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

Third-Party Data Sharing for Advertising

High severity Medium confidence Inferred from context Common · 288 of 352 platforms
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Document Record

What it is

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

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.

Recent Activity

This document changed recently

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.

View change record →
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.

View change record →
Medium Apr 19, 2026

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 →

Clause Stability Stable

0
Changes
4
Months Monitored
May 10, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 4430 other provisions on other platforms.

Consumer impact (what this means for users)

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.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Opt Out of Arbitration
    Visit Upwork's privacy settings page and use the cookie preference center to opt out of behavioral advertising cookies. California residents should look for the 'Do Not Sell or Share My Personal Information' link in the site footer.

How other platforms handle this

Skillshare Medium

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

Squarespace Medium

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.

Google Gemini Medium

Third-party apps use data from Gemini consistent with their own privacy policies and terms.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
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

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

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.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →
  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

Applicable regulations

CCPA/CPRA
California, USA
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
May 10, 2026
Last verified
May 10, 2026
Record ID
CA-P-009823
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-009823
Captured: 2026-05-10 23:05:47 UTC
SHA-256: ef83ddf58f654cc8…
URL: https://conductatlas.com/platform/upwork/upwork-privacy-policy/provision/CA-P-009823/third-party-data-sharing-for-advertising/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Upwork's Third-Party Data Sharing for Advertising clause do?

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.

How does this clause affect you?

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 many platforms have this type of clause?

ConductAtlas has identified this type of provision across 288 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.