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The policy states that BeReal uses AI to infer a user's likely gender from their username, first name, and biography, and to infer likely interests from the visual content of photos, with both used exclusively as internal criteria for selecting ads shown within the app.
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 AI-based processing of profile data and photo content to generate inferred attributes used for ad targeting. The legal basis and data protection compliance of inferring a characteristic associated with a protected category (gender) from profile text, and of analyzing user-generated photo content for interest signals, may require evaluation under GDPR automated processing provisions and applicable U.S. state sensitive data frameworks.
Interpretive note: Whether AI-inferred gender from profile text constitutes special category data under GDPR or sensitive personal information under applicable U.S. state law depends on regulatory guidance and enforcement interpretation that has not been definitively resolved.
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, BeReal's systems analyze the visual content of a user's photos and profile text fields (username, first name, biography) to infer likely gender and interests, which are then used to select which ads are shown to that user. The policy states these inferences are used exclusively for internal targeting and are not sold or shared with advertisers.
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"Your likely interests derived from the visual elements of your photos, used exclusively as internal targeting criteria. Your likely gender, inferred via AI from your username, first name and biography, used exclusively as internal targeting criteria.Excerpt from BeReal's Privacy Policy
REGULATORY LANDSCAPE: This provision implicates GDPR, particularly provisions relating to automated processing, profiling, and potentially special category data if gender inference is treated as a protected characteristic under applicable law. The relevant enforcement authority is CNIL as lead supervisory authority, with competent local DPAs for EU/EEA users. Under U.S. state law, inferred gender may qualify as sensitive personal information under CPRA and analogous state statutes, triggering heightened use and disclosure obligations. The FTC's authority over unfair or deceptive data practices is also potentially relevant. GOVERNANCE EXPOSURE: High. Inferring gender from profile text and analyzing photo content for interest signals for ad targeting purposes creates compliance exposure across multiple frameworks. GDPR's provisions on profiling and automated processing, and the question of whether inferred gender constitutes special category data, require legal assessment. The policy asserts this processing relies on legitimate interest or consent depending on jurisdiction, but the adequacy of that basis for AI-based gender inference warrants specific legal review. JURISDICTION FLAGS: EU/EEA users face the highest exposure given GDPR's treatment of automated profiling and potential special category data implications. California residents may have rights to opt out of or limit processing of sensitive personal information under CPRA if gender inference qualifies. Illinois, Texas, and other states with biometric or sensitive data laws may create additional obligations depending on whether photo analysis implicates those frameworks. CONTRACT AND VENDOR IMPLICATIONS: The policy does not identify the specific AI system or vendor used for gender and interest inference. Procurement and vendor assessment teams should identify whether this processing is conducted by BeReal internally or by a third-party AI provider, and assess applicable data processing agreements and subprocessor disclosures. COMPLIANCE CONSIDERATIONS: Compliance teams should evaluate whether a Data Protection Impact Assessment (DPIA) has been conducted for the AI gender inference processing, whether the legitimate interest basis is documented and defensible under GDPR's balancing test, and whether consent mechanisms in the app adequately disclose the nature of AI-based profile analysis to users prior to processing. The opt-out mechanism via 'Modify my consents' in app Privacy settings should be tested for accessibility and effectiveness.
This provision establishes AI-based processing of profile data and photo content to generate inferred attributes used for ad targeting. The legal basis and data protection compliance of inferring a characteristic associated with a protected category (gender) from profile text, and of analyzing user-generated photo content for interest signals, may require evaluation under GDPR automated processing provisions and applicable U.S. state …
Under this provision, BeReal's systems analyze the visual content of a user's photos and profile text fields (username, first name, biography) to infer likely gender and interests, which are then used to select which ads are shown to that user. The policy states these inferences are used exclusively for internal targeting and are not sold or shared with advertisers.
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