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 the company's operational policy regarding collection of data from minors and defines the remediation process when such collection occurs. It reflects compliance with children's privacy regulations that require parental consent before collecting data from users under 18.
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 →Users under 18 are not authorized to use the Services under these terms. If a user under 18 provides personal information, Upwork states it will take steps to remove that information upon becoming aware of it, and it solicits notification from others who become aware of such submissions.
How other platforms handle this
Our Services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13 without verifiable parental consent, we will take steps to delete such info...
Our services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13, we will take steps to delete that information. Users between the ages of 1...
Our Services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If we become aware that a child under 13 has provided us with personal information, we will take steps to delete such information.
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"Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18. If you become aware that a child has provided us with personal information, please contact us. If we become aware that we have collected personal information from children without verification of parental consent, we take steps to remove that information from our servers.— Excerpt from Upwork's Upwork Privacy Policy
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This provision establishes the company's operational policy regarding collection of data from minors and defines the remediation process when such collection occurs. It reflects compliance with children's privacy regulations that require parental consent before collecting data from users under 18.
Users under 18 are not authorized to use the Services under these terms. If a user under 18 provides personal information, Upwork states it will take steps to remove that information upon becoming aware of it, and it solicits notification from others who become aware of such submissions.
ConductAtlas has identified this type of provision across 10 platforms. See the full comparison.
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