Upwork and its advertising partners use cookies and similar trackers to monitor how you use the platform and across the web, including for targeted advertising.
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
Behavioral tracking technologies can build detailed profiles of your online activity, and the data collected may be shared with advertising partners. Users in the EU have a legal right to consent to or reject non-essential cookies.
Interpretive note: The exact verbatim text could not be confirmed from the truncated document. The actual configuration and compliance of Upwork's consent management platform cannot be assessed from the policy text alone.
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 …
Upwork uses cookies and third-party tracking tools that monitor your browsing behavior both on and potentially off the Upwork platform for advertising and analytics purposes. EU users must be given a genuine choice to accept or reject these cookies, and you can update your preferences through Upwork's cookie settings.
How other platforms handle this
We use cookies and similar tracking technologies to track the activity on our Services and store certain information. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Services. You can instruct your browser to refuse all c...
We and our third-party partners may use cookies, web beacons, and other tracking technologies to collect information about your use of our Services, including your browser type, pages viewed, links clicked, and the date and time of your visit.
We use cookies, web beacons, pixel tags, and similar tracking technologies to collect information about your interactions with our website and services. This includes information about the pages you visit, links you click, and how you navigate our site. We use this information for analytics, persona...
Monitoring
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"We and our third-party partners may use cookies, web beacons, and other tracking technologies on our platform to collect information about your browsing activities, device, and usage of our services for purposes including analytics, advertising, and personalization.— Excerpt from Upwork's Upwork Privacy Policy
REGULATORY LANDSCAPE: The ePrivacy Directive (EU Cookie Directive) and GDPR together require that non-essential cookies be set only with the user's prior, freely given, specific, and informed consent. The UK's PECR implements equivalent requirements for UK users. The FTC has issued guidance on online tracking and behavioral advertising, and the California Consumer Privacy Act/CPRA includes provisions on the sale and sharing of personal information collected through tracking technologies. The Global Privacy Control signal must be honored for California users as an opt-out mechanism under CPRA. GOVERNANCE EXPOSURE: High. Cookie consent compliance is one of the most actively enforced areas of EU data protection law. Consent management platforms must be configured to ensure that tracking cookies are not loaded prior to user consent and that the consent interface does not use dark patterns. Failure to comply has resulted in significant fines from EU data protection authorities. JURISDICTION FLAGS: EU/EEA users have the strongest protections and must be offered a genuine reject-all option equivalent in prominence to the accept option. California users are protected by CPRA's opt-out provisions for sharing personal information through tracking technologies. Users in other US states with comprehensive privacy laws (Colorado, Virginia, Connecticut) have similar opt-out rights. UK users are covered by PECR. CONTRACT AND VENDOR IMPLICATIONS: Enterprise clients should assess whether Upwork's use of advertising cookies on pages where enterprise users interact with the platform is consistent with the enterprise's own data protection obligations. If enterprise users access Upwork through a corporate environment, the enterprise may have independent obligations regarding cookie consent. COMPLIANCE CONSIDERATIONS: The consent management platform used by Upwork should be audited to confirm that: (1) consent is obtained before non-essential cookies are set; (2) withdrawal of consent is as easy as giving it; (3) the Global Privacy Control signal is honored for California users; and (4) the list of third-party cookie partners is current and disclosed.
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Behavioral tracking technologies can build detailed profiles of your online activity, and the data collected may be shared with advertising partners. Users in the EU have a legal right to consent to or reject non-essential cookies.
Upwork uses cookies and third-party tracking tools that monitor your browsing behavior both on and potentially off the Upwork platform for advertising and analytics purposes. EU users must be given a genuine choice to accept or reject these cookies, and you can update your preferences through Upwork's cookie settings.
ConductAtlas has identified this type of provision across 70 platforms. See the full comparison.
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