23andMe collects your genetic information from your DNA sample as well as self-reported health data, family history, traits, and behavioral information from how you use the service. This data collectively forms an unusually comprehensive personal profile.
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
The scope definition determines which digital properties and service interactions fall under the privacy framework described in the statement. This establishes the jurisdictional boundaries for how 23andMe applies its privacy procedures across its portfolio of platforms and services.
Interpretive note: The full document text was truncated; the complete list of data categories collected and detailed use purposes may be specified in sections not fully available in the reviewed excerpt.
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 →The data 23andMe collects spans your DNA sequence, health conditions, family relationships, and digital behavior, creating a profile that cannot be changed or replaced if compromised; users should carefully review all consent options before submitting a sample.
How other platforms handle this
"By clicking 'Next', you are indicating that you have read and agree to the TERMS OF USE AND PRIVACY POLICY"
We automatically collect certain information from your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Service, we collect information about the individual web pages or products th...
Location data. Data about your device's location, which can be either precise or imprecise. For example, we collect location data using Global Navigation Satellite System (GNSS) (e.g., GPS) and data about nearby cell towers and Wi-Fi hotspots. Location can also be inferred from a device's IP address...
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"This Privacy Statement applies to all websites owned and operated by 23andMe, including www.23andme.com, and any other websites, pages, features, or content we own or operate, and to your use of the 23andMe mobile app and any related Services.— Excerpt from 23andMe's 23andMe Privacy Statement
REGULATORY LANDSCAPE: Genetic data is classified as a special category of personal data under GDPR Article 9, requiring explicit consent as the lawful basis for processing in most contexts. The collection of health-related phenotypic data alongside genetic information may engage HIPAA-adjacent frameworks at the state level even if 23andMe is not a covered entity under federal HIPAA. The California Genetic Information Privacy Act imposes specific consent and use limitations beyond CCPA. The FTC's health breach notification rule and guidance on sensitive health data are also relevant to the data collection scope. GOVERNANCE EXPOSURE: High. The breadth of data collected, spanning biological, health, familial, and behavioral categories, creates significant governance exposure across multiple regulatory frameworks simultaneously. The permanent and heritable nature of genetic data means that any breach, unauthorized use, or consent failure has consequences that are not correctable after the fact. JURISDICTION FLAGS: EU/EEA users are protected by GDPR's explicit consent requirement for special category data; national data protection authorities in Germany and France have historically taken conservative positions on genetic data processing. Illinois BIPA does not directly cover genetic sequencing but may apply to certain biometric data elements. States with standalone genetic privacy statutes (California, Texas, Florida, Illinois, Washington) create layered obligations beyond federal baselines. CONTRACT AND VENDOR IMPLICATIONS: Laboratory partners, cloud storage providers, and analytics vendors handling genetic data should be subject to data processing agreements with appropriate security and use limitation provisions consistent with GDPR Article 28 and equivalent US standards. Insurance against genetic data breach events should be evaluated given the severity and permanence of potential harms. COMPLIANCE CONSIDERATIONS: A comprehensive data mapping exercise covering all categories of data collected, all systems in which they are stored, and all downstream uses (including research partnerships) is essential. Consent records for each data category and use purpose should be maintained with sufficient granularity to demonstrate compliance with GDPR and CCPA requirements. Security certification and breach response protocols specific to genetic data should be reviewed.
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The scope definition determines which digital properties and service interactions fall under the privacy framework described in the statement. This establishes the jurisdictional boundaries for how 23andMe applies its privacy procedures across its portfolio of platforms and services.
The data 23andMe collects spans your DNA sequence, health conditions, family relationships, and digital behavior, creating a profile that cannot be changed or replaced if compromised; users should carefully review all consent options before submitting a sample.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by 23andMe.