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

Employer Code Provider Data Sharing

Medium severity Medium confidence Explicit document language 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
4
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

See how other platforms handle Employer Code Provider Data Sharing and similar clauses.

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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 …

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →
  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

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: Sept. 8, 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.