Upwork · Upwork Privacy Policy · View original document ↗

Merger and Acquisition Data Transfer

Medium severity Rare · 1 of 325 platforms
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Recent governance activity Upwork recorded 2 documented changes in the last 30 days.
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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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

A new company acquiring Upwork could have very different privacy practices, and you would have limited ability to prevent your sensitive data from being transferred to and used by that new entity.

Recent Activity

This document changed recently

High May 1, 2026

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 …

Consumer impact (what this means for users)

Upwork collects a wide range of personal data including financial information, platform communications, work history, and device and usage data, and the policy authorizes sharing this information with other platform users, advertising partners, and third-party vendors. Users should be aware that profile information including work history and feedback may be visible to other platform participants, and that behavioral advertising cookies are used to track activity across the web. You can adjust your cookie preferences and submit data access or deletion requests through Upwork's privacy settings or by contacting privacy@upwork.com.

How other platforms handle this

Medium Medium

If Medium is involved in a merger, acquisition, or sale of all or a portion of its assets, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well a...

Perplexity AI Medium

In the event of a merger, acquisition, reorganization, bankruptcy, or other sale of all or a portion of our assets, your personal information may be transferred to the acquiring entity or successor as part of that transaction. We will notify you of any such change in ownership or control of your per...

Substack Medium

We may share and/or transfer customer information in connection with the sale or merger of our business or assets (subject to local laws). Also, if we go out of business, enter bankruptcy, or go through some other change of control.

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▸ View Original Clause Language DOCUMENT RECORD
"
We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. In such transactions, user information generally is one of the transferred business assets.

— Excerpt from Upwork's Upwork Privacy Policy

Applicable regulations

CCPA/CPRA
California, USA
GDPR
European Union

Provision details

Document information
Document
Upwork Privacy Policy
Entity
Upwork
Document last updated
May 5, 2026
Tracking information
First tracked
May 10, 2026
Last verified
May 10, 2026
Record ID
CA-P-006526
Document ID
CA-D-00142
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
ef83ddf58f654cc82f83982d55b3609f4bcd07d93da04e1f8cd0b3188ea88c71
Analysis generated
May 10, 2026 23:05 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Upwork
Document: Upwork Privacy Policy
Record ID: CA-P-006526
Captured: 2026-05-10 23:05:47 UTC
SHA-256: ef83ddf58f654cc8…
URL: https://conductatlas.com/platform/upwork/upwork-privacy-policy/merger-and-acquisition-data-transfer/
Accessed: May 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 Upwork's Merger and Acquisition Data Transfer clause do?

A new company acquiring Upwork could have very different privacy practices, and you would have limited ability to prevent your sensitive data from being transferred to and used by that new entity.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 1 platforms. See the full comparison.

Is ConductAtlas affiliated with Upwork?

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