Duolingo's main service is not for children under 13, and the company states it does not knowingly collect personal information from under-13 users. Parents who want to set up accounts for younger children are directed to a separate product called Duolingo ABC.
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The provision establishes COPPA compliance architecture by restricting the main platform to users 13 and older and directing under-13 users to a separate product, which is directly relevant for parents and for institutional compliance teams managing youth-facing deployments.
Interpretive note: The document does not describe the specific technical age-verification mechanisms in place, and the adequacy of stated measures for COPPA compliance depends on operational implementation not fully described in this document.
Parents whose children under 13 have created Duolingo accounts on the main platform should contact privacy@duolingo.com, as the terms state the platform does not knowingly collect personal information from under-13 users and accounts can be removed.
How other platforms handle this
The Service is not directed to children under the age of 16. If you are under the age of 16, you may only use the Service with the involvement and consent of a parent or guardian. If you are a parent or guardian and you are aware that your child has provided us with personal information without your...
The Services are not directed to children under 13. We do not knowingly collect personally identifiable information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at priv...
YOU MUST BE AND HEREBY AFFIRM THAT YOU ARE AN ADULT OF THE LEGAL AGE OF MAJORITY IN YOUR COUNTRY OR STATE OF RESIDENCE. If you are under the legal age of majority, your parent or legal guardian must consent to this agreement.
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"The Services are not directed to children under 13. If you learn that your child under 13 has created an account on Duolingo, please contact us at privacy@duolingo.com. We do not knowingly collect personally identifiable information from children under the age of 13. Parents or guardians can create a Duolingo account for their child under 13 via Duolingo ABC.— Excerpt from Duolingo's Duolingo Terms of Service
(1) REGULATORY LANDSCAPE: The provision directly implicates COPPA, which is enforced by the FTC and requires verifiable parental consent before collecting personal information from children under 13. The provision also engages state-level children's privacy laws, including California's Age-Appropriate Design Code (AB 2273) and similar legislation in other states, which may impose additional obligations. For EEA users, GDPR Article 8 sets the age of digital consent at 16 (or lower if member states have set a minimum of 13), which may require additional consent mechanisms for teenage users. (2) GOVERNANCE EXPOSURE: Medium. The terms state that Duolingo does not knowingly collect personal information from under-13 users and provides a contact for parents, but the document does not detail the specific technical or procedural age-verification mechanisms in place, which is a standard area of FTC scrutiny in COPPA enforcement. (3) JURISDICTION FLAGS: US federal COPPA obligations apply to all users under 13 regardless of geography. California's Age-Appropriate Design Code imposes additional requirements for minors under 18. GDPR member states have varying age of digital consent thresholds. UK Children's Code (Age Appropriate Design Code) applies to UK users under 18. (4) CONTRACT AND VENDOR IMPLICATIONS: Educational institutions and organizations deploying Duolingo for students should assess whether their student population includes under-13 users and evaluate whether COPPA-compliant consent mechanisms have been implemented. FERPA considerations may also apply for school-managed deployments. (5) COMPLIANCE CONSIDERATIONS: Legal teams should verify that the age-gating mechanism on the main platform is technically implemented and auditable, and that the Duolingo ABC product has appropriate COPPA-compliant parental consent mechanisms. The FTC has brought enforcement actions against platforms with inadequate COPPA age-verification and parental consent processes.
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The provision establishes COPPA compliance architecture by restricting the main platform to users 13 and older and directing under-13 users to a separate product, which is directly relevant for parents and for institutional compliance teams managing youth-facing deployments.
Parents whose children under 13 have created Duolingo accounts on the main platform should contact privacy@duolingo.com, as the terms state the platform does not knowingly collect personal information from under-13 users and accounts can be removed.
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