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Privacy Evaluation for Duolingo

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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 say they allow users to engage in social interactions through discussions with other individuals where they can send messages, but not for children under the age of 13. Duolingo's terms say they collect personally identifiable information and automatically collected usage information from users when they register an account.

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 companies. 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 users can access, modify, and delete their data at any time and that some features of the application are designed 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. 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 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.

Privacy

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 companies. 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.

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 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 service 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 also say they obtain parental consent before collecting personal information from children, both in the United States, the European Union, and other countries. Lastly, Duolingo says that it collects a parent's email addresses to contact parents and obtain consent for their children's account.

Rating

This product received a Warning rating based on the following details:
  • Unclear whether personal information is sold or rented to third parties.
  • Personal information is shared for third-party marketing.
  • Personalised advertising is displayed.
  • Data are collected by third-parties for their own purposes.
  • User's information is used to track and target advertisements on other third-party websites or services.
  • Data profiles are created and used for personalised advertisements.
Data Collection
SCORE: 45%

What data does it collect?

  • Personally identifiable information (PII) is 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.
  • Interactions, behaviors, or usage analytics data are collected.
  • Unclear whether this product collects sensitive data.
  • 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: 70%

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.
  • Unclear whether the categories of third parties that receive data are indicated.
  • Data are 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 supported.
  • Unclear whether 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.
  • Account creation is required.
  • Unclear whether 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.
  • Unclear whether this product uses reasonable security practices 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 all data are stored in an encrypted format.
  • Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 85%

What rights do I have to the data?

  • Users can 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.
  • Unclear whether this product deletes data when no longer necessary.
  • Methods are available to restrict who has access to data.
  • Processes to download user data are available.
Data Sold
SCORE: 25%

Is the data sold?

  • Unclear whether personal information is sold or rented to third parties.
  • Users can opt out from the disclosure or sale of their data to a third party.
  • Unclear whether 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.
  • Unclear whether third-party transfers are contractually required to use the same privacy practices.
  • User information that is shared is 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: 55%

How safe is this product?

  • Users can interact with trusted users.
  • Users can interact with untrusted users, including strangers and/or adults.
  • Profile information must be shared for social interactions.
  • Personal information can be displayed publicly.
  • Users can control how their data are displayed to others.
  • User-created content is reviewed, screened, or monitored by the company.
  • Unclear whether user-created content is 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: 60%

Are there advertisements or tracking?

  • Personal information is shared for third-party marketing.
  • Traditional or contextual advertisements are displayed.
  • Personalised advertising is displayed.
  • Data are collected by third-parties for their own purposes.
  • User's information is used to track and target advertisements on other third-party websites or services.
  • Data profiles are created and used for personalised advertisements.
  • The company can 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: 55%

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.
  • Unclear whether company has 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.
  • Unclear whether this product provides parental consent notice and method for submission.
School Purpose
SCORE: 38%

Is the product intended for school?

  • Intended for students.
  • Unclear whether personal information or education records are collected from preK-12 students.
  • Unclear whether intended for teachers.
  • 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: 40%

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.
  • Unclear whether company may 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.
  • Unclear whether 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.