23andMe can use a de-identified version of your genetic data to develop new products and services, including sharing it with third-party commercial partners. The terms describe this research participation as voluntary and subject to a separate consent document.
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
The provision establishes the scope and permissible uses of de-identified data for internal product development and potential third-party commercialization activities. By specifying that such activities operate under voluntary participation with IRB oversight, the clause delineates the regulatory framework governing 23andMe's research operations on de-identified genetic and health information.
Interpretive note: The scope of 'de-identified' is not defined in the excerpted document text, and whether the de-identification standard applied satisfies the requirements of each served jurisdiction is uncertain and may require jurisdiction-specific legal analysis.
Under these terms, your de-identified genetic information may be used in commercial activities with outside companies as part of 23andMe's product development program. Because this participation is described as voluntary and consent-based, reviewing and understanding your research consent options before submitting a sample is the most important action you can take.
How other platforms handle this
Developing new products and services and improving the Services
If we de-identify information, we will maintain and use the information in de-identified form and not attempt to re-identify the information except as required or permitted by law.
combination of Service Data with information from other Google products and services. We also use Service Data for internal reporting and analysis of applicable product and business operations.
"When we use the term "Product Development", it means research performed for the purpose of new product development and new product development activities performed by 23andMe on De-identified Information. These activities may include, among other things, improving our Services and/or offering new products or services to you; performing quality control activities; conducting data analysis that may lead to and/or include commercialization with a third party. Participation in such research is voluntary and based upon an Institutional Review Board-approved consent document.Excerpt from 23andMe's Terms of Service
(1) REGULATORY LANDSCAPE: This provision implicates data protection frameworks governing genetic data as a special category, including the GDPR for EEA users (though this document applies to non-EEA users, downstream data flows may still be …
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
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The provision establishes the scope and permissible uses of de-identified data for internal product development and potential third-party commercialization activities. By specifying that such activities operate under voluntary participation with IRB oversight, the clause delineates the regulatory framework governing 23andMe's research operations on de-identified genetic and health information.
Under these terms, your de-identified genetic information may be used in commercial activities with outside companies as part of 23andMe's product development program. Because this participation is described as voluntary and consent-based, reviewing and understanding your research consent options before submitting a sample is the most important action you can take.
ConductAtlas has identified this type of provision across 279 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by 23andMe.