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.
Removal of explicit international data transfer provision eliminates disclosure about cross-border data movement and associated regulatory frameworks affecting user privacy.
View full 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
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...
we also transfer personal information to all other countries in which Adobe or its affiliates, providers, and partners operate. We carry out these transfers in compliance with applicable laws – for example, by putting data transfer agreements in place...
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...
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 …
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
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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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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 288 platforms. See the full comparison.
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