription; audio is deleted but text transcripts may be retained and shared with AI vendors. Duolingo also clarified that IP addresses may be retained longer than 30 days for paying subscribers specifically for payment processing and fraud prevention. The policy changed the Video Call feature from 'Duolingo offers' to 'Duolingo may offer', clarifying it is optional. You can disable FullStory and Session Replay activity recording using the Tracking toggle in app Settings.
View change record →How other platforms handle this
This Privacy Policy is also incorporated into and governed by our Terms of Use.
This Policy does not apply to Personal Data we process in our role as a data processor or service provider on behalf of our customers and partners.
In the event of any conflict between these Terms of Use and information provided by Customer Service or other portions of our websites, these Terms of Use will control.
"If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.Excerpt from Duolingo's Privacy Policy
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The clause states: “If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.”
ConductAtlas has identified this type of provision across 297 platforms. See the full comparison.
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