What can I do about this clause?

{'method': 'IN_APP', 'recipient': 'https://www.duolingo.com/settings/account', 'difficulty': 'MODERATE', 'action_type': 'DELETE_DATA', 'instructions': 'Go to your Duolingo account settings and request account deletion, which will trigger a data deletion request. Note that the perpetual content license may mean previously submitted content is not fully removed — contact privacy@duolingo.com for a specific data deletion request.', 'deadline_days': None, 'deadline_hours': None}

Which regulatory agencies enforce this type of clause?

{'agency': 'FTC', 'reason': 'The FTC has authority over unfair or deceptive data practices under Section 5 of the FTC Act, including overbroad content license grants that are not clearly disclosed to consumers at the point of submission.', 'complaint_url': 'https://reportfraud.ftc.gov/'}

What is the severity of this clause?

ConductAtlas classifies this Perpetual User Content License clause as high severity. Severity reflects the magnitude of rights affected, the breadth of users impacted, and the degree of discretion the platform retains.

Do other platforms have similar clauses?

Yes. ConductAtlas has identified similar Perpetual User Content License clauses across approximately 1 other tracked platforms. You can compare how platforms differ on this clause type in the cross-platform comparison view.

Perpetual User Content License — Duolingo

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What it is

Any content you post on Duolingo — including voice recordings, forum posts, and profile content — can be used by Duolingo forever, for any purpose including advertising, without paying you.

Consumer impact (what this means for users)

Voice recordings made during Duolingo lessons, profile photos, and any other content you submit can be used by Duolingo commercially and permanently, including in promotional materials, without any compensation or further consent required from you.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.

Delete Your Data

Go to your Duolingo account settings and request account deletion, which will trigger a data deletion request. Note that the perpetual content license may mean previously submitted content is not fully removed — contact privacy@duolingo.com for a specific data deletion request.

Cross-platform context

See how other platforms handle Perpetual User Content License and similar clauses.

Compare across platforms →

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Why it matters (compliance & risk perspective)

This license is permanent and irrevocable, meaning even if you delete your account or the content, Duolingo may retain the right to continue using what you previously submitted.

View original clause language

By submitting or posting Content on areas of the Service that are accessible by the public or other users, you grant Duolingo a worldwide, royalty-free, fully paid-up, non-exclusive, perpetual, irrevocable, transferable, and fully sublicensable license, without additional consideration to you or any third party, to reproduce, distribute, perform and display (publicly or otherwise), create derivative works of, adapt, modify and otherwise use, analyze and exploit such Content, in any format or media now known or hereafter developed, and for any purpose (including promotional purposes, such as testimonials).

Institutional analysis (Compliance & legal intelligence)

REGULATORY FRAMEWORK: This provision engages GDPR Articles 6 and 7 (lawful basis and consent) for EU/EEA users — a perpetual, irrevocable license is difficult to reconcile with the GDPR right to withdraw consent under Art. 7(3) and the right to erasure under Art. 17. It also implicates CCPA/CPRA §1798.100 et seq. regarding consumers' rights to deletion of personal information where such information is embedded in licensed content. COPPA (15 U.S.C. §6501) is relevant where content is submitted by users under 13. The Illinois Biometric Information Privacy Act (BIPA, 740 ILCS 14) may be engaged if voice recordings constitute biometric identifiers.

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Applicable agencies

FTC

The FTC has authority over unfair or deceptive data practices under Section 5 of the FTC Act, including overbroad content license grants that are not clearly disclosed to consumers at the point of submission.
File a complaint →

Provision details

Document information

Document

Duolingo Terms of Service

Entity

Duolingo

Document last updated

April 29, 2026

Tracking information

First tracked

April 18, 2026

Last verified

April 18, 2026

Record ID

CA-P-002773

Document ID

CA-D-00085

Evidence Provenance

Source URL

https://www.duolingo.com/terms

Wayback Machine

View archived versions →

SHA-256

d19834a28338bd25c025cefc24f18f933e0381108cf4fd3784c6e64a4a6f59fb

Verified

✓ Snapshot stored ✓ Change verified

How to Cite

ConductAtlas Policy Archive
Entity: Duolingo | Document: Duolingo Terms of Service | Record: CA-P-002773
Captured: 2026-04-18 09:26:58 UTC | SHA-256: d19834a28338bd25…
URL: https://conductatlas.com/platform/duolingo/duolingo-terms-of-service/perpetual-user-content-license/
Accessed: May 2, 2026

Classification

Severity

High

Perpetual User Content License