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The policy states that BeReal does not sell personal information in the traditional sense but acknowledges that certain advertising activities may qualify as a sale, sharing, or targeted advertising processing under applicable U.S. state privacy laws, covering identifiers, device identifiers, mobile advertising IDs, network activity, approximate geolocation, and advertising-related inferences.
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 the categories of personal information that may have been involved in advertising-related disclosures or processing activities that qualify as sale, sharing, or targeted advertising under U.S. state law, and identifies the opt-out mechanism available to users.
Interpretive note: The policy uses 'may have' language, acknowledging definitional uncertainty across state frameworks; whether specific activities qualify as sale or sharing depends on applicable statutory definitions and enforcement interpretations.
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, users' identifiers, device identifiers, mobile advertising IDs, internet activity information, approximate geolocation, and advertising-related inferences may have been shared or processed in ways that qualify as a sale or sharing under applicable U.S. state privacy laws. Users can opt out by navigating to 'Privacy' settings in the app and selecting 'Modify my consents,' or by contacting dpo@bere.al.
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"We do not sell personal information as traditionally understood. However, under some U.S. state privacy laws, certain advertising or measurement activities may be considered a "sale", "sharing" or processing for "targeted advertising". In the last twelve (12) months, we may have sold, shared or processed for targeted advertising the following categories of personal information: identifiers, device identifiers, mobile advertising IDs, internet or other electronic network activity information, approximate geolocation information, and advertising-related inferences.Excerpt from BeReal's Privacy Policy
REGULATORY LANDSCAPE: This provision directly engages CCPA as amended by CPRA and analogous U.S. state consumer privacy laws. The California Privacy Protection Agency (CPPA) and California Attorney General enforce CCPA/CPRA. State attorneys general in states with analogous statutes hold corresponding enforcement authority. The provision's acknowledgment that activities 'may' qualify as sale or sharing reflects the unsettled definitional scope of those terms across state frameworks. GOVERNANCE EXPOSURE: Medium. The policy's use of 'may have' language regarding sale and sharing over the prior twelve months reflects appropriate disclosure practice under CCPA/CPRA but creates a compliance documentation obligation. Compliance teams should maintain records of which advertising and measurement activities occurred and whether they meet the statutory definitions of sale or sharing in each applicable state. JURISDICTION FLAGS: California creates the highest current exposure given CPRA's expanded definition of sharing for cross-context behavioral advertising and the CPPA's active enforcement posture. Virginia, Colorado, Connecticut, Texas, and other states with consumer privacy statutes imposing targeted advertising opt-out rights create parallel obligations. The policy commits to processing California opt-out requests within 15 business days. CONTRACT AND VENDOR IMPLICATIONS: Ad network and measurement partners who receive the data categories listed in this provision should be assessed for compliance with applicable state law opt-out signal requirements, including Global Privacy Control (GPC) recognition where required. Data processing agreements with these partners should address sale and sharing limitations consistent with the opt-out mechanism the policy establishes. COMPLIANCE CONSIDERATIONS: Compliance teams should verify that the opt-out mechanism in app Privacy settings operates to suppress all categories of data listed in this provision from sale, sharing, and targeted advertising processing upon user election. Annual records of data categories involved in advertising-related disclosures should be maintained to support the twelve-month look-back disclosure required by CCPA/CPRA. The policy should also be assessed for GPC signal recognition requirements under CPRA regulations.
This provision establishes the categories of personal information that may have been involved in advertising-related disclosures or processing activities that qualify as sale, sharing, or targeted advertising under U.S. state law, and identifies the opt-out mechanism available to users.
Under this provision, users' identifiers, device identifiers, mobile advertising IDs, internet activity information, approximate geolocation, and advertising-related inferences may have been shared or processed in ways that qualify as a sale or sharing under applicable U.S. state privacy laws. Users can opt out by navigating to 'Privacy' settings in the app and selecting 'Modify my consents,' or by contacting dpo@bere.al.
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