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Privacy Evaluation for Duolingo

Last updated May 11, 2020

Overview

Duolingo is a language learning application that users can access without paying subscription fees. Duolingo offers a consumer and a "for schools" version, and both applications are governed by the same privacy policy. Duolingo's terms state they allow users to engage in social interactions through discussions with other individuals where they can send messages. Duolingo's terms state they collect personally identifiable information and automatically collected usage information from users when they register an account. Duolingo's terms specify 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. Duolingo's terms state that they allow some of the application to be used by children under the age of 13.

Duolingo can be accessed through its website, and is available for download at the iOS App Store, and the Google Play Store. The Privacy Policy and Terms of Use accessed for this evaluation can be found on Duolingo’s website, iOS App Store, and the Google Play Store. Additionally, other policies used for this evaluation include: Community Guidelines. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

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, however, are unclear as to whether Duolingo moderates content and interactions between users.

Privacy

The terms of Duolingo state 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 state 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 state they allow third parties to collect personal information. Duolingo's terms state they may use or share aggregate or anonymous data collected through the service, including Activity Data, for purposes such as understanding or improving the service and may provide personally-identifiable information to service providers who help provide the service, such as hosting the service at a co-location facility or sending email updates.

Lastly, the terms state 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.

Security

Duolingo's terms state 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.

Compliance

Duolingo is a service meant for all ages, and the vendor is clear that it does design some features specifically for children. However, the service would likely appeal to children under 13 years of age, which take into account several factors that include the educational related subject matter, visual content, the game-based features of the application, age of models or cartoons, and activities provided. The privacy policy indicates that users can access, delete, or modify their data by visiting their account settings or notifying Duolingo through email. Duolingo's terms state they make a good faith effort to obtain parental consent before collecting personal information from children, both in the United States, the European Union, and other countries. Although the method of providing consent is unclear, Duolingo states that it uses parental email addresses to contact parents and obtain consent for their children's account.

Data Collection
SCORE: 55%

What data does it collect?

  • Personally identifiable information (PII) is not collected.
  • The categories of collected personally identifiable information are indicated.
  • Collection or use of data is limited to product requirements.
  • Unclear whether this product collects geolocation data.
  • Biometric or health data are not collected.
  • Unclear whether this product collects behavioral data.
  • Unclear whether this product collects sensitive data.
  • Non-personally identifiable information is not collected.
  • Unclear whether this product treats combined information as personally identifiable information (PII).
  • Personal information from children under 13 years of age is collected online.
Data Sharing
SCORE: 85%

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.
  • Use of information is limited to the purpose for which it was collected.
  • 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.
Data Security
SCORE: 15%

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.
Data Rights
SCORE: 65%

What rights do I have to the data?

  • Unclear whether opt-in consent is requested from users at the time personal information is collected.
  • Unclear whether users can control their information through privacy settings.
  • 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.
  • Processes to delete user data are not available.
  • Processes to download user data are not available.
Data Sold
SCORE: 40%

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.
Data Safety
SCORE: 50%

How safe is this product?

  • Users can interact with trusted users and/or students.
  • Unclear whether users can 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.
  • Unclear whether social interactions between users are moderated.
  • Unclear whether social interactions of users are logged.
  • Users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 55%

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.
Parental Consent
SCORE: 50%

Can I provide parental consent?

  • Intended for children under 13.
  • Unclear whether intended for parents or guardians.
  • Vendor does have actual knowledge that personal information from users under 13 years of age is collected.
  • Unclear whether children's privacy is applicable.
  • Unclear whether this product indicates COPPA parental consent exceptions.
  • 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.
School Purpose
SCORE: 10%

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.

Common Sense Standard Privacy Report (SPR)

The standard privacy report (SPR) displays all the privacy practices from a product's policies in a single, easy-to-read outline. The report shows a green check mark for better privacy practices and an orange alert for risky or unclear practices. This alert indicates that more time should be focused on these particular details prior to use.

About Privacy Evaluations

The privacy evaluations have been designed with the help and support of a consortium of schools and districts across the United States. These evaluations are designed to help educators make informed decisions about the potential privacy implications of educational technology used to support teaching and learning.

Our core evaluation criteria will always be freely available. People are encouraged to read the questions we use and our information security primer. Vendors are encouraged to use our questions and the information security primer to self-evaluate. You can also learn more about our evaluation process. Please be in touch with any questions or feedback.