BeReal · BeReal Privacy Policy · View original document ↗

Change in Ownership Data Transfer

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Document Record

What it is

The policy states that in the event of a merger, acquisition, reorganization, asset sale, or bankruptcy, BeReal may share, sell, or transfer user information to the relevant party, with the current Privacy Policy stated to apply to transferred information.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision reserves the right to transfer user data to an acquiring or successor entity in a range of corporate transactions. The assertion that the current Privacy Policy would apply to transferred information does not bind the acquiring entity to maintain the same practices, and the actual privacy treatment of transferred data would depend on the acquiring entity's policies and applicable law.

Recent Activity

This document changed recently

Medium Jul 8, 2026

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.

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Clause Stability Stable

0
Changes
4
Months Monitored
Jul 9, 2026
First Seen
Jul 9, 2026
Last Seen

Consumer impact (what this means for users)

Under this provision, user data across all categories collected by BeReal may be shared, sold, or transferred to another entity in connection with a merger, acquisition, asset sale, or bankruptcy. The policy asserts the current Privacy Policy applies to transferred information, though the enforceability of that assertion against an acquiring entity would depend on applicable law and the terms of any transaction.

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
In the event of a merger, acquisition, reorganization or sale of assets, or bankruptcy, BeReal may share, sell or transfer information about you. This Privacy Policy would apply to all transferred information.

Excerpt from BeReal's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

REGULATORY LANDSCAPE: This provision implicates GDPR requirements for lawful transfer of personal data in corporate transactions, including the need for a valid legal basis for the transfer and appropriate safeguards if transferred to an entity outside the EU/EEA. CCPA and analogous U.S. state laws may impose notice or opt-out requirements depending on the nature of the transaction. CNIL is the lead supervisory authority for GDPR purposes. GOVERNANCE EXPOSURE: Medium. The provision is standard in consumer-facing privacy policies but the assertion that the current Privacy Policy applies to all transferred information does not legally bind a successor entity to maintain equivalent practices absent contractual or regulatory requirements. Users have no opt-out right specified for this type of transfer. JURISDICTION FLAGS: EU/EEA users retain GDPR data subject rights regardless of corporate ownership changes, and any transfer to a non-EU/EEA acquirer would require appropriate safeguards. California residents may have rights under CCPA depending on how the transaction is structured and whether it constitutes a 'sale' under the statute. CONTRACT AND VENDOR IMPLICATIONS: In M&A due diligence, the acquirer should assess the scope of user data collected under this policy, the legal bases for processing, and any ongoing regulatory investigations or obligations. The assertion that the current policy applies post-transfer should be reviewed as part of transaction documentation. COMPLIANCE CONSIDERATIONS: Compliance teams conducting or reviewing M&A transactions involving BeReal should assess whether applicable law requires user notification of ownership changes affecting personal data processing, and whether the acquiring entity's privacy practices are compatible with the representations made in this policy.

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Applicable agencies

  • FTC
    The FTC has authority over consumer data practices in corporate transactions, including whether post-acquisition data use is consistent with prior privacy representations.
    File a complaint →

Provision details

Document information
Document
BeReal Privacy Policy
Entity
BeReal
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-014999
Document ID
CA-D-00250
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
1bcaea508b2d4d3072f172a6021b5cb0ecb6214987a133d040c2ca03aa9f8663
Analysis generated
July 9, 2026 06:54 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: BeReal
Document: BeReal Privacy Policy
Record ID: CA-P-014999
Captured: 2026-07-09 06:54:13 UTC
SHA-256: 1bcaea508b2d4d30…
URL: https://conductatlas.com/platform/bereal/bereal-privacy-policy/provision/CA-P-014999/change-in-ownership-data-transfer/
Accessed: July 24, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does BeReal's Change in Ownership Data Transfer clause do?

This provision reserves the right to transfer user data to an acquiring or successor entity in a range of corporate transactions. The assertion that the current Privacy Policy would apply to transferred information does not bind the acquiring entity to maintain the same practices, and the actual privacy treatment of transferred data would depend on the acquiring entity's policies and …

How does this clause affect you?

Under this provision, user data across all categories collected by BeReal may be shared, sold, or transferred to another entity in connection with a merger, acquisition, asset sale, or bankruptcy. The policy asserts the current Privacy Policy applies to transferred information, though the enforceability of that assertion against an acquiring entity would depend on applicable law and the terms of …

Is ConductAtlas affiliated with BeReal?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by BeReal.