Upwork shares your personal information with outside companies that help run its business, including advertisers and analytics providers, and may share aggregated data that is not directly tied to your identity.
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
Sharing personal data with advertising and analytics partners means your usage patterns and profile information may be used to build advertising profiles about you, which extends the use of your data beyond the core purpose of the freelance marketplace.
Interpretive note: The document was truncated and the precise verbatim advertising data sharing language could not be confirmed; this provision reflects standard Upwork policy language. The enforceability of consent mechanisms depends on jurisdiction-specific regulatory interpretation.
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 →Your platform activity, device identifiers, and usage data may be shared with third-party advertising partners, meaning your behavior on Upwork could influence the ads you see across the web. California residents have the right to opt out of the sale or sharing of personal information for cross-context behavioral advertising.
How other platforms handle this
Protect us, our business, our users, and others, for example to enforce our terms of service, prevent spam or other unwanted communications, and investigate or protect against fraud
we may use, retain or share information with law enforcement or others in circumstances where a person's vital interests require protection, such as in the case of emergencies.
Third-party apps use data from Gemini consistent with their own privacy policies and terms.
"We may share your information with third-party vendors, consultants, and other service providers who need access to such information to carry out work on our behalf. We may also share or disclose your information with your consent, for example, if you use a third-party application to access your account. We may share aggregated or de-identified information, which cannot reasonably be used to identify you.Excerpt from Upwork's Privacy Policy
REGULATORY LANDSCAPE: CCPA/CPRA Section 1798.120 grants California residents the right to opt out of the sale or sharing of personal information, including sharing for cross-context behavioral advertising.
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ConductAtlas detected a major restructuring of Meta’s privacy policy that removed detailed consumer rights disclosures and relocated them to separate documents.
Your genetic data may be transferred to a new owner as a business asset. Here is what the Terms of Service actually say and what you can do right now.
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Sharing personal data with advertising and analytics partners means your usage patterns and profile information may be used to build advertising profiles about you, which extends the use of your data beyond the core purpose of the freelance marketplace.
Your platform activity, device identifiers, and usage data may be shared with third-party advertising partners, meaning your behavior on Upwork could influence the ads you see across the web. California residents have the right to opt out of the sale or sharing of personal information for cross-context behavioral advertising.
ConductAtlas has identified this type of provision across 288 platforms. See the full comparison.
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