Upwork's platform is for adults only and the company states it does not knowingly collect data from anyone under 18. If a child's data is found, Upwork says it will delete it.
This analysis describes what Upwork'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 establishes that Upwork relies on user self-certification of age rather than active age verification, which may leave a compliance gap under COPPA for younger teenagers if minors access the platform.
Interpretive note: The exact verbatim text could not be confirmed from the truncated document. The adequacy of Upwork's age verification mechanism is not described in the policy and is a practical compliance question distinct from the policy assertion.
The updated terms establish a new beta feature allowing invited users to connect third-party AI agents to their Upwork accounts. Agents can read information and draft communications (proposals, job posts, messages) without per-action confirmation, but cannot autonomously move money or finalize contracts; those actions require the user to authenticate and confirm on Upwork directly. Users are responsible for all agent actions and must ensure agent-generated content carries mandatory disclosure labels; submitting proposals through agents consumes Connects and incurs fees regardless of whether the user approves the draft-confirm action. You can revoke agent access by visiting the App Authorization page, and these beta terms apply only until you accept replacement terms.
View change record →Upwork's privacy policy previously disclosed that it complied with the U.S. Data Privacy Framework and certified adherence to its Principles regarding how it processes personal data from EU, UK, and Swiss residents. The updated policy removes nearly all of this language, including the explicit commitment to Data Privacy Framework Principles and the statement that those Principles would govern in case of conflict with other policy terms. Users in the EU, UK, and Switzerland no longer have a clear, policy-level statement of the legal framework protecting their data when transferred to the U.S., which may reduce transparency about data protection safeguards. You may contact Upwork to request copies of the data transfer mechanism documents it uses.
View change record →The updated policy now explicitly states that Upwork complies with the U.S. Data Privacy Framework and has certified to the U.S. Department of Commerce that it adheres to DPF principles when processing personal data from EU, UK, and Swiss residents. The policy establishes that if any conflict exists between Upwork's privacy policy and DPF principles, the DPF principles will govern. This creates an explicit legal hierarchy for data protection standards applicable to residents of those jurisdictions. Users from affected regions can visit https://www.dataprivacyframework.gov/ to view Upwork's certification and learn more about the DPF program.
View change record →If you are under 18 or are a parent of a minor who may have created an Upwork account, you should know that Upwork's services are not intended for minors and any such accounts should be reported to Upwork for deletion. Parents can contact privacy@upwork.com to request deletion of a minor's data.
How other platforms handle this
to request that your data be transferred to a third party (data portability)
Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.
Further, you may take legal actions in relation to any potential breach of your rights regarding the processing of your Personal Information, as well as to lodge complaints before the competent data prot...
"Our services are not directed to individuals who are under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that a child under 18 has provided us with personal information, we will take steps to delete such information.Excerpt from Upwork's Privacy Policy
REGULATORY LANDSCAPE: The Children's Online Privacy Protection Act (COPPA) in the US applies to operators of websites directed to children under 13 and requires verifiable parental consent before collecting personal information from children.
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This provision establishes that Upwork relies on user self-certification of age rather than active age verification, which may leave a compliance gap under COPPA for younger teenagers if minors access the platform.
If you are under 18 or are a parent of a minor who may have created an Upwork account, you should know that Upwork's services are not intended for minors and any such accounts should be reported to Upwork for deletion. Parents can contact privacy@upwork.com to request deletion of a minor's data.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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