Overview
Duolingo ABC - Learn to Read is a popular new app for children to learn to read and help kids have fun while they practice reading and writing. Duolingo's terms say for Duolingo ABC, there is no social sharing function. Duolingo's terms also say instead of collecting any personally identifiable information about a child, Duolingo will only store the e-mail address of their parent or guardian. In addition, the terms say Duolingo has implemented administrative and technical safeguards it believes are sufficient to protect the confidentiality, integrity, and availability of a child's data. Duolingo's terms say Duolingo ABC is separate from the traditional Duolingo learning app and does not share any account information between the two. The Duolingo ABC app is designed to be set up by parents and the terms say a parent or guardian needs to provide their child’s age before use. The terms say Duolingo ABC does not share a user's personal data with any third parties, and Duolingo ABC does not display advertising of any kind. Lastly, children can not enter profile information such as a profile picture or a bio.
Duolingo ABC - Learn to Read can be accessed through its website, and is available for download at the iOS App Store. The Privacy Policy and Terms of Use accessed for this evaluation can be found on Duolingo’s website. 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 all user interactions by removing some content such as alcohol references. The terms note that in this version, children can not enter profile information such as a profile picture or a bio. The terms also say Duolingo ABC does not contain user generated content or social features of any kind.
Privacy
The terms say when using the app for the first time, a user can provide a nickname or first name for the learner, an approximate age, and optionally an email address. Duolingo's terms say personal information is not needed for any kind of account creation, nor does it need to be accurate. For example, a user can provide any text for the learner's nickname, and the app will use that text when teaching how to write their name.
Duolingo's terms also say they do not share a user's personal information with third-parties, unless it is necessary to offer the service, or required by law. However, Duolingo's general privacy 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 say Duolingo does not share a user's personal data with any third parties, and Duolingo ABC does not display advertising of any kind.
Security
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 test results. In addition, Duolingo ABC's terms say personal information is transmitted securely and encrypted. However, there is no indication as to whether users will be notified in the event of a data breach.
Compliance
Duolingo ABC says that it is intended for children to learn to read and help kids have fun while they practice reading and writing. 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 that they use parental consent before collecting personal information from children, both in the United States, the European Union, and other countries. The terms say a parent or guardian can control app settings for their child and also delete app data from a special settings screen meant to be accessible only by adults. Duolingo states that it uses parental email addresses to contact parents and obtain consent for their children's account. Lastly, educators should be aware that Duolingo A's terms say the app is primarily designed to be used by individuals, rather than schools or teachers and no education records are collected.
Overall Score
Every privacy rating includes an overall score. A higher score (up to 100%) means the product provides more transparent privacy policies with better practices to protect user data. The score is best used is as an indicator of how much additional work a person will need to do to make an informed decision about a product.
| Basic Score | Full Score | |
|---|---|---|
| Comprehensive Assessment | 85 | 65 |
Concerns
The privacy evaluation process summarizes the policies of an application or service into concern categories based on a subset of evaluation questions that can be used to quickly identify particular practices of a vendor’s policies. These concerns are composed of evaluation questions that can be used to calculate scores relative to that concern.
| Concern | Basic Score | Full Score |
|---|---|---|
| Data Collection: Protecting personal information | 100 | 70 |
| Data Sharing: Protecting data from third parties | 100 | 95 |
| Data Security: Protecting against unauthorized access | 67 | 50 |
| Data Rights: Controlling data use | 100 | 100 |
| Data Sold: Preventing sale of data | 75 | 50 |
| Data Safety: Promoting responsible use | 88 | 60 |
| Ads & Tracking: Prohibiting the exploitation of users' decision making process | 100 | 95 |
| Parental Consent: Protecting children’s personal information | 100 | 70 |
| School Purpose: Following student data privacy laws | 0 | 30 |
Statutes
Each statute or regulation is associated with one or more evaluation questions. As such, we can calculate scores for each statute or regulation using only those questions associated with the statute or regulation. Each specific statute or regulation's score serves as an indirect proxy indicating the likelihood of the application or service satisfying all of its compliance obligations.
| Statute | Basic Score | Full Score |
|---|---|---|
| California Online Privacy Protection Act (CalOPPA) | 100 | 88 |
| Children's Online Privacy Protection Act (COPPA) | 96 | 75 |
| Family Educational Rights and Privacy Act (FERPA) | 89 | 67 |
| Student Online Personal Information Protection Act (SOPIPA) | 81 | 79 |
| General Data Protection Regulation (GDPR) | 86 | 69 |
Privacy Policy Details
1: Transparency
1.1: Policy Version
- Privacy policies do indicate a version or effective date.
- Privacy policies do not indicate a changelog or past policy version is available.
1.2: Policy Notice
- Users are notified if there are any material changes to the policies.
- Privacy policies indicate the method used to notify a user when policies are updated.
1.3: Policy Changes
- Users are notified prior to any material changes to the policies.
- Changes to the policies are effective immediately and continued use of the product indicates consent.
1.4: Policy Coverage
- Privacy policies indicate the products that are covered by the policies.
1.5: Policy Contact
- Users cannot contact the vendor about any privacy policy questions, complaints, or material changes to the policies.
1.6: Policy Principles
- Privacy policies do not indicate any privacy principles, layered notices, or a table of contents.
1.7: Policy Language
- Privacy policies are available in multiple languages.
1.8: Intended Use
- Intended for children under 13.
- Unclear whether intended for teens.
- Unclear whether intended for adults over 18.
- Intended for parents or guardians.
- Unclear whether intended for students.
- Not intended for teachers.
2: Focused Collection
2.1: Data Collection
- Personally identifiable information (PII) is not collected.
- The categories of collected personally identifiable information are indicated.
- Geolocation data are not collected.
- Biometric or health data are not collected.
- Behavioral data are collected.
- Sensitive data are collected.
- Non-personally identifiable information is collected.
- Unclear whether free or reduced lunch status is collected.
2.2: Data Source
- Personal information or education records are not collected from preK-12 students.
- Personal information from children under 13 years of age is collected online.
2.3: Data Exclusion
- Specific types of personal information are not collected.
- Unclear whether specific types of collected information are excluded from the privacy policy.
2.4: Data Limitation
- Collection or use of data is limited to product requirements.
3: Data Sharing
3.1: Data Shared With Third Parties
- Collected information is shared with third parties.
- The categories of information shared with third parties are indicated.
3.2: Data Use by Third Parties
- The purpose for sharing a user's personal information with third parties is indicated.
- Data are not shared for analytics.
- Data are shared for research and/or product improvement.
- Data are not shared for third-party advertising and/or marketing.
3.3: Data Not Shared With Third Parties
- Specific categories of information are not shared with third parties.
3.4: Data Sold to Third Parties
- Data are not sold or rented to third parties.
3.5: Third-Party Data Acquisition
- Personal information from users is not acquired from third parties.
3.6: Third-Party Links
- Links to third-party external websites are not age-appropriate.
3.7: Third-Party Data Access
- Third parties are not authorized to access a user's information.
3.8: Third-Party Data Collection
- Personal information of users is collected by a third party.
3.9: Third-Party Data Misuse
- Unclear whether personal information can be deleted from a third party if found to be misused.
3.10: Third-Party Service Providers
- Data are shared with third-party service providers.
- The roles of third-party service providers are indicated.
3.11: Third-Party Affiliates
- The categories of third parties that receive personal information are indicated.
3.12: Third-Party Policies
- Links to privacy policies of third-party companies are not available.
3.13: Third-Party Data Combination
- Data cannot be combined with data from third-party sources.
- Unclear whether data shared with third parties can be combined by third parties for their own purposes.
3.14: Third-Party Authentication
- Social or federated login is not supported.
- Personal information from social or federated login providers is not collected.
- Personal Information is not shared with social or federated login providers.
3.15: De-identified or Anonymized Data
- User information is not shared in an anonymous or deidentified format.
- Unclear whether the vendor describes their deidentification process of user information.
3.16: Third-Party Contractual Obligations
- Contractual limits are placed on third-party data use.
- Unclear whether contractual limits prohibit third parties from reidentifying deidentified information.
4: Respect for Context
4.1: Data Use
- Use of information is limited to the purpose for which it was collected.
- The purpose for which data atr collected is indicated.
4.2: Data Combination
- Unclear whether this product treats combined information as personally identifiable information (PII).
4.3: Data Notice
- Unclear whether notice is provided if the context in which data are collected changes.
4.4: Data Changes
- Unclear whether consent is obtained if the practices in which data are collected change.
4.5: Policy Enforcement
- Accounts may be terminated if users engage in any prohibited activities.
5: Individual Control
5.1: User Content
- Users cannot create or upload content.
5.2: User Consent
- Opt-in consent is requested from users at the time personal information is collected.
5.3: Remedy Process
- A grievance or remedy mechanism is available for users to file a complaint.
5.4: Data Settings
- Users can control their information through privacy settings.
5.5: Data Disclosure
- Users can opt out from the disclosure or sale of their data to a third party.
- Users can request to know what personal information has been shared with third parties for commercial purposes.
- Unclear whether notice is provided in the event the vendor receives a government or legal request for a user’s information.
5.6: Intellectual Property
- Users retain ownership of their data.
- A copyright license is claimed to data or content collected from a user.
- Unclear whether any copyright license to a user's data is limited in scope or duration.
- Unclear whether notice is provided to users when their content is removed or disabled because of an alleged copyright violation.
6: Access and Accuracy
6.1: Data Access
- Processes to access and review user data are available.
- Permissions, roles, or access controls are available to restrict who has access to data.
- Processes to review data are available for the school, parents, or students.
6.2: Data Integrity
- Unclear whether the vendor maintains the accuracy of data they collect.
6.3: Data Correction
- Processes to modify inaccurate data are available.
- Processes for the school, parents, or students to modify data are available.
- Unclear whether the time period for the vendor to modify inaccurate data is indicated.
6.4: Data Retention
- A data-retention policy is available.
- Unclear whether the retention time period of a user's data can be changed upon a valid inspection request.
6.5: Data Deletion
- Data are not deleted when no longer necessary.
- A user's data are deleted upon account cancellation or termination.
- Processes to delete user data are available.
- Processes for the school, parents, or students to delete data are available.
- The time period for the vendor to delete data is indicated.
6.6: Data Portability
- Processes to download user data are available.
- Unclear whether a user can assign an authorized account manager or legacy contact.
7: Data Transfer
7.1: Data Handling
- User information can be transferred to a third party.
- Unclear whether notice is provided to users if the vendor assigns its rights or delegates its duties to another company.
- Unclear whether users are notified if their information is transferred to a third party.
7.2: Transfer Request
- Unclear whether user information can be deleted prior to its transfer to a third party.
7.3: Onward Contractual Obligations
- Third-party transfer is contractually required to use the same privacy practices.
8: Security
8.1: User Identity
- A user's identity is not verified with additional personal information.
8.2: User Account
- Account creation is not required.
- Parental controls or managed accounts are available.
- Unclear whether two-factor account protection is available.
8.3: Third-Party Security
- Unclear whether third-party contractual security protections are required.
8.4: Data Confidentiality
- Industry best practices are used to protect data.
- Unclear whether this product limits employee or physical access to user information.
8.5: Data Transmission
- All data in transit are encrypted.
8.6: Data Storage
- Unclear whether this product encrypts all data at rest.
- Personal information of users is not stored with a third party.
8.7: Data Breach
- Unclear whether this product provides notice in the event of a data breach.
8.8: Data Oversight
- Unclear whether this product performs data-privacy and security-compliance audits.
9: Responsible Use
9.1: Social Interactions
- Users cannot interact with trusted users and/or students.
- Users cannot interact with untrusted users, including strangers and/or adults.
- Profile information is not shared for social interactions.
9.2: Data Visibility
- Personal information is not displayed publicly.
- Unclear whether this product allows users to control how their data are displayed.
9.3: Monitor and Review
- User-created content is not reviewed, screened, or monitored by the vendor.
- User-created content is filtered for personal information before being made publicly visible.
- Social interactions between users are not moderated.
- Unclear whether social interactions of users are logged.
9.4: Report Content
- Unclear whether users can filter or block inappropriate content.
- Unclear whether users can report abuse or cyberbullying.
9.5: Internet Safety
- Unclear whether the vendor provides links to tools or processes that support safe and appropriate social interactions.
10: Advertising
10.1: Vendor Communications
- A user can receive service- or administrative-related communications from the vendor.
10.2: Traditional Advertising
- Traditional or contextual advertisements are not displayed.
10.3: Behavioral Advertising
- Behavioral or targeted advertising is not displayed.
10.4: Ad Tracking
- Data are not collected by third-party advertising or tracking services.
- Data are not used to track and target advertisements on other third-party websites or services.
- Data profiles are not created and used for data enhancement, and/or targeted advertisements.
10.5: Filtered Advertising
- Children do not receive any inappropriate advertisements.
10.6: Marketing Communications
- The vendor cannot send marketing messages.
- The vendor does provide promotional sweepstakes, contests, or surveys.
10.7: Unsubscribe
- Users can opt out of traditional, contextual, or behavioral advertising.
- Users can opt out or unsubscribe from marketing communications.
10.8: Do Not Track
- Vendor does not respond to Do Not Track or other opt-out mechanisms.
- Unclear whether the vendor provides a method for users to opt-out from third-party tracking.
11: Compliance
11.1: Children Under 13
- Vendor does have actual knowledge that personal information from users under 13 years of age is collected.
- Children's privacy is applicable.
- Account creation is not restricted for users under 13 years of age.
- Unclear whether this product restricts in-app purchases for users under 13 years of age.
- Unclear whether the vendor participates in an FTC-approved COPPA safe harbor program.
11.2: Students in K–12
- 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.
11.3: Parental Consent
- 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.
- Unclear whether the vendor can use collected information to support the “internal operations” of the product.
- Unclear whether this product indicates COPPA parental consent exceptions.
- Unclear whether the vendor indicates FERPA parental consent exceptions.
- Unclear whether this product discloses directory information.
- Unclear whether this product transfers parental consent obligations to the school or district.
11.4: Legal Requirements
- The legal jurisdiction that applies to the laws governing any dispute is indicated.
- A user is not required to waive the right to a jury trial, or settle any disputes by arbitration.
- A user is required to waive the right to join a class action lawsuit.
- A vendor will disclose personal information to law enforcement.
11.5: Certification
- Unclear whether the vendor has signed a privacy pledge or received a privacy certification.
11.6: International Laws
- A user's data are subject to International data transfer or jurisdiction laws, such as the GDPR.
- The vendor has indicated it is a Data Controller or Data Processor.