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
The CCPA provides California residents specific rights to delete their personal data that we collected from them and retained, subject to certain exceptions (the "right to delete").
"You can disable the Contact Sync feature and your sharing of contacts with Duolingo by accessing the Social Accounts section of the app Settings. This will also instruct Duolingo to automatically delete any previously shared information about your contacts.Excerpt from Duolingo's Privacy Policy
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
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The clause states: “You can disable the Contact Sync feature and your sharing of contacts with Duolingo by accessing the Social Accounts section of the app Settings. This will also instruct Duolingo to automatically delete any previously shared information about your contacts.”
ConductAtlas has identified this type of provision across 277 platforms. See the full comparison.
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