Children under 13 are not permitted to use Duolingo's standard services, and teenagers between 13 and 18 need a parent's permission — though the terms do not specify how that consent is verified.
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
Duolingo's platform is widely used by minors, including through Duolingo for Schools; the adequacy of parental consent mechanisms and age verification is a significant compliance consideration under COPPA and equivalent laws.
Interpretive note: The terms prohibit under-13 use but do not describe the operational verification mechanism; COPPA compliance depends on practices not fully described in the terms document itself.
Parents should be aware that children under 13 are technically prohibited from using the standard service, and that the terms do not describe a verified parental consent process for users aged 13-17.
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 the age of 13. If you are under 13 years old, please do not use the Services. If you are between the ages of 13 and 18 (or the applicable age of majority in your jurisdiction), you may only use the Services with the consent of your parent or legal guardian.— Excerpt from Duolingo's Duolingo Terms of Service
REGULATORY LANDSCAPE: This provision directly engages COPPA, enforced by the FTC, which requires verifiable parental consent before collecting personal information from children under 13. The provision's prohibition on under-13 use, without a described verification mechanism, raises questions about whether COPPA compliance is fully operationalized at the account creation stage. For educational deployments, FERPA (enforced by the Department of Education) may apply where Duolingo for Schools is used and student records are involved. EU jurisdictions impose age verification requirements under GDPR Article 8 for digital services, with the age threshold varying by member state (typically 13-16). GOVERNANCE EXPOSURE: High. Duolingo's broad consumer user base and brand recognition among children creates significant COPPA compliance exposure. The terms' prohibition on under-13 use is not supported by a described verification or parental consent mechanism in the terms themselves, though operational practices may differ. JURISDICTION FLAGS: All U.S. jurisdictions are subject to COPPA. EU member states have varying age thresholds under GDPR Article 8. UK GDPR and the Age Appropriate Design Code (Children's Code) impose additional obligations for services likely to be accessed by children. Educational deployments in the U.S. trigger FERPA obligations. CONTRACT AND VENDOR IMPLICATIONS: Schools and educational institutions deploying Duolingo for Schools should confirm that separate terms or data processing agreements address FERPA and COPPA obligations, and that appropriate parental consent mechanisms are in place for student users. COMPLIANCE CONSIDERATIONS: Legal teams should assess whether operational age verification mechanisms are consistent with COPPA's verifiable parental consent requirements, review Duolingo's separate Children's Privacy Policy for consistency with these terms, evaluate FERPA compliance for school deployments, and confirm that GDPR Article 8 age-of-consent requirements are operationally supported for EU users.
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Duolingo's platform is widely used by minors, including through Duolingo for Schools; the adequacy of parental consent mechanisms and age verification is a significant compliance consideration under COPPA and equivalent laws.
Parents should be aware that children under 13 are technically prohibited from using the standard service, and that the terms do not describe a verified parental consent process for users aged 13-17.
ConductAtlas has identified this type of provision across 9 platforms. See the full comparison.
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