You must be at least 18 years old to create an account, though parents or legal guardians may submit samples on behalf of minors.
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 provision establishes 18 as the minimum age for account creation while creating a parental consent pathway for minors, which has implications for how genetic data of children is collected and processed under applicable privacy laws.
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…
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…
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…
The Terms permit genetic sample collection from minors only when a parent or legal guardian registers and submits the sample, meaning the parent's account and consent govern the minor's genetic data processing under these Terms.
How other platforms handle this
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.
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.
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.
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"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
REGULATORY LANDSCAPE: The collection of genetic data from minors implicates COPPA for users under 13, as well as state children's privacy laws including the California Age-Appropriate Design Code. The parental consent mechanism described in the Terms, where a parent registers their own account and submits a minor's sample, should be evaluated against COPPA's specific consent requirements. The FTC enforces COPPA and has taken enforcement action against companies that collect children's data without compliant parental consent. GOVERNANCE EXPOSURE: High. Genetic data is among the most sensitive categories of personal information, and collection from minors under a parent-mediated consent structure requires careful implementation of consent mechanisms, data retention limits, and access controls specific to minors' data. The adequacy of the consent structure for minors' genetic data should be evaluated against COPPA, CCPA's children's data provisions, and applicable state genetic privacy laws. JURISDICTION FLAGS: California's CCPA imposes specific obligations for data of consumers under 16. Illinois' BIPA covers biometric identifiers, and whether genetic data qualifies under BIPA is a developing legal question. States with genetic privacy statutes may impose additional consent requirements for minor genetic data collection beyond what the Terms describe. CONTRACT AND VENDOR IMPLICATIONS: Laboratory partners processing samples from minors should confirm that their data handling practices are consistent with the heightened obligations applicable to children's data under federal and state law. Any third-party research participation involving minor samples requires additional consent review. COMPLIANCE CONSIDERATIONS: Compliance teams should audit the consent flow for minor sample submission to confirm it meets COPPA requirements, including verifiable parental consent mechanisms. Data mapping should separately categorize minor genetic data to ensure appropriate retention, access, and deletion controls are applied.
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This provision establishes 18 as the minimum age for account creation while creating a parental consent pathway for minors, which has implications for how genetic data of children is collected and processed under applicable privacy laws.
The Terms permit genetic sample collection from minors only when a parent or legal guardian registers and submits the sample, meaning the parent's account and consent govern the minor's genetic data processing under these Terms.
ConductAtlas has identified this type of provision across 1 platforms. See the full comparison.
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