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

Age Restriction and Authorized Representative Requirement

Medium severity Medium confidence Explicitdocumentlanguage Unique · 0 of 343 platforms
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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)

The clause establishes gatekeeping requirements for service access and sample processing. It allocates responsibility for legal authorization to the account holder and creates a contractual condition that sample submission constitutes representation of authority to provide that particular genetic material to 23andMe.

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 users are directed to region-specific Terms instead. Additionally, when terms for a specific Service conflict with the main Terms, the specific Service terms now govern that portion of your use rather than the main Terms controlling. The mandatory arbitration provision remains in the document but is no longer prominently featured at the very beginning of the Terms.

View change record →
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 a prominently featured mandatory arbitration provision that requires disputes to be resolved through individual arbitration on an individual basis rather than through jury trials or class action lawsuits. This means that if a user has a dispute with 23andMe, the updated terms require arbitration as the method of resolution instead of traditional litigation. Additionally, if a user purchases additional services, the main Terms of Service (including the arbitration provision) will control any conflicting terms from those additional services. You can review the complete updated Terms of Service through the link provided in the document.

View change record →
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 also clarify that when service-specific terms conflict with the general Terms of Service, the service-specific terms will govern that particular service rather than the general terms controlling all conflicts. This means users of additional services may operate under different dispute resolution and governance procedures depending on which service they are using.

View change record →

Clause Stability Stable

0
Changes
3
Months Monitored
May 9, 2026
First Seen
May 11, 2026
Last Seen
This clause type exists across 560 other provisions on other platforms.

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

The Meta Products are not directed to children. Access to or use of Meta Products by anyone under the age of 13 is not allowed. If you are based in the EU, you must be at least 16 years old, or the minimum age in your country if it is higher than 16, to use or access Meta Products, unless your count...

PayPal Medium

Activities involving gambling, gaming and/or any other activity with an entry fee and a prize, including, but not limited to property/real estate prizes, casino games, sports betting, horse or greyhound racing, fantasy sports, lottery tickets, other ventures that facilitate gambling, games of skill ...

Mailchimp Medium

You must process unsubscribe requests within 10 business days, and the unsubscribe mechanism must remain operational for at least 30 days following the campaign send.

See all platforms with this clause type →

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▸ 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.

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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: July 1, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

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

The clause establishes gatekeeping requirements for service access and sample processing. It allocates responsibility for legal authorization to the account holder and creates a contractual condition that sample submission constitutes representation of authority to provide that particular genetic material to 23andMe.

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.