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

Minor Account and Sample Submission by Legal Guardian

High severity Medium confidence Explicit document language Unique · 0 of 352 platforms
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Document Record

What it is

The terms permit parents or legal guardians to submit genetic samples on behalf of minors, and legally authorized representatives to submit on behalf of other individuals, as a condition of service eligibility.

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)

This provision authorizes the collection and processing of genetic information from minors through parental or guardian consent, establishing the contractual basis for 23andMe to hold and process a child's genetic data. This mechanism engages both COPPA for online services directed at or knowingly collecting data from minors and state genetic privacy statutes that may impose separate consent or data retention requirements for minors' genetic information.

Interpretive note: The specific data rights, research participation scope, and deletion procedures applicable to minors' genetic data are not fully detailed in the provided document section.

Clause Stability Stable

0
Changes
5
Months Monitored
Jul 9, 2026
First Seen
Jul 9, 2026
Last Seen

Consumer impact (what this means for users)

Under this clause, users who are parents or legal guardians may submit genetic samples on behalf of minors, binding both themselves and the minor to the terms of service including data use and research authorization provisions. The specific data rights and deletion procedures available for minors' genetic data are not detailed in the provided document section.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    Parents or legal guardians managing a minor's account may request deletion of the minor's genetic data and close the associated account through Account Settings or by contacting 23andMe customer support.

Cross-platform context

See how other platforms handle Minor Account and Sample Submission by Legal Guardian and similar clauses.

Compare across platforms →
▸ View Original Clause Language DOCUMENT RECORD
"
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 Terms of Service

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: COPPA applies to the online collection of personal information from children under 13, and may apply to 23andMe's collection of genetic data from minors if the online account creation or results delivery …

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →
  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

Provision details

Document information
Document
23andMe Terms of Service
Entity
23andMe
Document last updated
May 5, 2026
Tracking information
First tracked
May 11, 2026
Last verified
July 9, 2026
Record ID
CA-P-016452
Document ID
CA-D-00147
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
bddb92bc01773d87e5f6157d525fe0a08abb0e48becacc33725f316880d9f25e
Analysis generated
May 11, 2026 23:34 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: 23andMe
Document: 23andMe Terms of Service
Record ID: CA-P-016452
Captured: 2026-05-11 23:34:45 UTC
SHA-256: bddb92bc01773d87…
URL: https://conductatlas.com/platform/23andme/23andme-terms-of-service/provision/CA-P-016452/minor-account-and-sample-submission-by-legal-guardian/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does 23andMe's Minor Account and Sample Submission by Legal Guardian clause do?

This provision authorizes the collection and processing of genetic information from minors through parental or guardian consent, establishing the contractual basis for 23andMe to hold and process a child's genetic data. This mechanism engages both COPPA for online services directed at or knowingly collecting data from minors and state genetic privacy statutes that may impose separate consent or data retention …

How does this clause affect you?

Under this clause, users who are parents or legal guardians may submit genetic samples on behalf of minors, binding both themselves and the minor to the terms of service including data use and research authorization provisions. The specific data rights and deletion procedures available for minors' genetic data are not detailed in the provided document section.

Is ConductAtlas affiliated with 23andMe?

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