On March 23, 2026, 23andMe revised its Terms of Service to narrow the geographic scope of applicability and clarify how conflicting terms are resolved. The updated terms now apply only to users outside the United States, Canada, EEA, UK, and Switzerland, rather than to US-based users. When additional service terms conflict with these Terms, the additional terms now govern that specific service, whereas previously these Terms would control all conflicts.
The updated terms now apply only to users who live outside or access services outside the United States, Canada, EEA, UK, and Switzerland. Previously, the terms applied to US-based users. The terms also clarify that when service-specific terms conflict with the general Terms of Service, the service-specific terms will govern that particular service rather than the general terms controlling all conflicts. This means users of additional services may operate under different dispute resolution and governance procedures depending on which service they are using.
The updated terms establish that users in major markets (US, Canada, EEA, UK, Switzerland) are no longer covered by this general agreement and must operate under separate, region-specific terms. This creates a fragmented governance structure where dispute resolution, data handling, and liability may differ significantly depending on jurisdiction and which service is used. The change also establishes that service-specific terms now override the general Terms in cases of conflict, which means users operating multiple 23andMe services may be subject to different agreements with potentially conflicting dispute resolution or consent mechanisms.
→ If you live in or access services from the United States, Canada, EEA, UK, or Switzerland, review the region-specific Terms of Service applicable to your location, as the general Terms no longer apply to you.
→ If you use additional 23andMe services beyond the base product, review the service-specific terms, as they now override the general Terms in case of conflict.
→ If you are a US or Canada-based user, you may operate under region-specific terms without realizing it, potentially subjecting you to different dispute resolution procedures, data handling practices, or consent mechanisms than you expect.
→ If you use multiple 23andMe services, service-specific terms will apply to each service, and you may not be aware of differences in arbitration clauses, data retention periods, or liability limitations across services.
ConductAtlas has recorded 2 material changes to this document (since March 2026).
Terms now apply only to users outside the US, Canada, EEA, UK, and Switzerland, excluding 23andMe's largest markets from coverage under this general agreement.
Service-specific terms now govern in case of conflict with the general Terms, replacing the previous rule that the general Terms would control all conflicts.
This change record describes what was added, removed, or modified in the document. Analysis reflects what the updated agreement states or permits. It does not constitute a legal determination about enforceability. Applicability may vary by jurisdiction. Methodology
Users in the US and major markets are no longer covered by these general Terms and must review region-specific versions instead.
If you use an additional service with its own terms, those service terms control how that service operates, not the general Terms.
+ 1 more obligation changes. Full breakdown available with Watcher.
Track changes →23andMe significantly narrowed the geographic scope of its general Terms of Service, excluding the US market and major regulatory jurisdictions (EEA, UK). This suggests users in those regions operate under region-specific or service-specific terms not detailed in this document. The revised conflict resolution hierarchy also establishes that service-specific terms now take precedence over the general Terms, which may fragment compliance obligations across different product lines. Organizations relying on these terms should verify which version applies to their user base and identify the service-specific terms that now govern particular offerings.
FTC Act (unfair or deceptive practices); GDPR (if EEA users are subject to separate terms); CCPA (if California users operate under distinct terms). The exclusion of major regulatory markets from the primary Terms raises questions about whether separate, legally compliant terms exist for those jurisdictions and whether the change adequately discloses this to affected users.
Full compliance analysis
Obligation analysis, escalation trigger, board language, and recommended action.
Watcher: regulatory citations + obligations. Professional: full compliance memo.
ConductAtlas provides verified policy intelligence sourced directly from platform documents. All analysis is intended to support, not replace, legal and compliance review. Record CA-C-000061.
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