BeReal collects personal data including photos, location information, device data, and usage information as part of providing the service, and this data may be shared with third parties including analytics providers and advertising partners.
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
BeReal's core product involves capturing dual-camera photos at random moments, which means the app regularly collects images of your face and surroundings, and the terms govern how that sensitive data is used and shared.
Interpretive note: The specific data collection disclosures are contained in BeReal's Privacy Policy rather than the Terms of Service; the exact terms text is not available in the truncated HTML, and this analysis reflects publicly known BeReal data practices and applicable regulatory requirements.
This new high-severity provision explicitly addresses data collection and privacy practices, reflecting increased focus on user data protection and transparency requirements.
View full change record →By using BeReal, you consent to the collection of photos, location data, and other personal information; EU users have rights to access, correct, and delete this data under GDPR, while California users have similar rights under CCPA.
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BeReal has changed this document before.
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(1) REGULATORY LANDSCAPE: Data collection practices engage GDPR for EU and EEA users (with the CNIL as lead supervisory authority), CCPA and CPRA for California residents, COPPA for users under 13 in the US, and potentially Illinois BIPA if facial images are processed as biometric identifiers. The collection of precise location data and front-camera images raises particular sensitivity under these frameworks. (2) GOVERNANCE EXPOSURE: High. The dual-camera photo feature is central to BeReal's product and inherently involves collection of facial images and environmental context at unpredictable times. If these images are processed using facial recognition or similar biometric techniques, exposure under BIPA and GDPR's special categories of personal data provisions is significant. Location data collection raises additional exposure under CCPA and GDPR. (3) JURISDICTION FLAGS: Illinois BIPA creates heightened exposure for facial image collection and processing. GDPR imposes strict requirements on processing of biometric data as a special category. California CPRA grants additional rights regarding sensitive personal information including precise geolocation and biometric data. France's CNIL has historically been active in enforcement against consumer platforms. (4) CONTRACT AND VENDOR IMPLICATIONS: All third-party analytics, advertising, and data processing vendors must have appropriate data processing agreements in place under GDPR Article 28. Any cross-border data transfers to non-EEA countries must rely on an adequate transfer mechanism such as Standard Contractual Clauses. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should conduct a data mapping exercise to identify all categories of personal data collected through BeReal, audit consent mechanisms at account creation and ongoing, verify data retention schedules, and assess whether the privacy notice adequately describes data sharing with third parties at the level of specificity required by GDPR and CCPA. A data protection impact assessment may be warranted given the scale and sensitivity of photo and location data collection.
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BeReal's core product involves capturing dual-camera photos at random moments, which means the app regularly collects images of your face and surroundings, and the terms govern how that sensitive data is used and shared.
By using BeReal, you consent to the collection of photos, location data, and other personal information; EU users have rights to access, correct, and delete this data under GDPR, while California users have similar rights under CCPA.
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