Provision record
Duolingo · Duolingo Terms of Service · View original document ↗

Employer Code Provider Data Sharing

Medium severity Medium confidence Explicitdocumentlanguage Unique · 0 of 352 platforms
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Document Record

What it is

The agreement authorizes Duolingo to share individual usage data, as well as anonymized aggregate data, with the third-party organization that provided a user's Promotion Code, such as an employer. This sharing is conditioned on the user having redeemed a Code Provider-issued Promotion Code.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision authorizes disclosure of individual-level usage data to employer or organizational Code Providers, creating a secondary data disclosure pathway that users may not anticipate when using a benefit-provided subscription. The scope of 'individual usage data' is not further defined in the provision.

Interpretive note: The specific categories of data encompassed by 'individual usage data' are not defined in this provision, creating ambiguity about the scope of potential disclosure to Code Providers.

Clause Stability Stable

0
Changes
3
Months Monitored
Jul 9, 2026
First Seen
Jul 9, 2026
Last Seen

Consumer impact (what this means for users)

Under this clause, users who access Duolingo through an employer-provided or organizational Promotion Code consent to Duolingo sharing their individual usage data with that Code Provider. The agreement does not specify limits on the categories of usage data that may be shared.

Cross-platform context

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Monitoring

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▸ View Original Clause Language DOCUMENT RECORD
"
If you redeem a Promotion Code from a Code Provider, you understand and agree that Duolingo may share data relating to your use of the Promotion Code with your Code Provider, including both anonymized, aggregate data, and individual usage data.

Excerpt from Duolingo's Terms of Service

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision engages GDPR Article 6 lawful basis requirements and Article 13 transparency obligations for EU users, as the sharing of individual usage data with an employer constitutes a disclosure to a third party that requires a documented lawful basis. CCPA imposes disclosure obligations regarding third-party data sharing that are relevant to California users. Employment privacy laws in certain jurisdictions may impose additional restrictions on employer access to employee personal data derived from benefit programs. (2) GOVERNANCE EXPOSURE: Medium. The undefined scope of 'individual usage data' creates ambiguity about what specific data elements may be shared with Code Providers, limiting users' ability to assess the disclosure. Employers receiving this data may have separate legal obligations regarding its use depending on jurisdiction. (3) JURISDICTION FLAGS: EU and EEA users are subject to GDPR, which requires a specific lawful basis for each data sharing relationship and clear disclosure of the categories of data and recipients involved. The UK GDPR and Data Protection Act 2018 create similar requirements. California users have CCPA rights including the right to know about third-party disclosures of personal information. (4) CONTRACT AND VENDOR IMPLICATIONS: Employers deploying Duolingo through Code Provider arrangements should assess whether their receipt of individual employee usage data is consistent with their own privacy policies, employment agreements, and applicable employment privacy law. A data processing or sharing agreement with Duolingo may be warranted in regulated industries or jurisdictions. (5) COMPLIANCE CONSIDERATIONS: Legal teams at organizations acting as Code Providers should evaluate whether the receipt of individual employee usage data requires disclosure in employee privacy notices, consent mechanisms, or data protection impact assessments under applicable law.

Full institutional analysis

Regulatory citations, enforcement risk, and due diligence action items.

Applicable agencies

  • FTC
    The FTC's consumer protection and privacy authority is relevant to disclosure practices regarding third-party data sharing, including sharing with employer Code Providers.
    File a complaint →
  • State AG
    State attorneys general enforce CCPA and other state privacy laws that may require additional disclosure or consent for sharing individual usage data with third-party employers.
    File a complaint →

Provision details

Document information
Document
Duolingo Terms of Service
Entity
Duolingo
Document last updated
May 5, 2026
Tracking information
First tracked
April 18, 2026
Last verified
July 9, 2026
Record ID
CA-P-014348
Document ID
CA-D-00085
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
8b5399f8bdac8c2417a9e058d0f1636534227a752fe28cd240a84c400320905a
Analysis generated
April 18, 2026 09:26 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Duolingo
Document: Duolingo Terms of Service
Record ID: CA-P-014348
Captured: 2026-04-18 09:26:58 UTC
SHA-256: 8b5399f8bdac8c24…
URL: https://conductatlas.com/platform/duolingo/duolingo-terms-of-service/provision/CA-P-014348/employer-code-provider-data-sharing/
Accessed: July 25, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Duolingo's Employer Code Provider Data Sharing clause do?

This provision authorizes disclosure of individual-level usage data to employer or organizational Code Providers, creating a secondary data disclosure pathway that users may not anticipate when using a benefit-provided subscription. The scope of 'individual usage data' is not further defined in the provision.

How does this clause affect you?

Under this clause, users who access Duolingo through an employer-provided or organizational Promotion Code consent to Duolingo sharing their individual usage data with that Code Provider. The agreement does not specify limits on the categories of usage data that may be shared.

Is ConductAtlas affiliated with Duolingo?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Duolingo.