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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
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.
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.
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"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
(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.
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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.
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.
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