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The policy states that advertisers may provide BeReal with hashed lists of their customers' phone numbers, which BeReal matches against hashed phone numbers in its user account database to identify which BeReal users to show that advertiser's ads to, with the hashed values from advertisers deleted after the matching process.
This analysis describes what BeReal's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision establishes a custom audience matching workflow using hashed phone numbers as the matching identifier. The policy asserts that matched audience lists and BeReal user phone numbers are not disclosed back to advertisers, but the processing of user phone numbers for advertiser targeting purposes may constitute a 'sale' or 'sharing' under applicable U.S. state privacy laws, as acknowledged in Section 9.5.
Interpretive note: Whether this matching workflow constitutes a 'sale' or 'sharing' under specific state privacy laws depends on the applicable statutory definition and enforcement interpretation, which varies by jurisdiction.
The updated policy now requires email address in addition to phone number, full name, and date of birth to create an account. BeReal discloses that it derives likely gender from your username, first name, and biography using AI, and uses this classification for internal targeting purposes. The policy also reveals that a randomized sample of 0.001% of users will have their interface interactions (touches and swipes) recorded through an analytics partner for up to 90 days to understand how users navigate the app; this practice does not apply in all geographic regions. You can review your app settings or contact BeReal to inquire about your data collection status.
View change record →Under this provision, the phone number associated with a user's BeReal account may be used to match the user to an advertiser's customer list for the purpose of displaying that advertiser's ads to the user within the app. The policy states this matching uses hashed values and that user phone numbers are not disclosed to advertisers.
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"When an advertiser runs a campaign with us, it may provide us with a hashed (pseudonymized) list of phone numbers of its own customers. We match this list against hashed phone numbers associated with BeReal user accounts in order to display that advertiser's ads to the relevant users on BeReal. We do not receive phone numbers in clear text from advertisers, and hashed values provided for matching are not kept beyond the matching operation.Excerpt from BeReal's Privacy Policy
REGULATORY LANDSCAPE: This provision implicates CCPA as amended by CPRA, and analogous U.S. state consumer privacy laws, given the policy's own acknowledgment in Section 9.5 that such activities may constitute a 'sale,' 'sharing,' or processing for 'targeted advertising.' GDPR's provisions on lawful basis for processing and data minimization are also relevant for EU users. The FTC has authority over unfair or deceptive data practices in this context. GOVERNANCE EXPOSURE: Medium. The policy discloses the matching workflow and states that hashed advertiser-provided values are not retained beyond the matching operation. However, compliance teams should assess whether the use of user phone numbers for advertiser audience matching, even in hashed form, triggers opt-in or opt-out requirements under applicable state law, and whether the current opt-out mechanism via app settings is operationally adequate and legally sufficient. JURISDICTION FLAGS: California residents have the right to opt out of sale and sharing under CPRA, and the policy commits to processing opt-out requests within 15 business days for California residents. Other U.S. states with consumer privacy laws imposing targeted advertising opt-out rights create similar obligations. EU/EEA users are subject to GDPR consent or legitimate interest requirements for this type of processing. CONTRACT AND VENDOR IMPLICATIONS: Advertiser data processing agreements should address the hashed matching workflow, data retention commitments (the policy asserts hashed values are not kept beyond the matching operation), and the boundaries of what is disclosed to advertisers post-match. Procurement teams should assess whether this workflow is conducted in-house or via a third-party identity resolution or clean room provider. COMPLIANCE CONSIDERATIONS: Compliance teams should verify that the opt-out mechanism for sale, sharing, and targeted advertising in the app's Privacy settings operates to exclude user phone numbers from advertiser matching workflows, and should document the technical implementation of hashed value deletion post-match. Data mapping should reflect phone numbers as a data element used in advertising-related processing.
This provision establishes a custom audience matching workflow using hashed phone numbers as the matching identifier. The policy asserts that matched audience lists and BeReal user phone numbers are not disclosed back to advertisers, but the processing of user phone numbers for advertiser targeting purposes may constitute a 'sale' or 'sharing' under applicable U.S. state privacy laws, as acknowledged in …
Under this provision, the phone number associated with a user's BeReal account may be used to match the user to an advertiser's customer list for the purpose of displaying that advertiser's ads to the user within the app. The policy states this matching uses hashed values and that user phone numbers are not disclosed to advertisers.
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