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

Research participation is voluntary with IRB consent

Medium severity High confidence Explicitdocumentlanguage Common · 280 of 352 platforms
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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 voluntary nature of research participation and the IRB consent requirement are the two conditions governing whether a user's data may be used for research.

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
Jul 10, 2026
First Seen
Jul 10, 2026
Last Seen
This clause type exists across 3354 other provisions on other platforms.

Consumer impact (what this means for users)

Users are not automatically enrolled in research; participation requires voluntary agreement under an IRB-approved consent process.

How other platforms handle this

Google Cloud Medium

In some cases we will seek your consent to send you marketing communications.

Roblox Medium

Additionally, with your explicit and informed consent, we may use your phone number to recommend you as a friend to others using Roblox. You will be recommended with your contact name as stored on your ...

Paramount+ Medium

By clicking the submit button, you agree to Paramount+ using your email address to send you marketing communications, updates, special offers and other information about Paramount+.

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▸ View Original Clause Language DOCUMENT RECORD
"
Participation in such research is voluntary and based upon an Institutional Review Board-approved consent document.

— Excerpt from 23andMe's 23andMe Terms of Service

Applicable regulations

BIPA
Illinois, USA
CCPA/CPRA
California, USA
CAN-SPAM
United States Federal
ePrivacy Directive
European Union
FTC Act Section 5
United States Federal
GDPR
European Union
HIPAA
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 11, 2026
Last verified
July 9, 2026
Record ID
CA-P-027195
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-027195
Captured: 2026-05-11 23:34:45 UTC
SHA-256: bddb92bc01773d87…
URL: https://conductatlas.com/platform/23andme/23andme-terms-of-service/provision/CA-P-027195/research-participation-is-voluntary-with-irb-consent/
Accessed: July 13, 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 Research participation is voluntary with IRB consent clause do?

The voluntary nature of research participation and the IRB consent requirement are the two conditions governing whether a user's data may be used for research.

How does this clause affect you?

Users are not automatically enrolled in research; participation requires voluntary agreement under an IRB-approved consent process.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 280 platforms. See the full comparison.

Is ConductAtlas affiliated with 23andMe?

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