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The agreement states that participation in sharing features, including DNA Relatives and Your Connections, is a voluntary user election rather than a default setting.
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 that genetic relationship data disclosed through features such as DNA Relatives is shared only upon affirmative user participation, which has implications for the genetic privacy of both the opting-in user and any biological relatives whose identities may be inferred from shared genetic data.
Interpretive note: The document does not describe the specific data elements shared through DNA Relatives and Your Connections, the scope of visibility between matched users, or the privacy protections applied to biological relatives who are not 23andMe account holders.
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 provision, users must affirmatively opt into sharing features such as DNA Relatives and Your Connections; these features are not enabled by default. Participation in these features may result in genetic relationship information being visible to or matched with other 23andMe users who are biological relatives.
Cross-platform context
See how other platforms handle DNA Relatives and Sharing Features Opt-In and similar clauses.
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"You decide whether you want to participate in our sharing features, like DNA Relatives and Your Connections.Excerpt from 23andMe's Privacy Statement
(1) REGULATORY LANDSCAPE: This provision engages genetic privacy frameworks including California GIPA, GDPR Article 9 (genetic data as special category), and UK GDPR. The sharing of genetic relationship data through features like DNA Relatives may implicate the privacy interests of third-party biological relatives who have not consented to 23andMe's data practices, which is a recurring regulatory concern under GDPR and state genetic privacy laws. (2) GOVERNANCE EXPOSURE: Medium. The opt-in framing mitigates some regulatory exposure by requiring affirmative consent. However, genetic relationship features inherently involve the processing of data that reveals information about individuals who are not 23andMe account holders, raising third-party privacy considerations that may require assessment under applicable law. (3) JURISDICTION FLAGS: EU and UK users have GDPR and UK GDPR protections for genetic data as special category information. California GIPA governs use and disclosure of genetic data for California residents. The genetic privacy interests of biological relatives who are not 23andMe customers may create regulatory exposure in jurisdictions with broad genetic information protection statutes. (4) CONTRACT AND VENDOR IMPLICATIONS: The document does not describe the technical or contractual mechanisms governing data flows within the DNA Relatives feature, including whether matched users' data is disclosed reciprocally and under what conditions. Legal teams should assess whether the data flows within this feature are accurately described in the privacy notice and compliant with applicable consent requirements. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should review whether the consent mechanism for DNA Relatives and similar features satisfies GDPR requirements for special category data processing, including explicit consent under Article 9. The privacy implications for third-party biological relatives who are not 23andMe users should be assessed and disclosed appropriately in the privacy notice.
This provision establishes that genetic relationship data disclosed through features such as DNA Relatives is shared only upon affirmative user participation, which has implications for the genetic privacy of both the opting-in user and any biological relatives whose identities may be inferred from shared genetic data.
Under this provision, users must affirmatively opt into sharing features such as DNA Relatives and Your Connections; these features are not enabled by default. Participation in these features may result in genetic relationship information being visible to or matched with other 23andMe users who are biological relatives.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by 23andMe.