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
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If you are an individual consumer in an Applicable Country that requires consumer contracts to be governed by the laws of the Applicable Country, the Terms will be governed by the laws of the Applicable Country...
Except as provided in the dispute resolution section above, all claims arising out of or relating to these Terms will be brought exclusively in the federal or state courts of San Francisco, California.
"the applicable supplemental privacy policies and local laws will take precedence over this Privacy Policy to the extent they conflict.Excerpt from Duolingo's Privacy Policy
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The clause states: “the applicable supplemental privacy policies and local laws will take precedence over this Privacy Policy to the extent they conflict.”
ConductAtlas has identified this type of provision across 264 platforms. See the full comparison.
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