23andMe · 23andMe Privacy Statement · View original document ↗

Business Asset Transfer in Bankruptcy or Acquisition

High severity Unique · 0 of 325 platforms
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Recent governance activity 23andMe recorded 2 documented changes in the last 30 days.
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Document Record

What it is

If 23andMe is acquired, merges with another company, or goes through bankruptcy, your personal and genetic data may be transferred to the new owner as a business asset.

This analysis describes what 23andMe'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 clause establishes the operational framework for data continuity during corporate transactions, ensuring genetic and health data classified as business assets remain accessible to successor entities. The provision addresses the status of personal information under standard business acquisition protocols rather than treating it as separately governed by user consent requirements.

Recent Activity

This document changed recently

Medium May 5, 2026

The updated privacy statement no longer explicitly directs users to a separate Medical Record Privacy Notice for telehealth services or explains that medical information collected through telehealth is governed by different privacy rules. Previously, the policy stated that users choosing telehealth services coordinated through 23andMe would find healthcare privacy protections described in a separate notice. That reference is now absent from the main privacy statement. Users seeking privacy information specific to telehealth services will need to determine independently whether a separate notice exists or contact 23andMe directly using the provided contact information.

View change record →
Medium Mar 23, 2026

The updated privacy statement no longer explicitly discloses a separate Medical Record Privacy Notice that previously described how medical information is used, disclosed, and maintained for telehealth services. Users who receive telehealth services coordinated through 23andMe may now lack clear notice of which privacy framework governs their medical records, since the reference to that parallel notice has been removed. The organizational scope change from '23andMe Research Institute' to '23andMe' narrows the explicitly named entities responsible for the policy, though operational impact depends on how these entities actually function.

View change record →

Consumer impact (what this means for users)

Given 23andMe's publicly reported financial difficulties and bankruptcy filing, this clause has immediate practical relevance — consumers' genetic data could be acquired by an unknown third party with potentially different data practices. Consumers concerned about this should consider deleting their account and requesting sample discard now.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    Log into your 23andMe account, navigate to Settings, and select the option to delete your account. This will also automatically opt you out of Research and discard your sample — note this process cannot be reversed.

How other platforms handle this

Canva Medium

If Canva is involved in a merger, acquisition, or sale of all or a portion of its assets, your information may be transferred as part of that transaction. We will notify you via email or a prominent notice on our website prior to your information becoming subject to a different privacy policy.

Windsurf Medium

If you are a resident in the EEA, Switzerland or the UK, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We may transfer Personal Information from the EEA, Switzerland or the UK to the U.S. and other third countries ...

OpenAI Medium

We may share or transfer personal information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

See all platforms with this clause type →

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ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

This provision is material to M&A due diligence and implicates CCPA requirements for successor entities to honor existing privacy commitments, as well as FTC guidance on data asset transfers in corporate transactions involving sensitive consumer data.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC has previously intervened in data asset transfers during bankruptcy to protect consumers, and has authority over deceptive privacy practices.
    File a complaint →
  • State AG
    State attorneys general have authority to challenge data transfers that violate state consumer protection and privacy laws including CCPA.
    File a complaint →

Applicable regulations

BIPA
Illinois, USA
CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
HIPAA
United States Federal
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
23andMe Privacy Statement
Entity
23andMe
Document last updated
May 5, 2026
Tracking information
First tracked
March 20, 2026
Last verified
March 20, 2026
Record ID
CA-P-000901
Document ID
CA-D-00148
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
844495d7dee785114a99561b45c570c06ec624efeede6528fc52ced0ba522f1b
Analysis generated
March 20, 2026 10:27 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: 23andMe
Document: 23andMe Privacy Statement
Record ID: CA-P-000901
Captured: 2026-03-20 10:27:43 UTC
SHA-256: 844495d7dee78511…
URL: https://conductatlas.com/platform/23andme/23andme-privacy-statement/business-asset-transfer-in-bankruptcy-or-acquisition/
Accessed: May 20, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

Other risks in this policy

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Frequently Asked Questions

What does 23andMe's Business Asset Transfer in Bankruptcy or Acquisition clause do?

This clause establishes the operational framework for data continuity during corporate transactions, ensuring genetic and health data classified as business assets remain accessible to successor entities. The provision addresses the status of personal information under standard business acquisition protocols rather than treating it as separately governed by user consent requirements.

How does this clause affect you?

Given 23andMe's publicly reported financial difficulties and bankruptcy filing, this clause has immediate practical relevance — consumers' genetic data could be acquired by an unknown third party with potentially different data practices. Consumers concerned about this should consider deleting their account and requesting sample discard now.

Is ConductAtlas affiliated with 23andMe?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by 23andMe.