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The policy states that advertising network and mediation partners may collect data directly from users' devices through SDKs or cookies embedded in the BeReal app, operating under those partners' own privacy policies rather than BeReal's policy.
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 that third-party ad partners operate their own data collection infrastructure within the BeReal app, processing user data under their own privacy policies. BeReal directs users to a separate partner list for information about those practices and to exercise rights directly with those partners.
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, advertising and mediation partners integrated into the BeReal app may collect identifiers, device data, and usage information directly from a user's device via SDKs or cookies, subject to those partners' own privacy policies. BeReal's policy directs users to a partner list to review those practices and exercise rights.
Cross-platform context
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"To allow us to monetize the ad inventory of our App and provide users with free products and services, we work with advertising networks and mediation partners. These partners may collect information directly from your device or your use of the App through their own tools, such as software development kits ("SDKs") or cookies, in accordance with their own privacy policies.Excerpt from BeReal's Privacy Policy
REGULATORY LANDSCAPE: This provision implicates GDPR's requirements for joint controller or controller-processor relationships and the EU ePrivacy Directive's requirements for consent to SDK and cookie-based data collection. CCPA and analogous U.S. state laws apply to the extent ad partners' collection activities constitute a 'sale' or 'sharing' of personal information. The FTC has authority over unfair or deceptive data practices involving third-party collection within consumer apps. GOVERNANCE EXPOSURE: Medium. The involvement of multiple advertising and mediation partners collecting data independently under their own policies creates a complex data governance environment. The policy does not enumerate specific partners within the policy text, instead directing users to an external list, which limits in-document transparency. JURISDICTION FLAGS: EU/EEA users are entitled under GDPR and ePrivacy to prior informed consent for SDK and cookie-based collection by third parties. California residents may have opt-out rights over data collected by ad partners if that collection constitutes a sale or sharing under CPRA. The adequacy of the consent mechanism for third-party SDK collection should be assessed by jurisdiction. CONTRACT AND VENDOR IMPLICATIONS: Legal and procurement teams should review the partner list referenced in the policy to identify all ad network and mediation partners, assess their applicable privacy policies and data practices, and confirm that data processing agreements or equivalent contractual protections are in place. The policy's statement that partners operate under their own policies suggests BeReal may not assert direct control over partner collection practices. COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether the consent mechanism presented to users at app onboarding or within the Privacy settings adequately covers third-party SDK collection, and whether the partner list is kept current and accessible. The opt-out of sale and sharing in app Privacy settings should be tested to confirm it operates to suppress third-party SDK-based data collection.
This provision establishes that third-party ad partners operate their own data collection infrastructure within the BeReal app, processing user data under their own privacy policies. BeReal directs users to a separate partner list for information about those practices and to exercise rights directly with those partners.
Under this provision, advertising and mediation partners integrated into the BeReal app may collect identifiers, device data, and usage information directly from a user's device via SDKs or cookies, subject to those partners' own privacy policies. BeReal's policy directs users to a partner list to review those practices and exercise rights.
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