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This provision discloses that Duolingo's website places targeting cookies from Google, Meta, Amazon, and unspecified other companies, which those companies may use to track user activity across multiple websites for personalized advertising purposes.
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
This provision establishes that cross-site behavioral tracking occurs through third-party cookies placed by named advertising platforms, and that users in the EU and UK are opted out of personalized advertising by default while users in other jurisdictions must actively opt out.
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 →Under this provision, Duolingo's website places targeting cookies from Google, Meta, Amazon, and other companies that may track browsing activity across multiple websites. Users can manage or reject these cookies through the Duolingo Privacy Preference Center or opt out of personalized advertising in app Settings.
Cross-platform context
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"Please note that our cookies include Targeting Cookies from Google, Meta, Amazon, and other companies, which these companies may use to track your activities across multiple websites to deliver personalized advertising to you.Excerpt from Duolingo's Privacy Policy
1) REGULATORY LANDSCAPE: This provision implicates the EU ePrivacy Directive (Cookie Law) and GDPR consent requirements for EU and EEA users, requiring prior informed consent before placing non-essential tracking cookies. UK PECR imposes equivalent requirements for UK users. The CCPA and California Privacy Rights Act require disclosure of cross-context behavioral advertising and provide opt-out rights for California residents. The FTC Act is relevant to the accuracy of consent and opt-out mechanism representations. 2) GOVERNANCE EXPOSURE: Medium. The policy discloses that EU and UK users are opted out of personalized advertising by default, which aligns with GDPR and PECR requirements. However, the policy does not specify whether targeting cookies are blocked by default for EU users or whether opt-out occurs at the advertising-delivery level only. This distinction may affect compliance posture under applicable cookie consent requirements. 3) JURISDICTION FLAGS: EU and EEA users require prior consent for non-essential cookies under GDPR and the ePrivacy Directive. UK users are subject to PECR. California users have CCPA opt-out rights for cross-context behavioral advertising. The policy's reference to 'other companies' placing targeting cookies, without exhaustive disclosure, may raise transparency concerns under GDPR Article 13. 4) CONTRACT AND VENDOR IMPLICATIONS: The involvement of Google, Meta, and Amazon as cookie vendors means their respective data processing terms govern how tracked data is used beyond Duolingo's platform. Procurement and compliance teams should assess whether Duolingo's cookie consent implementation satisfies the consent standards required by each named vendor's own terms and applicable law. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should audit the implementation of the Privacy Preference Center to confirm that non-essential cookies are not loaded prior to user consent for EU and UK users. The cookie list page referenced in the policy should be reviewed for completeness and currency. CCPA opt-out disclosures should be verified against California regulatory guidance on cross-context behavioral advertising.
This provision establishes that cross-site behavioral tracking occurs through third-party cookies placed by named advertising platforms, and that users in the EU and UK are opted out of personalized advertising by default while users in other jurisdictions must actively opt out.
Under this provision, Duolingo's website places targeting cookies from Google, Meta, Amazon, and other companies that may track browsing activity across multiple websites. Users can manage or reject these cookies through the Duolingo Privacy Preference Center or opt out of personalized advertising in app Settings.
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