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 endeavor to ensure that, by default, we only collect and process your Data needed to provide you access to the Platform and our Services...This means that we will neither publish nor share your Data by default.
We use industry standard technical and organizational measures to secure the information we store.
We maintain administrative, technical, and physical safeguards to protect your personal information. When we collect or transmit sensitive information such as a credit or debit card number, we use Payment Card Industry (PCI) standards to protect that information.
"Duolingo commits to resolve DPF Principles-related complaints about our collection and use of your personal information.Excerpt from Duolingo's Privacy Policy
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The clause states: “Duolingo commits to resolve DPF Principles-related complaints about our collection and use of your personal information.”
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