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

Business Transaction Data Transfer

High severity Medium confidence Inferred from context Common · 288 of 352 platforms
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Document Record

What it is

In the event of a merger, acquisition, bankruptcy, or sale of assets, your personal information including your genetic data may be transferred to a new owner as part of that transaction. The policy discloses this possibility but the document reviewed does not specify whether users will receive advance notice or a right to object before such a transfer occurs.

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 operationalizes the user's ability to terminate participation in the service and Research program, while establishing that sample disposal is automated upon deletion. The irreversibility specification creates a procedural checkpoint regarding data and sample retention.

Interpretive note: The full business transaction clause language was not fully reproduced in the document excerpt reviewed; the specific notice obligations and user rights in the event of a transaction may be detailed elsewhere in the full policy.

Clause Stability Stable

0
Changes
5
Months Monitored
May 10, 2026
First Seen
May 11, 2026
Last Seen
This clause type exists across 4430 other provisions on other platforms.

Consumer impact (what this means for users)

A business transaction such as a merger or acquisition could result in your genetic and personal health data being transferred to a new company, potentially one with different privacy policies and data use practices than those you originally agreed to.

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, go to Settings, scroll to the account management section, and select the option to delete your account; this will also trigger discarding of your stored sample and is irreversible.

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...

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...

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...

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
You can delete your 23andMe account any time. If you do, we will automatically opt you out of Research and discard your sample. Keep in mind this process cannot be cancelled or reversed.

Excerpt from 23andMe's Privacy Statement

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

REGULATORY LANDSCAPE: Business transaction data transfers involving genetic data engage GDPR Article 6 lawful basis requirements and, for special category data, Article 9 explicit consent or equivalent grounds; a change of controller in an M&A …

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
May 10, 2026
Last verified
May 10, 2026
Record ID
CA-P-008856
Document ID
CA-D-00148
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
75d8665d135fa6d31192b0d85a6673be7360c09d76bada7d500c8998b5548dc2
Analysis generated
May 10, 2026 11:48 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: 23andMe
Document: 23andMe Privacy Statement
Record ID: CA-P-008856
Captured: 2026-05-10 11:48:38 UTC
SHA-256: 75d8665d135fa6d3…
URL: https://conductatlas.com/platform/23andme/23andme-privacy-statement/provision/CA-P-008856/business-transaction-data-transfer/
Accessed: Sept. 8, 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 Transaction Data Transfer clause do?

This clause operationalizes the user's ability to terminate participation in the service and Research program, while establishing that sample disposal is automated upon deletion. The irreversibility specification creates a procedural checkpoint regarding data and sample retention.

How does this clause affect you?

A business transaction such as a merger or acquisition could result in your genetic and personal health data being transferred to a new company, potentially one with different privacy policies and data use practices than those you originally agreed to.

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.