User Content License

What it is

Any content you submit to Duolingo — such as profile information, forum posts, or practice responses — can be used by Duolingo and its business partners in a wide range of ways, including for promotional purposes, without paying you.

Why it matters (compliance & governance perspective)

The license is sublicensable and transferable, meaning Duolingo can pass these rights to third parties such as partners or acquirers, and the license covers derivative works, which means modified versions of your content can also be used.

Consumer impact (what this means for users)

Content you submit to Duolingo may be used for promotional, commercial, or other business purposes by Duolingo and parties it authorizes, and this use does not require your separate consent or any payment to you.

What you can do

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: This provision engages GDPR Articles 6 and 7 (lawful basis and conditions for consent) for EU users, since the breadth of the license may exceed what users reasonably expect when submitting content in a language-learning context. The sublicensable and transferable nature of the license raises questions about data subject rights under GDPR Article 17 (right to erasure): deletion of an account may not automatically terminate all licensed uses of previously submitted content, creating a potential tension between the terms and GDPR obligations. The FTC's authority over deceptive practices is also relevant if the scope of use is not adequately disclosed at the point of content submission. GOVERNANCE EXPOSURE: Medium. The license is broad but is expressly limited to use in connection with the Services and Duolingo's business. The sublicensable and transferable language creates downstream risk, particularly in the context of corporate transactions (mergers, acquisitions) where content rights could transfer to a new entity. JURISDICTION FLAGS: EU/EEA and UK users may have additional protections under GDPR and the UK GDPR that limit Duolingo's ability to use personal data embedded in user content beyond the original purpose. California residents may assert rights under CCPA to know about and limit uses of their personal information, which could intersect with this license. CONTRACT AND VENDOR IMPLICATIONS: If Duolingo transfers or sublicenses user content to third-party vendors or partners, those arrangements should be assessed for compliance with applicable data processing agreements and GDPR Article 28 processor obligations. Procurement teams at organizations using Duolingo for Schools should assess whether student-generated content could fall within this license and whether that is appropriate under FERPA. COMPLIANCE CONSIDERATIONS: Legal teams should map what types of user-submitted content are subject to this license, assess whether the license scope is adequately disclosed to users at the point of submission, evaluate whether account deletion requests under GDPR Article 17 or CCPA effectively terminate the license, and determine whether separate data processing agreements are needed for institutional deployments.

Applicable agencies

Provision details

Other risks in this policy

• Mandatory Arbitration and Class Action Waiver high
• Account Suspension and Termination medium
• Disclaimer of Warranties low
• Limitation of Liability medium
• Indemnification medium
• Age Restriction and Parental Consent high

Related Analysis

• Robinhood's Agreement Authorizes Position Liquidation Without Prior Notice

  Buried in Robinhood's customer agreement is broad authority to close your positions, suspend your account, and force arbitration. Here is what it actually says.

• Stripe's Reserve and Hold Authority: What the Terms Authorize

  Stripe's terms authorize fund reserves, payout withholding, and account termination. Here is what the agreement states and what business owners should review.