23andMe · 23andMe Terms of Service · View original document ↗

Age Restriction and Authorized Representative Requirement

Medium severity Medium confidence Explicitdocumentlanguage Unique · 0 of 325 platforms
Share 𝕏 Share in Share 🔒 PDF
Recent governance activity 23andMe recorded 4 documented changes in the last 30 days.
Start monitoring updates
Monitor governance changes for 23andMe Create a free account to receive the weekly governance digest and monitor one platform for governance changes.
Create free account No credit card required.
Document Record

What it is

Users must be at least 18 to create an account and agree to these terms. Parents or legal guardians may submit samples on behalf of minors, and legally authorized representatives may submit on behalf of other individuals.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

Minors cannot independently consent to genetic testing under these terms; parental or guardian consent is required. This is a significant protection given the lifelong and familial implications of genetic data, though the adequacy of parental consent mechanisms for minors' genetic data varies by jurisdiction.

Interpretive note: The adequacy of parental consent for minor sample submission under the data protection laws of each served jurisdiction is uncertain, particularly where national law imposes additional requirements for processing children's sensitive genetic data.

Recent Activity

This document changed recently

Medium May 5, 2026

The updated Terms now apply only to users who live outside the United States, Canada, EEA, UK, and Switzerland, or who access the Services from outside those regions. US, Canadian, EEA, UK, and Swiss…

High Apr 19, 2026

The updated Terms of Service now apply exclusively to users in the United States, narrowing the geographic scope from the prior version that addressed users in multiple regions. The terms now contain…

Medium Mar 23, 2026

The updated terms now apply only to users who live outside or access services outside the United States, Canada, EEA, UK, and Switzerland. Previously, the terms applied to US-based users. The terms a…

Consumer impact (what this means for users)

If you are a parent submitting a genetic sample for a minor child, you are personally agreeing to all terms on that child's behalf, including any data use and research participation provisions. The child's genetic data may be used under the same terms as adult user data, subject to applicable law.

How other platforms handle this

Meta Medium

Our Products are not directed to children. You must be at least 13 years old to use our Products. If you are under 18, you must have your parent or legal guardian's permission to use our Products and they must read and agree to these Terms on your behalf.

Venmo Medium

To be eligible to use the Venmo services, you must be a resident of the United States and at least 18 years of age. By accepting these terms, you represent and warrant that you meet the eligibility requirements. If you do not meet these requirements, you may not use the Venmo services.

Runway Medium

You may not use Runway's tools to create content that promotes, glorifies, or facilitates acts of terrorism, mass violence, or genocide, or that could be used to provide material support to individuals or organizations engaged in such activities.

See all platforms with this clause type →

Monitoring

23andMe has changed this document before.

Receive same-day alerts, structured change summaries, and monitoring for up to 10 platforms.

Start Watcher free trial Or create a free account →
▸ View Original Clause Language DOCUMENT RECORD
"
You are at least 18 years old; Any sample you provide to 23andMe is either your own, or the sample of a minor for whom you are a parent or legal guardian, or the sample of a person for whom you are a legally authorized representative.

— Excerpt from 23andMe's 23andMe Terms of Service

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision engages COPPA in the US (though the US has a separate version), and equivalent child and minor data protection frameworks in served jurisdictions, including Australia's Privacy Act provisions on children, Singapore's PDPA advisory guidelines on minors, and national implementations of child protection frameworks across served countries. Parental consent for genetic testing of minors is a particularly sensitive area because the data reveals information about the entire biological family, not just the minor. (2) GOVERNANCE EXPOSURE: Medium. The terms permit parental submission of minor samples but do not specify age ranges for minors or any differentiated data handling for children's genetic data. In some jurisdictions, additional protections or consent mechanisms are required for processing children's sensitive personal data, including genetic information. (3) JURISDICTION FLAGS: Australia, New Zealand, and many European-adjacent jurisdictions have heightened standards for processing children's personal data. The terms do not specify a minimum age for minors whose samples may be submitted, which may create ambiguity about the intended scope of this permission and its compliance with national child data protection requirements. (4) CONTRACT AND VENDOR IMPLICATIONS: Any downstream commercialization of de-identified genetic data that includes data from minors submitted by parents may require additional legal basis or consent mechanisms under national child protection frameworks in served jurisdictions. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether the parental consent mechanism for minor sample submission is adequate under the child data protection frameworks of each jurisdiction served by this international version, and whether any additional safeguards or disclosures are required for genetic data derived from minors.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

Track 1 platform — free Try Watcher free for 14 days

Free: track 1 platform + weekly digest. Watcher: 10 platforms + same-day alerts. No credit card required.

Applicable agencies

  • FTC
    The FTC has authority over children's online privacy and data practices under COPPA for US-connected activities, and its guidance on children's data is relevant context for evaluating the adequacy of minor data protections in consumer genetic testing services.
    File a complaint →

Applicable regulations

CFAA
United States Federal

Provision details

Document information
Document
23andMe Terms of Service
Entity
23andMe
Document last updated
May 5, 2026
Tracking information
First tracked
May 9, 2026
Last verified
May 9, 2026
Record ID
CA-P-007406
Document ID
CA-D-00147
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
b70f3e6c5981582ff73b50d36ff70d7261796be2cd43a111b581991c2f7af73e
Analysis generated
May 9, 2026 18:23 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: 23andMe
Document: 23andMe Terms of Service
Record ID: CA-P-007406
Captured: 2026-05-09 18:23:26 UTC
SHA-256: b70f3e6c5981582f…
URL: https://conductatlas.com/platform/23andme/23andme-terms-of-service/age-restriction-and-authorized-representative-requirement/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

Professional Governance Intelligence

Need to monitor specific governance provisions?

Professional includes provision-level monitoring, governance timelines, regulatory mapping, and audit-ready analysis.

Arbitration clauses AI governance Data rights Indemnification Retention policies
Start Professional free trial

Or start with Watcher →

Built from archived source documents, structured governance mappings, and historical version tracking.

Frequently Asked Questions

What does 23andMe's Age Restriction and Authorized Representative Requirement clause do?

Minors cannot independently consent to genetic testing under these terms; parental or guardian consent is required. This is a significant protection given the lifelong and familial implications of genetic data, though the adequacy of parental consent mechanisms for minors' genetic data varies by jurisdiction.

How does this clause affect you?

If you are a parent submitting a genetic sample for a minor child, you are personally agreeing to all terms on that child's behalf, including any data use and research participation provisions. The child's genetic data may be used under the same terms as adult user data, subject to applicable law.

Is ConductAtlas affiliated with 23andMe?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by 23andMe.