Get the weekly research letter
Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean. No account.
The policy states that BeReal records touch and swipe interactions with the app interface for a randomized 0.001% sample of users, conducted via an analytics partner, retained for a maximum of 90 days, and not deployed in all geographic regions.
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 session recording program involving a third-party analytics partner. The geographic deployment limitation and the involvement of an external partner in processing interaction recordings may require evaluation under applicable regional data protection law and subprocessor disclosure requirements.
Interpretive note: The policy does not identify which geographic regions are excluded from this processing, and does not specify whether users are individually notified when selected for recording, creating uncertainty about the adequacy of disclosure and consent mechanisms.
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, a randomly selected 0.001% of users may have their touch and swipe interactions with the app interface recorded by a third-party analytics partner for up to 90 days. The policy states this processing is not deployed in all geographic regions and does not identify which regions are included or excluded.
Cross-platform context
See how other platforms handle UX Interaction Recording for Sampled Users and similar clauses.
Compare across platforms →Monitoring
BeReal has changed this document before.
Receive same-day alerts, structured change summaries, and monitoring for up to 25 platforms.
"For a randomized sample of users (0.001%), we record technical interactions with the App interface, such as touching and swiping. This is conducted through our analytic partner to help us visualize how users navigate the App and improve the overall user interface. This processing is not deployed in all geographic regions and may not apply depending on your location. This data is kept for a maximum of 90 days from the time of collection and is then automatically deleted.Excerpt from BeReal's Privacy Policy
REGULATORY LANDSCAPE: This provision implicates GDPR's requirements for lawful basis, data minimization, and subprocessor agreements, as well as the EU ePrivacy Directive for device-level data collection. Applicable U.S. state consumer privacy laws may also apply depending on the user's state of residence. CNIL is the lead supervisory authority for GDPR purposes. GOVERNANCE EXPOSURE: Low to Medium. The 0.001% sample size limits the scale of processing, and the 90-day retention cap and automatic deletion represent disclosed data minimization measures. However, the policy does not identify the analytics partner conducting the recording, which limits the ability to assess subprocessor risk and applicable privacy practices. JURISDICTION FLAGS: The policy's statement that this processing 'is not deployed in all geographic regions' without specifying which regions are excluded creates uncertainty. EU/EEA users may have heightened protection if the processing is excluded from those regions, but this cannot be confirmed from the policy text alone. California and other U.S. states with consumer privacy laws may create disclosure or consent obligations for this processing. CONTRACT AND VENDOR IMPLICATIONS: The analytics partner conducting the recordings should be identified in subprocessor disclosures and assessed under applicable data processing agreement requirements. The partner's own privacy practices govern how they handle the recorded data, and BeReal's policy directs users to the partner list for further information. COMPLIANCE CONSIDERATIONS: Compliance teams should confirm whether users in the sample are notified prior to or upon recording, and whether consent is obtained where required by applicable law. The geographic deployment scope should be documented to support regional compliance assessments. The automatic 90-day deletion should be verified in practice.
Full institutional analysis
Regulatory citations, enforcement risk, and due diligence action items.
Monitor: same-day alerts on the platforms you choose. Analyst: full institutional analysis.
Compliance Governance Intelligence
Need to monitor specific governance provisions?
Compliance includes provision-level monitoring, governance timelines, regulatory mapping, and audit-ready analysis.
Built from archived source documents, structured governance mappings, and historical version tracking.
This provision establishes a session recording program involving a third-party analytics partner. The geographic deployment limitation and the involvement of an external partner in processing interaction recordings may require evaluation under applicable regional data protection law and subprocessor disclosure requirements.
Under this provision, a randomly selected 0.001% of users may have their touch and swipe interactions with the app interface recorded by a third-party analytics partner for up to 90 days. The policy states this processing is not deployed in all geographic regions and does not identify which regions are included or excluded.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by BeReal.