Old version
April 19, 2026 06:10 UTC
bb09e7d7a683a2ddccd1f385d3502d4065003b0fac491bebe8a3be3e675aa10f
CA-V-000701
New version
May 1, 2026 06:08 UTC
e1123dbf9ceb71e5f5a07776864b5455c3c3fa3180df8783706cec3bd811c67b
CA-V-002051
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Change Summary
Upwork removed detailed language about its compliance with the U.S. Data Privacy Framework (a legal mechanism for transferring personal data from Europe and Switzerland to the U.S.) but kept a single sentence stating you can request copies of data transfer documents. This means the policy no longer explicitly commits to Data Privacy Framework protections or acknowledges regulatory oversight, which may create uncertainty about how your data is legally protected if you are in the EU, UK, or Switzerland.
high severity
0 Sentences added
19 Sentences removed
2 Sentences modified
3945 Sentences before
3926 Sentences after
Added
Removed
Modified
BeforeAfter
1337Privacy Policy Version 10.2 Effective January 6th 2026 Download Table of Contents This Privacy Policy explains how and why Upwork collects, uses, and shares personal information when you interact with or use our Site or Service.1337Privacy Policy Version 10.3 Effective April 30th 2026 Download Table of Contents This Privacy Policy explains how and why Upwork collects, uses, and shares personal information when you interact with or use our Site or Service.
1541In addition, Upwork Global LLC is self-certified under the U.S. Department of Commerce’s Data Privacy Framework, as described below.1541To exercise any legal right to see copies of the data transfer mechanism documents that Upwork uses to transfer data to third parties, please contact us. 8.
1542Personal information from EU, Swiss, and UK residents will be treated in accordance with the Data Privacy Framework Principles.Removed
1543To exercise any legal right to see copies of the data transfer mechanism documents that Upwork uses to transfer data to third parties, please contact us.Removed
1544Data Privacy Framework Notice Upwork complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.Removed
1545Upwork has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.Removed
1546Upwork has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.Removed
1547If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.Removed
1548To learn more about the DPF Program, and to view our certification, please visit https://www.dataprivacyframework.gov/ .Removed
1549When Upwork receives Personal Information under the DPF and then transfers it to a third party service provider acting as an agent on their behalf, Upwork may have certain responsibilities under the DPF if both (i) the agent processes the information in a manner inconsistent with the DPF and (ii) Upwork or its affiliate is responsible for the event giving rise to the damage.Removed
1550Covered European residents should contact Upwork at the contact information below regarding Upwork’s compliance with the DPF.Removed
1551Upwork will attempt to answer your questions and satisfy your concerns in a timely and complete manner as soon as possible.Removed
1552If, after discussing the matter with Upwork, your issue or complaint is not resolved, Upwork has agreed to participate in the DPF independent dispute resolution mechanisms listed below, free of charge to you.Removed
1553PLEASE CONTACT UPWORK FIRST.Removed
1554For other Personal Information Upwork receives under the DPF, we have committed to refer unresolved privacy complaints under the DPF Principles to an independent dispute resolution mechanism, JAMS Data Privacy Framework Dispute Resolution, operated by JAMS.Removed
1555If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/dpf-dispute-resolution for more information and to file a complaint.Removed
1556If your complaint still is not resolved through these channels, under limited circumstances, an additional binding arbitration option may be available before a DPF panel, as described at https://www.dataprivacyframework.gov/s/ .Removed
1557Every individual also has a right to lodge a complaint with the relevant supervisory authority.Removed
1558The Federal Trade Commission has jurisdiction over Upwork’s compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.Removed
1559In cases of onward transfers to third parties, Upwork has responsibility for the processing of personal information we receive under the DPF Principles and subsequently transfers to a third party acting as an agent on our behalf.Removed
1560To the extent required by the DPF, Upwork shall remain liable under the DPF Principles if our agent processes such personal information in a manner inconsistent with the DPF Principles, unless we are able to prove that we are not responsible for the event giving rise to the damage. 8.Removed
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