Your personal and genetic data may be transferred to and processed in countries outside your home country, including the United States, which may have different privacy protections.
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
International data transfers are operationally significant because genetic and health data is subject to varying regulatory requirements across jurisdictions. The provision defines how 23andMe complies with data localization rules, adequacy determinations, and standard contractual clauses that govern cross-border data movement.
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 →EU and UK users should be aware that their highly sensitive genetic data is transferred internationally, and should review what transfer mechanisms (such as Standard Contractual Clauses) 23andMe uses to protect their data during those transfers.
How other platforms handle this
Tabnine is headquartered in the United States and operates globally. If you are located outside the United States, your personal data may be transferred to and processed in the United States or other countries that may not provide the same level of data protection as your home country. We rely on ap...
Pinterest, Inc. is based in the US. If you live outside the US, your information will be transferred to and processed in the US and other countries where our partners, service providers, and affiliates operate. We use approved data transfer mechanisms, including standard contractual clauses, to ensu...
If you are a resident in the EEA, Switzerland or the UK, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We may transfer Personal Information from the EEA, Switzerland or the UK to the U.S. and other third countries ...
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International transfers of special category genetic data require GDPR Chapter V-compliant transfer mechanisms; compliance teams should verify that SCCs or adequacy decisions are in place for all receiving jurisdictions, and that transfer impact assessments have been conducted given the sensitivity of genetic data.
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International data transfers are operationally significant because genetic and health data is subject to varying regulatory requirements across jurisdictions. The provision defines how 23andMe complies with data localization rules, adequacy determinations, and standard contractual clauses that govern cross-border data movement.
EU and UK users should be aware that their highly sensitive genetic data is transferred internationally, and should review what transfer mechanisms (such as Standard Contractual Clauses) 23andMe uses to protect their data during those transfers.
ConductAtlas has identified this type of provision across 48 platforms. See the full comparison.
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