Khanmigo

AI-powered tutor and teaching assistant from Khan Academy

Duolingo Max

AI-powered language learning with GPT-4 roleplay and explanation features

Khanmigo

Moderate

12/25

Duolingo Max

Caution

11/25

Score Breakdown

DimensionKhanmigoDuolingo Max

Data Residency

Where is your data stored and processed?

Khanmigo: Data hosted in the US on AWS infrastructure. No EU data residency option available, which may concern European schools subject to GDPR.

Duolingo Max: All learner data hosted in the US. No EU data residency option. GDPR transfers handled via SCCs. Not suitable for public-sector EU organisations requiring in-region hosting.

2/5

Data hosted in the US on AWS infrastructure. No EU data residency option available, which may concern European schools subject to GDPR.

2/5

All learner data hosted in the US. No EU data residency option. GDPR transfers handled via SCCs. Not suitable for public-sector EU organisations requiring in-region hosting.

Legal Jurisdiction

Which laws govern the company and your data?

Khanmigo: California nonprofit, subject to US law including the CLOUD Act. Dedicated student privacy statutes (COPPA, FERPA) apply but EU transfers rely on SCCs.

Duolingo Max: Delaware-incorporated US public company. Subject to CLOUD Act. GDPR compliance provided contractually rather than through jurisdictional equivalence.

2/5

California nonprofit, subject to US law including the CLOUD Act. Dedicated student privacy statutes (COPPA, FERPA) apply but EU transfers rely on SCCs.

2/5

Delaware-incorporated US public company. Subject to CLOUD Act. GDPR compliance provided contractually rather than through jurisdictional equivalence.

Data Retention & Training

Is your data used for model training?

Khanmigo: Conversation logs retained for safety monitoring and product improvement. OpenAI does not train on API data from Khan Academy. Parental consent and deletion mechanisms in place for COPPA.

Duolingo Max: Users can request data export and deletion. Anonymised learning data used to improve the adaptive model. Clear privacy policy with opt-out mechanisms for personalisation.

3/5

Conversation logs retained for safety monitoring and product improvement. OpenAI does not train on API data from Khan Academy. Parental consent and deletion mechanisms in place for COPPA.

3/5

Users can request data export and deletion. Anonymised learning data used to improve the adaptive model. Clear privacy policy with opt-out mechanisms for personalisation.

Certifications

ISO 27001, SOC 2, Cyber Essentials, etc.

Khanmigo: SOC 2 Type II reported. Lacks ISO 27001 and formal FERPA third-party audit certification; relies on contractual commitments and self-attestation for education compliance.

Duolingo Max: SOC 2 Type II reported. No ISO 27001. COPPA compliance self-attested. Certification portfolio is light compared to enterprise SaaS peers.

2/5

SOC 2 Type II reported. Lacks ISO 27001 and formal FERPA third-party audit certification; relies on contractual commitments and self-attestation for education compliance.

2/5

SOC 2 Type II reported. No ISO 27001. COPPA compliance self-attested. Certification portfolio is light compared to enterprise SaaS peers.

Regulatory Fit

Suitability for regulated industries and professional services

Khanmigo: Strong fit for US K-12 institutions under COPPA and FERPA. Adequate for general consumer use in EU. Less suitable for highly regulated EU public-sector school environments without additional DPA review.

Duolingo Max: Well-suited for consumer and informal education use. Less appropriate for highly regulated institutional deployments. COPPA compliance makes it viable for K-12 with parental consent.

3/5

Strong fit for US K-12 institutions under COPPA and FERPA. Adequate for general consumer use in EU. Less suitable for highly regulated EU public-sector school environments without additional DPA review.

2/5

Well-suited for consumer and informal education use. Less appropriate for highly regulated institutional deployments. COPPA compliance makes it viable for K-12 with parental consent.

Total Score

12/25

11/25

Best For

Khanmigo

Best for teams on a tight budget.

Duolingo Max

Best for enterprises requiring SSO integration.

Detailed Comparison

Duolingo Max vs Khanmigo: Trust & Compliance Comparison

Duolingo Max (Duolingo, US) scores 11/25 overall with a Review Required (Caution) trust badge. AI-powered language learning with GPT-4 roleplay and explanation features. Khanmigo (Khan Academy, US) scores 12/25 with a Bronze (Moderate) trust badge. AI-powered tutor and teaching assistant from Khan Academy.

Dimension-by-Dimension Breakdown

#### Data Residency

Both score equally at 2/5.

●Duolingo Max (2/5): All learner data hosted in the US. No EU data residency option. GDPR transfers handled via SCCs. Not suitable for public-sector EU organisations requiring in-region hosting.

●Khanmigo (2/5): Data hosted in the US on AWS infrastructure. No EU data residency option available, which may concern European schools subject to GDPR.

#### Legal Jurisdiction

Both score equally at 2/5.

●Duolingo Max (2/5): Delaware-incorporated US public company. Subject to CLOUD Act. GDPR compliance provided contractually rather than through jurisdictional equivalence.

●Khanmigo (2/5): California nonprofit, subject to US law including the CLOUD Act. Dedicated student privacy statutes (COPPA, FERPA) apply but EU transfers rely on SCCs.

#### Data Retention & Training

Both score equally at 3/5.

●Duolingo Max (3/5): Users can request data export and deletion. Anonymised learning data used to improve the adaptive model. Clear privacy policy with opt-out mechanisms for personalisation.

●Khanmigo (3/5): Conversation logs retained for safety monitoring and product improvement. OpenAI does not train on API data from Khan Academy. Parental consent and deletion mechanisms in place for COPPA.

#### Certifications

Both score equally at 2/5.

●Duolingo Max (2/5): SOC 2 Type II reported. No ISO 27001. COPPA compliance self-attested. Certification portfolio is light compared to enterprise SaaS peers.

●Khanmigo (2/5): SOC 2 Type II reported. Lacks ISO 27001 and formal FERPA third-party audit certification; relies on contractual commitments and self-attestation for education compliance.

#### Regulatory Fit

Khanmigo leads with 3/5 vs 2/5.

●Duolingo Max (2/5): Well-suited for consumer and informal education use. Less appropriate for highly regulated institutional deployments. COPPA compliance makes it viable for K-12 with parental consent.

●Khanmigo (3/5): Strong fit for US K-12 institutions under COPPA and FERPA. Adequate for general consumer use in EU. Less suitable for highly regulated EU public-sector school environments without additional DPA review.

Certifications at a Glance

Certification	Duolingo Max	Khanmigo
SOC 2 Type II	Yes	Yes

Overall Verdict

Duolingo Max and Khanmigo are closely matched on trust and compliance, with scores of 11/25 and 12/25 respectively. The right choice depends on your specific regulatory requirements and existing technology stack.

Frequently Asked Questions

Which is better for EU compliance, Khanmigo or Duolingo Max?

Khanmigo has a TrustKit score of 12/25 while Duolingo Max scores 11/25. Khanmigo currently rates higher across data residency, legal jurisdiction, data retention, certifications, and regulatory fit.

How do Khanmigo and Duolingo Max compare on data residency?

Khanmigo scores 2/5 for data residency (Data hosted in the US on AWS infrastructure. No EU data residency option available, which may concern European schools subject to GDPR.), while Duolingo Max scores 2/5 (All learner data hosted in the US. No EU data residency option. GDPR transfers handled via SCCs. Not suitable for public-sector EU organisations requiring in-region hosting.).

Are Khanmigo and Duolingo Max GDPR compliant?

Both tools are assessed across five compliance dimensions. Khanmigo has a regulatory fit score of 3/5 and Duolingo Max scores 2/5. Check the full comparison above for a detailed breakdown.

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