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The agreement establishes that users consent to Upwork publishing individual and composite feedback about them, including job success scores and user ratings, to other users and the public, and that Upwork reserves the right to remove feedback that violates its terms or is inconsistent with its business interests.
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 authorizes Upwork to aggregate and publish reputational data about individual users, including composite scores derived from multiple user interactions, and reserves Upwork's discretion to remove feedback based on its own business interests assessment, which is an operational factor affecting how freelancer and client reputations are managed on the platform.
The updated terms establish that when clients fund, release, or pay bonuses for multiple milestones in a single transaction session (a 'Bulk Payment Action'), each transaction is treated as a separate, independent, and irrevocable authorization to Payment Escrow. The revised language explicitly states that each transaction receives its own unique transaction identifier, is independently recorded in transaction history, is subject to its own service fees, and is independently subject to dispute assistance rights. Clients must review and confirm all individual transactions before submitting a bulk action. Additionally, the updated Fee and ACH Authorization Agreement states that unused ACH payment methods will be inactivated after 24 months of non-use, with advance notification provided.
View change record →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 →Under this clause, users grant Upwork authorization to publish composite feedback, job success scores, and reputational data about them to other users, and Upwork retains discretion to remove feedback it determines negatively affects its marketplace, which may affect a freelancer's or client's profile visibility and profile score.
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"You acknowledge and agree that Users publish and request Upwork to publish on their behalf information on the Site such as feedback, composite feedback, or geographical location. Such information is based on data that Freelancers or Clients voluntarily submit to Upwork and does not constitute an introduction, endorsement, or recommendation by Upwork. You acknowledge and agree that User feedback benefits the marketplace and its Users, and you specifically request and agree that Upwork may make available to other Users individual and composite feedback about Users, including you.Excerpt from Upwork's Privacy Policy
(1) REGULATORY LANDSCAPE: Publication of reputational and composite scoring data about individuals engages GDPR provisions on profiling and automated decision-making for EU users, particularly where composite scores may influence hiring or contracting decisions; CCPA and CPRA rights to access and correct personal information apply to California residents whose feedback data is processed. (2) GOVERNANCE EXPOSURE: Medium. The broad discretion reserved by Upwork to remove feedback based on business interests, without a detailed procedural framework, may create disputes with users whose feedback is removed and may engage platform accountability discussions under the EU Digital Services Act for EU-accessible platforms. (3) JURISDICTION FLAGS: EU users may have GDPR Article 22 rights regarding automated decision-making if composite scores are used to make consequential decisions about profile visibility or contract eligibility; California users have CCPA rights to access and in some cases correct personal information including composite scoring data. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise clients should assess whether the prohibition on using composite information for employment, credit, or underwriting decisions is operationally integrated into their talent evaluation workflows, as the agreement explicitly states users agree not to use this data for such decisions. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should evaluate whether Upwork's composite scoring methodology constitutes profiling under GDPR and whether users are provided adequate transparency regarding how composite scores are calculated and how they may be corrected if inaccurate.
This provision authorizes Upwork to aggregate and publish reputational data about individual users, including composite scores derived from multiple user interactions, and reserves Upwork's discretion to remove feedback based on its own business interests assessment, which is an operational factor affecting how freelancer and client reputations are managed on the platform.
Under this clause, users grant Upwork authorization to publish composite feedback, job success scores, and reputational data about them to other users, and Upwork retains discretion to remove feedback it determines negatively affects its marketplace, which may affect a freelancer's or client's profile visibility and profile score.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Upwork.