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Privacy Evaluation for Duolingo ABC - Learn to Read

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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.

Rating

This product received a Pass rating based on the following details:
  • Personal information is not sold or rented to third parties.
  • Personal information is not shared for third-party marketing.
  • Personalised advertising is not displayed.
  • Data are not collected by third-parties for their own purposes.
  • User's information is not used to track and target advertisements on other third-party websites or services.
  • Data profiles are not created and used for personalised advertisements.
Data Collection
SCORE: 80%

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.
  • Geolocation data are not collected.
  • Biometric or health data are not collected.
  • Interactions, behaviors, or usage analytics data are collected.
  • Sensitive data are collected.
  • Data is automatically collected.
  • Opt-in consent is requested from users at the time personal information is collected.
  • Personal information of users is collected by a third party.
Data Sharing
SCORE: 95%

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 data are indicated.
  • Data are not shared for analytics.
  • Data are shared for research and/or product improvement.
  • Third-party services are used to support the product.
  • The roles of third-party service providers are indicated.
  • Third-party login is not supported.
  • Contractual limits are placed on third-party data use.
Data Security
SCORE: 50%

How does it secure data?

  • A user's identity is not verified with additional personal information.
  • Account creation is not required.
  • Managed accounts are available.
  • Unclear whether multi-factor account protection is available.
  • Unclear whether third-parties with access to information are required to provide the same security protections as the company.
  • Reasonable security practices are used to protect data.
  • Unclear whether this product limits employee or physical access to user information.
  • All data in transit are encrypted.
  • Unclear whether all data are stored in an encrypted format.
  • Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 95%

What rights do I have to the data?

  • Users cannot create or upload content.
  • Users retain ownership of their data.
  • Processes to access or review user data are available.
  • Processes to modify data are available for authorized users.
  • A data-retention policy is available.
  • Processes for authorized users to delete data are available.
  • A user's data are deleted upon account cancellation or termination.
  • Data are not deleted when no longer necessary.
  • Methods are available to restrict who has access to data.
  • Processes to download user data are available.
Data Sold
SCORE: 50%

Is the data sold?

  • Personal information is not 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 in the event of a merge, acquisition, or bankruptcy.
  • 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 that is shared is not shared in an anonymous or de-identified format.
  • Unclear whether the company describes their de-identification process of user information.
  • Data are shared for research and/or product improvement.
  • Unclear whether contractual limits prohibit third parties from reidentifying or de-identified information.
Data Safety
SCORE: 60%

How safe is this product?

  • Users cannot interact with trusted users.
  • Users cannot interact with untrusted users, including strangers and/or adults.
  • Profile information must be not shared for social interactions.
  • Personal information can be not displayed publicly.
  • Unclear whether this product allows users to control how their data are displayed to others.
  • User-created content is not reviewed, screened, or monitored by the company.
  • 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.
  • Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 95%

Are there advertisements or tracking?

  • Personal information is not shared for third-party marketing.
  • Traditional or contextual advertisements are not displayed.
  • Personalised advertising is not displayed.
  • Data are not collected by third-parties for their own purposes.
  • User's information is not used to track and target advertisements on other third-party websites or services.
  • Data profiles are not created and used for personalised advertisements.
  • The company cannot send marketing messages.
  • The company does provide promotional sweepstakes, contests, or surveys.
  • Users can opt out of contextual, or personalised advertising.
  • Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 75%

Can I provide parental consent?

  • Intended for children under 13.
  • Personal information from children under 13 years of age is collected.
  • Intended for parents or guardians.
  • Company does have actual knowledge that personal information from users under 13 years of age is collected.
  • The company does provide a section, heading, or separate policy for children in their policies.
  • Parental consent is required before personal information is collected or disclosed.
  • 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: 38%

Is the product intended for school?

  • Unclear whether intended for students.
  • Personal information or education records are not collected from preK-12 students.
  • Not intended for teachers.
  • Unclear whether this product is primarily used by, designed for, and marketed toward students in grades preK–12.
  • Processes to enter education records into the product are described.
  • Unclear whether additional rights or protections may be provided with an additional school contract.
  • Unclear whether the company is designated as a school official.
  • Unclear whether this product transfers parental consent obligations to the school or district.
Individual Control
SCORE: 60%

Can I control the use of my data?

  • Users can control the use of their information through privacy settings.
  • Use of information is limited to the purpose for which it was collected.
  • The context or purpose for which data are collected is indicated.
  • Company will not combine data with additional data from third-party sources.
  • Unclear whether this product treats combined information as personally identifiable information (PII).
  • Unclear whether notice is provided if the context in which data are collected changes.
  • Unclear whether consent is obtained if the practices in which data are collected change.
  • A grievance or remedy mechanism is available for users to file a complaint.
  • Users can request to know what personal information has been shared with third parties.
  • Unclear whether notice is provided in the event the company receives a government or legal request for a user's 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.