Risk Score
0 = very fair · 100 = very risky
Summary
This analysis covers Duolingo's Terms of Service and Privacy Policy, governing use of the language-learning app and website. Duolingo collects substantial personal and behavioral data to support advertising, analytics, and product improvement. Users retain ownership of their content but grant Duolingo broad licensing rights. The terms include mandatory arbitration and class action waivers, unilateral modification rights, and the ability to terminate accounts at will. Overall, the terms are broadly typical for a free consumer app but contain several clauses that meaningfully limit user rights and enable aggressive data practices.
Flagged Clauses
Duolingo shares information about how you use the app — including behavioral and device data — with outside advertising and analytics companies. These third parties may use it to build profiles and target you with ads across other platforms.
“Duolingo shares personal data with third-party advertising partners, analytics providers, and service providers. Data shared includes usage behavior, device identifiers, and inferred user attributes for targeted advertising purposes.”
If Duolingo is sold or goes through a major corporate transaction, your personal data could be transferred to the new owner without your separate consent.
“Duolingo states it may share or transfer personal data in connection with a merger, acquisition, bankruptcy, or sale of all or a portion of its assets.”
Third-party code built into the Duolingo app can collect data directly from your device. Those companies operate under their own privacy rules, which Duolingo does not fully control.
“Duolingo uses third-party analytics and advertising SDKs (e.g., Google, Facebook/Meta, AppsFlyer) embedded in the app that may independently collect data under their own privacy policies.”
If you have a legal dispute with Duolingo, you cannot sue them in court or join a class action lawsuit with other users. You must go through private arbitration individually, which is generally more expensive and favorable to companies.
“Duolingo requires users to resolve disputes through binding individual arbitration and explicitly waives the right to participate in class action lawsuits or class-wide arbitration.”
New users have approximately 30 days after first agreeing to opt out of the arbitration clause, but must do so proactively in writing. Missing this window means arbitration is mandatory.
“The arbitration clause includes a 30-day opt-out window for new users, typically requiring written notice to a specific address.”
Duolingo can change the rules at any time. Simply continuing to use the app after changes are posted — even if you didn't read them — counts as your agreement to the new terms.
“Duolingo reserves the right to modify the Terms of Service at any time. Notice may be provided by posting updated terms on the website or app, and continued use constitutes acceptance.”
Duolingo can close your account at any time, for almost any reason, without necessarily warning you first. This includes any paid subscriptions you may have active.
“Duolingo may suspend or terminate accounts at its sole discretion, with or without notice, for any violation of the Terms or for any other reason it deems appropriate.”
Your paid subscription automatically renews and charges your payment method. Cancellations must happen before the renewal date, and refunds are largely handled by Apple or Google rather than Duolingo directly.
“Duolingo Super (paid subscription) auto-renews unless cancelled before the renewal date. Refund eligibility for recent charges may be limited and is handled through the relevant app store (Apple App Store / Google Play).”
If you cancel mid-subscription period, you typically won't get a refund for the unused time. You keep access until the end of the paid period, but no money comes back.
“Subscription fees are non-refundable except where required by law. Partial-period refunds are generally not provided upon cancellation.”
You technically still own what you post, but Duolingo can use it however they want, forever, for free, and can pass that right on to others — without needing to ask you again.
“Users retain ownership of content they submit (e.g., forum posts, user-generated contributions) but grant Duolingo a perpetual, worldwide, royalty-free, sublicensable, and transferable license to use, reproduce, modify, distribute, and display that content.”
You are licensing the right to use Duolingo's content — you don't own the courses or lessons. Access can be removed if Duolingo terminates your account or discontinues the service.
“Access to Duolingo courses, content, and features is provided as a service license, not a permanent purchase. Free and paid tiers both constitute licensed access that can be revoked.”
If something goes wrong — including data loss or service outages — Duolingo's financial responsibility is capped at $100 or what you paid in the last year, whichever is more. Their practical liability is very limited.
“Duolingo disclaims all warranties to the maximum extent permitted by law and limits its liability to the greater of $100 or the amount paid by the user in the past 12 months.”
If someone sues Duolingo because of something you did on the platform, you may be responsible for covering Duolingo's legal costs and damages.
“Users agree to indemnify and hold harmless Duolingo and its affiliates from any claims, damages, or costs arising from user's use of the service or violation of the Terms.”
Duolingo can access your microphone and camera during exercises, and collects detailed data on everything you do in the app. This data feeds into advertising and product systems beyond just teaching you a language.
“Duolingo collects learning activity data, microphone input (for speaking exercises), camera input (in applicable features), and device/location metadata. This data is used for product improvement, personalization, and potentially advertising.”
Duolingo infers where you are from your IP address and may access more precise location data through your phone depending on your app permissions.
“Duolingo may collect approximate location data derived from IP address and, on mobile, more precise location if permitted by device settings.”
Missing Protections
- No clear data deletion timeline — the policy does not specify how long data is retained after account deletion
- No explicit prohibition on selling personal data (data sharing with ad partners is described but 'selling' is not clearly addressed in non-CCPA contexts)
- No guaranteed service uptime or SLA for paid subscribers
- No explicit user notification requirement before material changes to paid subscription pricing
- No independent audit or certification of data security practices mentioned
- No explicit process for data portability — users cannot easily export their learning history or account data
- Arbitration opt-out process is mentioned but the exact notification address/method may not be clearly highlighted at signup
Fair Terms
- Users retain ownership of content they submit — Duolingo does not claim to own user-generated content outright
- A 30-day arbitration opt-out window exists for new users, which is better than no opt-out at all
- CCPA rights are acknowledged for California residents, including the right to know, delete, and opt out of data sale
- GDPR rights are acknowledged for EU/EEA users, including access, correction, deletion, and data portability requests
- Children under 13 (or under 16 in the EU) are subject to additional protections including parental consent mechanisms and reduced data collection
- Duolingo states it does not serve behavioral advertising to children in the children's app (Duolingo ABC)
- The core language learning service remains free, meaning users are not locked into a mandatory paid subscription
Document information only — not legal advice.