In the event of a merger, acquisition, bankruptcy, or sale of assets, your personal information including your genetic data may be transferred to a new owner as part of that transaction. The policy discloses this possibility but the document reviewed does not specify whether users will receive advance notice or a right to object before such a transfer occurs.
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 clause operationalizes the user's ability to terminate participation in the service and Research program, while establishing that sample disposal is automated upon deletion. The irreversibility specification creates a procedural checkpoint regarding data and sample retention.
Interpretive note: The full business transaction clause language was not fully reproduced in the document excerpt reviewed; the specific notice obligations and user rights in the event of a transaction may be detailed elsewhere in the full policy.
A business transaction such as a merger or acquisition could result in your genetic and personal health data being transferred to a new company, potentially one with different privacy policies and data use practices than those you originally agreed to.
How other platforms handle this
If we're involved in a reorganization, merger, acquisition, sale of some or all of our assets or other business transaction, depending on the circumstances, we may disclose any of the information described in Section 2 above...
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...
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...
"You can delete your 23andMe account any time. If you do, we will automatically opt you out of Research and discard your sample. Keep in mind this process cannot be cancelled or reversed.Excerpt from 23andMe's Privacy Statement
REGULATORY LANDSCAPE: Business transaction data transfers involving genetic data engage GDPR Article 6 lawful basis requirements and, for special category data, Article 9 explicit consent or equivalent grounds; a change of controller in an M&A …
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
Search "[your state] attorney general consumer complaint" to find your state's direct complaint form
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 clause operationalizes the user's ability to terminate participation in the service and Research program, while establishing that sample disposal is automated upon deletion. The irreversibility specification creates a procedural checkpoint regarding data and sample retention.
A business transaction such as a merger or acquisition could result in your genetic and personal health data being transferred to a new company, potentially one with different privacy policies and data use practices than those you originally agreed to.
ConductAtlas has identified this type of provision across 288 platforms. See the full comparison.
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