BeReal says it is not for children under 13 and that users aged 13 to 17 need a parent or guardian's consent, but the platform does not describe a technical age verification mechanism.
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
Without a robust age verification mechanism, the policy's restrictions on minors are difficult to enforce, and the platform's demographic appeal to teenagers creates regulatory exposure under COPPA (US) and GDPR Article 8 (EU) if underage users are collecting and sharing data without verified parental consent.
Interpretive note: The adequacy of BeReal's age verification mechanism is not described in detail in the available policy text; COPPA compliance depends heavily on the technical implementation, which cannot be fully assessed from the policy language alone.
This provision means users under 13 are formally excluded, but the absence of a described technical verification method means underage users may access the platform, with their dual-camera imagery and location data collected without verified parental consent.
How other platforms handle this
Our Services are not directed to children under 13. If you learn that anyone younger than 13 has unlawfully provided us with personal data, please contact us at privacy@medium.com.
Our services are restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on our platform and we do not knowingly collect personal information from anyone under 18. If you suspect that a user is under the age of 18, please use the reporting mechanism available...
If you do not have a social security number you may still be eligible to open a limited Revolut personal account. Depending on your immigration status, we may ask you to provide us with a copy of your supported U.S. visa and may limit your access to certain products and features.
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"BeReal is not intended for children under the age of 13. We do not knowingly collect personal data from children under 13. If you are between 13 and 17 years of age, you may use BeReal only with the involvement and consent of a parent or guardian.— Excerpt from BeReal's BeReal Privacy Policy
(1) REGULATORY LANDSCAPE: The Children's Online Privacy Protection Act (COPPA) in the United States prohibits collecting personal data from children under 13 without verifiable parental consent, enforced by the FTC. GDPR Article 8 sets the age of digital consent at 16 (with member states permitted to lower it to 13), and requires verifiable parental consent for children below that threshold. The UK Age Appropriate Design Code (Children's Code) imposes additional obligations on services likely to be accessed by children under 18. BeReal's platform is well-documented as having significant youth usage, which increases the scrutiny applied to its age assurance practices. (2) GOVERNANCE EXPOSURE: High. The policy's reliance on a 'we do not knowingly collect' standard without describing a technical age verification mechanism is a known COPPA compliance vulnerability. The FTC has brought enforcement actions against social media and app platforms under COPPA for similar practices. The UK ICO has actively enforced the Children's Code against social media platforms. The combination of BeReal's youth demographic and its collection of facial imagery and location data amplifies this exposure. (3) JURISDICTION FLAGS: United States (COPPA, FTC enforcement), EU/EEA (GDPR Article 8, member state implementing laws), UK (Children's Code, UK ICO enforcement). France, as BeReal's home jurisdiction, implements GDPR Article 8 with a 15-year threshold. The FTC's recent updates to COPPA rules have increased scrutiny of passive 'do not knowingly collect' approaches. (4) CONTRACT AND VENDOR IMPLICATIONS: Any third-party advertising partner receiving data from BeReal should be informed of the platform's age restrictions; sharing data from potentially underage users with advertising partners creates compounded COPPA and GDPR Article 8 liability. Sub-processor agreements should address handling of data identified as originating from users below the applicable age threshold. (5) COMPLIANCE CONSIDERATIONS: Legal teams should assess whether BeReal's current age gate mechanism constitutes 'verifiable parental consent' under COPPA's standards, and whether it satisfies GDPR Article 8's requirement for 'reasonable efforts' to verify age. A technical age assurance review, benchmarked against the UK ICO's Children's Code standards, is recommended given BeReal's known youth user base.
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Without a robust age verification mechanism, the policy's restrictions on minors are difficult to enforce, and the platform's demographic appeal to teenagers creates regulatory exposure under COPPA (US) and GDPR Article 8 (EU) if underage users are collecting and sharing data without verified parental consent.
This provision means users under 13 are formally excluded, but the absence of a described technical verification method means underage users may access the platform, with their dual-camera imagery and location data collected without verified parental consent.
ConductAtlas has identified this type of provision across 2 platforms. See the full comparison.
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