Provision record
Upwork · Upwork Privacy Policy · View original document ↗

California Right to Opt-Out of Sale or Sharing

Medium severity Explicitdocumentlanguage Common · 295 of 352 platforms
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Recent governance activity Upwork recorded 8 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

Recent Activity

This document changed recently

Medium Jul 21, 2026

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.

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Medium Jul 1, 2026

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.

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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 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.

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Clause Stability Stable

0
Changes
3
Months Monitored
Jul 10, 2026
First Seen
Jul 10, 2026
Last Seen
This clause type exists across 5260 other provisions on other platforms.

How other platforms handle this

Skillshare Medium

The right to know with whom we have shared your Personal Data, for what purposes, and what Personal Data has been shared (including whether Personal Data was disclosed to third parties for their own direct marketing purposes)

Discord Medium

We may use your information to let you know about new products or features we think you'll like...You may opt-out of receiving such marketing communications.

Baseten Medium

The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.

See all platforms with this clause type →

Monitoring

Upwork has changed this document before.

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▸ View Original Clause Language DOCUMENT RECORD
"
California residents have the right to opt-out of the "sale" or "sharing" of their personal information as defined by the CCPA. Where we are "sharing" your personal information with third parties for the purposes of cross-context behavioral advertising...

Excerpt from Upwork's Privacy Policy

Applicable regulations

CCPA/CPRA
California, USA
Colorado AI Act
US-CO
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US
VPPA
United States Federal

Provision details

Document information
Document
Upwork Privacy Policy
Entity
Upwork
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-027022
Document ID
CA-D-00142
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
a8317ef805233afd22c54b506ede241c26f34e99dfe8e9b9bde9646a3a54833d
Analysis generated
July 9, 2026 06:28 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Upwork
Document: Upwork Privacy Policy
Record ID: CA-P-027022
Captured: 2026-07-09 06:28:32 UTC
SHA-256: a8317ef805233afd…
URL: https://conductatlas.com/platform/upwork/upwork-privacy-policy/provision/CA-P-027022/california-right-to-opt-out-of-sale-or-sharing/
Accessed: July 25, 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 California Right to Opt-Out of Sale or Sharing clause do?

The clause states: “California residents have the right to opt-out of the "sale" or "sharing" of their personal information as defined by the CCPA. Where we are "sharing" your personal information with third parties for the purposes of cross-context behavioral advertising...”

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 295 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.