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Plain-English summary
Duolingo's Privacy Policy indicates that your public profile content can be deleted by them at their discretion for any reason (risk_flags-1), and your data rights requests can be refused if they interfere with services (risk_flags-2). Your profile is public by default, making your information accessible to third-party web scrapers (data_use-1). Interactions with AI features may be recorded and used to train Duolingo's AI models (data_use-2), and your personal data may be shared with third parties for personalized advertising (data_use-3). Additionally, your IP address might be used to suggest connections with other users on shared networks (data_use-5) and retained longer for payment processing and fraud prevention (data_use-4), while targeting cookies from major ad networks track your activity across websites (data_use-6).
90% confidence
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Risk Flags
Critical terms that may pose a risk to users. These include actions or clauses that can lead to significant material, financial, or privacy harm. Includes items like account termination without cause or refund, mandatory arbitration, broad content ownership transfer, or disclaimers of all warranties and liabilities.
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Public Profile Information can be modified or deleted by Duolingo
Duolingo may restrict or delete Public Profile Information if it violates Community Guidelines or "for any other reason."
Why it matters: This means your publicly shared profile content, including submitted comments, likes, reactions, and celebrations, can be removed by Duolingo at their discretion, without necessarily providing a specific reason related to Community Guidelines.
Duolingo may restrict or delete Public Profile Information if it violates our Community Guidelines or for any other reason.
b. Profile & Public Profile Information, paragraph 5 · Citation strength: strong
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User data rights are not absolute
Duolingo may refuse requests to exercise data subject rights if there is a legitimate reason, such as if identity cannot be authenticated, the request could violate third-party rights or applicable law, or if it interferes with a Duolingo service or prevents delivery of a requested service.
Why it matters: Even if you attempt to exercise your data rights, Duolingo states they can deny your request for various reasons, including if it might hinder their services, which can make it challenging to control your personal information.
Please note that these rights are not absolute and Duolingo may refuse requests to exercise data subject rights if there is a legitimate reason, such as if we cannot authenticate your identity, if the request could violate the rights of a third party or applicable law, or if the request could interfere with a Duolingo service or prevent us from delivering a service you requested.
### Your Data Subject Rights, paragraph 4 · Citation strength: strong
Data Use & Sharing
This section reviews how your data is collected, used, and shared, focusing on aspects that may be concerning or unexpected. This includes broad data collection, sharing with third parties, or uses beyond the primary service purpose.
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Your Profile is public by default
By default, your Profile is public and visible to other Duolingo users and anyone else on the Internet, and third-party websites or web scrapers may be able to read, collect, and use your public information for their own purposes.
Why it matters: Your public profile information can be collected and used by third-party websites or web scrapers for their own purposes, potentially exposing more of your data than you intend.
By default, your Profile is public, and visible to other Duolingo users and anyone else on the Internet. In addition, your Public Profile Information may be publicly visible. If your Profile is public, third-party websites or web scrapers may be able to read, collect, and use your public information for their own purposes.
b. Profile & Public Profile Information, paragraph 3 · Citation strength: strong
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AI feature interactions may be recorded and used for product improvement and AI model training
When you interact with AI-enabled features, Duolingo may generate, record, and store audio recordings or transcripts of the text and audio you submit, and use these for product improvement and personalization, including training their own AI models.
Why it matters: Your spoken or typed interactions with AI features can be recorded and used by Duolingo to improve their products and train their AI models, meaning your conversations could contribute to their technology development.
Additionally, Duolingo may generate, record, and store audio recordings or transcripts of the text and audio you submit, and use these recordings or transcripts for product improvement and personalization purposes, including training and running Duolingo’s own artificial intelligence models.
AI Features & Video Call, paragraph 3 · Citation strength: strong
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Personal information may be shared for personalized advertising
Duolingo may process and share your personal information to provide you with personalized advertising, working with various third-party marketing and advertising networks.
Why it matters: Your personal data might be shared with advertising partners to show you targeted ads.
Duolingo may process and share your personal information for the purpose of providing you with personalized advertising. To provide personalized advertising, we may work with a variety of marketing analytics service providers, website analysis firms, and third-party advertising networks, such as Unity, Meta, LiftOff, Pangle, Moloco, and Google.
d. Personalized advertising, paragraph 1 · Citation strength: strong
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IP addresses may be retained longer for payment processing and fraud prevention
If you purchase a Duolingo subscription and submit a payment method, Duolingo may retain your IP address for longer than 30 days solely for payment processing and fraud prevention purposes.
Why it matters: Your IP address might be kept for a longer period if you make a purchase, which is common for financial transaction security but extends data retention.
If you purchase a Duolingo subscription and submit a payment method to Duolingo, Duolingo may retain your IP address for longer solely for purposes of payment processing and fraud prevention.
f. Activity Data & IP Addresses, paragraph 3 · Citation strength: strong
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IP address used for friend recommendations
Duolingo may recommend other users to you, and you to others, based on a shared IP address, such as users on the same WiFi network or device.
Why it matters: Your IP address may be used to suggest connections with other users who share the same network or device, potentially revealing who you live or work with.
We may recommend other Duolingo users for you to follow, and for other users to follow you, based on a shared IP address such as other users on the same WiFi network as you, or if other users share your device.
f. Activity Data & IP Addresses, paragraph 2 · Citation strength: strong
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Cookies include targeting cookies from third parties for personalized advertising
The cookies used by Duolingo include Targeting Cookies from Google, Meta, Amazon, and other companies, which these companies may use to track your activities across multiple websites to deliver personalized advertising.
Why it matters: Third-party cookies are used to track your activities across different websites, enabling companies like Google, Meta, and Amazon to deliver personalized advertisements to you.
Please note that our cookies include Targeting Cookies from Google, Meta, Amazon, and other companies, which these companies may use to track your activities across multiple websites to deliver personalized advertising to you.
h. Cookies, paragraph 2 · Citation strength: strong
Cancellation & Renewal
This section highlights clauses related to how subscriptions or services can be canceled or renewed, and any associated terms that might be disadvantageous. This includes automatic renewals, difficult cancellation processes, or forfeiture of benefits upon cancellation.
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Looking good
No billing surprises spotted
Verbaterm only flags concerns it can cite. No cancellation, auto-renewal, or refund terms needed attention here.
"Gotchas"
This section includes terms that might be unexpected, easily overlooked, or potentially inconvenient for the user, but do not necessarily pose a severe risk. These can include limitations of services, specific user responsibilities, or conditions that might affect user experience.
Not clearly stated: The policy mentions that "Any features discussed in this Privacy Policy may not be available to all users or in all jurisdictions" (clause-0006). This is a general disclaimer that could be relevant to user expectations about features, but it lacks specific detail to be classified as a finding.
Protections
This section provides an overview of privacy-protective clauses and user-benefiting terms. These clauses enhance user control, limit data exploitation, or offer favorable conditions such as strong data security measures, transparent data handling, or clear opt-out options.
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Social login information from providers like Google and Facebook may be received only when registering via social login.
When you register for Duolingo using a social login, Duolingo may receive information about you from your social login provider, including your email address and contacts.
Why it helps: This clarifies that Duolingo only receives information from social login providers if you choose to register through that method, suggesting that direct registration would limit this data sharing.
If you register for Duolingo using a social login, Duolingo may receive information about you from your social login provider, including your email address and contacts.
a. Account Registration, paragraph 2 · Citation strength: strong
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Control over Profile visibility via settings
You can set your Profile to private in your [Settings](https://www.duolingo.com/settings/account).
Why it helps: Users have control over their privacy because they can change their profile visibility from public to private, preventing unwanted collection of their public information by third parties.
However, you can set your Profile to private in your [Settings](https://www.duolingo.com/settings/account).
b. Profile & Public Profile Information, paragraph 3 · Citation strength: strong
Protection95% confidence confidence
AI vendors are restricted from using personal information for their own purposes
Duolingo’s agreements with AI vendors, such as OpenAI and Google, state that they are not permitted to use any personal information for their own purposes when you interact with AI-enabled features.
Why it helps: This commitment helps to protect user privacy by ensuring that third-party AI vendors do not independently use personal data submitted through Duolingo's AI features.
Duolingo’s agreements with these AI vendors mean they are not permitted to use any personal information for their own purposes.
AI Features & Video Call, paragraph 3 · Citation strength: strong
Protection95% confidence confidence
User choice to skip speaking activities and not share audio for product improvement
Users may skip speaking activities and can choose not to share their audio with Duolingo for product improvement purposes within the app Settings.
Why it helps: Users have control over how their voice data is used, allowing them to opt out of sharing audio for product improvements and skip speaking activities if they prefer.
You may skip speaking activities. You may also choose not to share your audio with us for product improvement purposes within the app Settings. We will not use your audio recordings to develop any voice cloning technology.
d. Speaking Activities, paragraph 1 · Citation strength: strong
Protection95% confidence confidence
Contact Sync uses hashed phone numbers to protect contacts' privacy
If you use the Contact Sync feature, Duolingo will not store your contacts’ phone numbers, but only an encrypted “hash” of them, which cannot be used to identify real phone numbers or contact your contacts.
Why it helps: This protection means that your contacts' actual phone numbers are not stored by Duolingo, safeguarding their privacy by preventing direct access or use of their numbers.
If you use the Contact Sync feature, Duolingo will not store your contacts’ phone numbers, but only an encrypted “hash” of them. This hash is an alternative code to the actual phone number and can be used only to match the hash of other users’ numbers. The hashing process securely strips away the real phone number, so Duolingo cannot use the hashes to identify your contacts’ real phone numbers, contact your contacts, or share their information with anyone else.
e. Contact Sync Feature, paragraph 2 · Citation strength: strong
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Users can disable Contact Sync and automatically delete previously shared contact information
You can disable the Contact Sync feature and your sharing of contacts with Duolingo by accessing the Social Accounts section of the app Settings, which will also instruct Duolingo to automatically delete any previously shared information about your contacts.
Why it helps: Users have full control to stop sharing their contacts and ensure that any previously shared contact information is automatically deleted, enhancing their privacy and data management.
You can disable the Contact Sync feature and your sharing of contacts with Duolingo by accessing the Social Accounts section of the app Settings. This will also instruct Duolingo to automatically delete any previously shared information about your contacts.
e. Contact Sync Feature, paragraph 4 · Citation strength: strong
Protection90% confidence confidence
Comprehensive data subject rights and control mechanisms are available
Users have several data subject rights, including the ability to know what personal information has been collected and shared, opt out of sharing with third parties, object to processing, request deletion or correction of data, and export personal information.
Why it helps: Users are given extensive control over their personal data, including the right to access, correct, delete, and control its sharing, empowering them to manage their privacy effectively.
* Access a copy of the personal information that we hold about you. * Know what personal information about you we have shared with third parties. * Opt out of the sharing of your personal information with third parties. * Object to our processing of your personal information. * Request that we limit our use of your sensitive personal information to what is necessary to perform the services you requested. * Not be discriminated against for exercising your data subject rights. * Request that we delete any personal information we have collected from you. * Request that we correct any inaccurate personal information about you.
### Your Data Subject Rights, paragraph 2 · Citation strength: strong
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