The terms define Product Development as research and development activities using de-identified genetic information, which may include commercialization with third parties. The document states participation is voluntary and governed by a separate IRB-approved 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
This provision authorizes 23andMe to use de-identified genetic information derived from user samples for activities that may include commercial arrangements with third parties. The boundary between the base Terms consent and the separate IRB-approved research consent document requires careful evaluation, particularly given that genetic data presents re-identification risks that may affect the adequacy of de-identification under applicable law.
Interpretive note: The adequacy of de-identification under applicable legal standards and the precise scope of the IRB-approved consent document governing research participation are not fully determinable from the provided document text alone.
Under this clause, 23andMe may use de-identified versions of users' genetic information for Product Development activities, which the agreement states may include commercialization with third parties. Participation is described as voluntary and subject to a separate IRB-approved consent process, which users would need to review to understand the specific scope and withdrawal options.
Cross-platform context
See how other platforms handle Product Development and Third-Party Commercialization of De-Identified Genetic Data and similar clauses.
Compare across platforms →"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; or 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 engages CCPA and California's Genetic Information Privacy Act given 23andMe's California operations and the use of genetic data.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
Get the research letter
Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean.
This provision authorizes 23andMe to use de-identified genetic information derived from user samples for activities that may include commercial arrangements with third parties. The boundary between the base Terms consent and the separate IRB-approved research consent document requires careful evaluation, particularly given that genetic data presents re-identification risks that may affect the adequacy of de-identification under applicable law.
Under this clause, 23andMe may use de-identified versions of users' genetic information for Product Development activities, which the agreement states may include commercialization with third parties. Participation is described as voluntary and subject to a separate IRB-approved consent process, which users would need to review to understand the specific scope and withdrawal options.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by 23andMe.