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The agreement states that all payments are nonrefundable, with no refunds or credits for virtual items or partially used subscription periods, subject to applicable law. Purchases made through Apple or Google app stores are subject to those platforms' refund policies, not Duolingo's.
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
This provision establishes a blanket no-refund policy for virtual items and subscription periods, with a jurisdictional carve-out acknowledging that applicable law may override this term. The routing of app store refund responsibility to Apple and Google creates a separate procedural pathway for a significant portion of users.
Under this clause, users who cancel subscriptions retain access through the end of the current billing period but are not entitled to a refund for the unused portion. Users who purchased through Apple or Google app stores must seek refunds directly from those platforms, as the agreement states Duolingo cannot process those refunds.
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"All payments are nonrefundable and there are no refunds or credits for Virtual Items or partially used membership periods, unless otherwise required by the law in your jurisdiction. If you cancel your periodic subscription to a paid Duolingo service, you will continue to have access to the service through the end of your current billing period. Please note that if you made purchases on Duolingo through the Apple or Google app stores, payments and refunds are handled by Apple or Google, respectively, and Duolingo cannot issue refunds for those purchases.Excerpt from Duolingo's Terms of Service
(1) REGULATORY LANDSCAPE: No-refund policies in consumer subscription services engage state consumer protection statutes and, in the EU, the Consumer Rights Directive, which provides a 14-day right of withdrawal for digital services contracts in certain circumstances. The FTC's rules on negative option marketing and subscription cancellation requirements are relevant to the auto-renewal and no-refund structure. California's Automatic Renewal Law imposes specific disclosure and cancellation requirements for auto-renewing subscriptions. (2) GOVERNANCE EXPOSURE: Medium. The blanket no-refund assertion is qualified by 'unless otherwise required by the law in your jurisdiction,' which acknowledges jurisdictional variance but places the burden on users to identify applicable protections. The division of refund responsibility between Duolingo and app store platforms may create friction for users seeking refunds. (3) JURISDICTION FLAGS: EU users may have statutory withdrawal rights under the Consumer Rights Directive that supersede the no-refund policy, depending on the nature of the digital service and consent to immediate performance. California's Automatic Renewal Law creates specific disclosure and refund obligations that may constrain the no-refund policy's enforceability. UK consumers have similar protections under the Consumer Rights Act 2015. (4) CONTRACT AND VENDOR IMPLICATIONS: The delegation of refund processing to Apple and Google for app store purchases represents a limitation on Duolingo's direct contractual accountability for a significant transaction channel. Procurement assessments should note that refund disputes for app store purchases must be addressed through platform-specific mechanisms rather than Duolingo's customer service. (5) COMPLIANCE CONSIDERATIONS: Legal teams should verify that Duolingo's subscription disclosure and cancellation mechanisms comply with the FTC's negative option rule requirements and applicable state automatic renewal laws, particularly in California, New York, and other jurisdictions with specific statutory frameworks.
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This provision establishes a blanket no-refund policy for virtual items and subscription periods, with a jurisdictional carve-out acknowledging that applicable law may override this term. The routing of app store refund responsibility to Apple and Google creates a separate procedural pathway for a significant portion of users.
Under this clause, users who cancel subscriptions retain access through the end of the current billing period but are not entitled to a refund for the unused portion. Users who purchased through Apple or Google app stores must seek refunds directly from those platforms, as the agreement states Duolingo cannot process those refunds.
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