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

Business Asset Transfer in Bankruptcy or Acquisition

High severity Common · 288 of 352 platforms
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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.

Clause Stability Stable

0
Changes
5
Months Monitored
Apr 3, 2026
First Seen
Apr 10, 2026
Last Seen
This clause type exists across 4430 other provisions on other platforms.

Change history

removed May 21, 2026

The removal of this distinct high-severity provision on data transfer during corporate events reduces clarity on what happens to genetic data in M&A or bankruptcy scenarios.

View full 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

Squarespace Medium

If we're involved in a reorganization, merger, acquisition, sale of some or all of our assets or other business transaction, depending on the circumstances, we may disclose any of the information described in Section 2 above...

Skillshare Medium

Whenever we transfer personal data internationally, we use tools and transfer agreements to: make sure the data transfer complies with applicable law; and help to give your data the same level of protection as it has in the EU...

Tinder Medium

we may share data between our affiliates for the safety and security of our users and may take necessary actions if we believe you have violated these Terms, including banning you from our Services and/or our affiliates' services...

See all platforms with this clause type →
ConductAtlas Analysis

Institutional analysis (regulatory & 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 …

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →
  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

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/provision/CA-P-000901/business-asset-transfer-in-bankruptcy-or-acquisition/
Accessed: Sept. 2, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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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.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 288 platforms. See the full comparison.

Is ConductAtlas affiliated with 23andMe?

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