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
This provision establishes the operational framework for data distribution across the service delivery ecosystem. It creates contractual obligations binding third-party recipients to limited use restrictions, defining the scope of data access necessary for platform operations.
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 →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 →Under this clause, users' personal information is shared with multiple categories of external entities as part of standard service delivery. The terms authorize this sharing contingent on third-party compliance with use limitations specified in the contracts between 23andMe and those vendors.
How other platforms handle this
We may also share your personal information with third parties that assist us in providing our services, or where we are under an obligation to report to. But rest assured: we will only ever share your personal information in the limited circumstances described in this Policy.
We may share your personal information with third parties in the following circumstances: With service providers who perform services on our behalf, such as data analytics, marketing, customer service, and technology services. With financial partners, including banks, brokerage firms, and payment pr...
We may share your information with third parties that perform services on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. We may also share your information with business partners who offer products or services that...
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"We share your information with third-party service providers, business partners, and other vendors that help us provide our Services, operate our business, and communicate with you. These third parties may include, for example, companies that provide services like cloud computing and storage, payment processing, customer support, marketing, and analytics. We require these third parties to use your personal information only as necessary to provide the service or perform the function for which we've contracted with them.— Excerpt from 23andMe's 23andMe Privacy Statement
ConductAtlas detected a major restructuring of Meta’s privacy policy that removed detailed consumer rights disclosures and relocated them to separate documents.
Your genetic data may be transferred to a new owner as a business asset. Here is what the Terms of Service actually say and what you can do right now.
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This provision establishes the operational framework for data distribution across the service delivery ecosystem. It creates contractual obligations binding third-party recipients to limited use restrictions, defining the scope of data access necessary for platform operations.
Under this clause, users' personal information is shared with multiple categories of external entities as part of standard service delivery. The terms authorize this sharing contingent on third-party compliance with use limitations specified in the contracts between 23andMe and those vendors.
ConductAtlas has identified this type of provision across 2 platforms. See the full comparison.
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