Privacy Evaluation for Duolingo
Duolingo's terms do not say whether they sell user's data to third parties. However, Duolingo's terms do say they share users' data with third party advertising networks, marketing analytics service providers and website analysis firms, such as Google, Facebook, Oath, and Unity. These third-party advertising services collect may use personal data to track users and display targeted advertisements on other apps and services across the internet. Duolingo's terms also say they have implemented administrative and technical safeguards it believes are sufficient to protect the confidentiality, integrity and availability of a user's Testing ID, Photo, access credentials, and Duolingo language test results. Lastly, Duolingo's terms say that they allow some features of the application to be used by children under the age of 13.
Duolingo's community guidelines indicate that Duolingo ensures a safe environment for user interaction by removing inappropriate and offensive content, but some personal information may be publicly visible. However, Duolingo warns users not to overshare personal information when interacting with other users. The terms say Duolingo puts in place safety protections for children such as: a child’s profile is made private and hidden from other users’ searches and other users are unable to follow a child. In addition, the ability to follow other users or search for other users is disabled for children and the ability to send an invitation email is disabled and social logins with Facebook, Google or Apple are disabled.
The terms of Duolingo say they collect personally identifiable information and automatically collected usage information from users when they register an account. If a user registers for a Duolingo language test, each time they take a test they must also provide a picture or scan of a current, valid driver’s license, passport or other government issued ID and a picture of their face. When a user takes an examination of a Duolingo language test they must provide access to their computer’s webcam and microphone. Duolingo's terms say they will use them to record a user during the entire examination period and will store the recording to validate that a user took the examination without improper assistance.
Duolingo's terms do not say whether they sell user's data to third parties. However, Duolingo's terms do say they share users' data with third party advertising networks, marketing analytics service providers and website analysis firms, such as Google, Facebook, Oath, and Unity. These third-party advertising services may collect and use personal data to track users and display targeted advertisements on other apps and services across the internet. Lastly, the terms say information associated with a Duolingo language test, including examination results and a user's Testing Video, may be collectively deleted from a user's Duolingo account, but anonymized examination data, including a user's examination results and Testing Video, may be kept indefinitely by Duolingo to improve the examination and for research and analysis.
Duolingo's terms say they have implemented administrative and technical safeguards it believes are sufficient to protect the confidentiality, integrity and availability of a user's Testing ID, Photo, access credentials, and Duolingo language test results. However, Duolingo's terms do not provide any information about whether personal information is encrypted while in transit or at rest. Furthermore, there is no indication as to whether users will be notified in the event of a data breach.
What data does it collect?
- Personally identifiable information (PII) is not collected.
- The categories of collected personally identifiable information are indicated.
- Unclear whether the collection or use of data is limited to product requirements.
- Unclear whether this product collects geolocation data.
- Biometric or health data are collected.
- Behavioral data are collected.
- Sensitive data are collected.
- Non-personally identifiable information is not collected.
- Unclear whether opt-in consent is requested from users at the time personal information is collected.
- Personal information of users is collected by a third party.
What data does it share?
- Collected information is shared with third parties.
- The categories of information shared with third parties are indicated.
- The purpose for sharing a user's personal information with third parties is indicated.
- The categories of third parties that receive personal information are indicated.
- Data are not shared for analytics.
- Data are shared for research and/or product improvement.
- Data are not shared with third-party service providers.
- The roles of third-party service providers are indicated.
- Unclear whether this product supports social or federated login.
- Contractual limits are placed on third-party data use.
How does it secure data?
- A user's identity is verified with additional personal information.
- Unclear whether this product requires account creation.
- Unclear whether parental controls or managed accounts are available.
- Unclear whether two-factor account protection is available.
- Unclear whether third-party contractual security protections are required.
- Industry best practices are used to protect data.
- Unclear whether this product limits employee or physical access to user information.
- Unclear whether this product encrypts all data in transit.
- Unclear whether this product encrypts all data at rest.
- Unclear whether this product provides notice in the event of a data breach.
What rights do I have to the data?
- Users can create or upload content.
- Users retain ownership of their data.
- Processes to access and review user data are available.
- Processes to modify inaccurate data are available.
- A data-retention policy is available.
- Processes for the school, parents, or students to delete data are available.
- A user's data are not deleted upon account cancellation or termination.
- Data are not deleted when no longer necessary.
- Unclear whether permissions, roles, or access controls are available to restrict who has access to data.
- Processes to download user data are not available.
Is the data sold?
- Unclear whether data are sold or rented to third parties.
- Users can opt out from the disclosure or sale of their data to a third party.
- User information can be transferred to a third party.
- Unclear whether users are notified if their information is transferred to a third party.
- Unclear whether user information can be deleted prior to its transfer to a third party.
- Third-party transfer is contractually required to use the same privacy practices.
- User information is not shared in an anonymous or deidentified format.
- Unclear whether the vendor describes their deidentification process of user information.
- Data are shared for research and/or product improvement.
- Unclear whether contractual limits prohibit third parties from reidentifying deidentified information.
How safe is this product?
- Users can interact with trusted users and/or students.
- Users cannot interact with untrusted users, including strangers and/or adults.
- Profile information is shared for social interactions.
- Personal information is not displayed publicly.
- Unclear whether this product allows users to control how their data are displayed.
- User-created content is reviewed, screened, or monitored by the vendor.
- User-created content is not filtered for personal information before being made publicly visible.
- Social interactions between users are moderated.
- Unclear whether social interactions of users are logged.
- Users can report abuse or cyberbullying.
Ads & Tracking
Are there advertisements or tracking?
- Data are shared for third-party advertising and/or marketing.
- Traditional or contextual advertisements are displayed.
- Behavioral or targeted advertising is displayed.
- Data are collected by third-party advertising or tracking services.
- Data are used to track and target advertisements on other third-party websites or services.
- Data profiles are created and used for data enhancement, and/or targeted advertisements.
- The vendor cannot send marketing messages.
- The vendor does provide promotional sweepstakes, contests, or surveys.
- Users can opt out of traditional, contextual, or behavioral advertising.
- Unclear whether this product provides users the ability to opt out or unsubscribe from marketing communications.
Can I provide parental consent?
- Intended for children under 13.
- Personal information from children under 13 years of age is collected online.
- Unclear whether intended for parents or guardians.
- Vendor does have actual knowledge that personal information from users under 13 years of age is collected.
- Children's privacy is applicable.
- Parental consent is required.
- Unclear whether this product limits parental consent with respect to third parties.
- Unclear whether this product allows parents to withdraw consent for the further collection of their child's information.
- Children's personal information is deleted if collected without parental consent.
- Parental consent notice and method for submission are provided.
Is the product intended for school?
- Unclear whether intended for students.
- Unclear whether personal information or education records are collected from preK-12 students.
- Unclear whether intended for teachers.
- Unclear whether this product is primarily used by, designed for, and marketed toward students in grades preK–12.
- Product does create education records.
- Unclear whether this product provides notification of a contract or additional rights.
- Unclear whether this product designates the vendor as a school official.
- Unclear whether this product transfers parental consent obligations to the school or district.
- Unclear whether the vendor indicates FERPA parental consent exceptions.
- Unclear whether this product discloses directory information.