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.
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 …
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
We may share your information with third-party advertising partners to provide you with targeted advertising. We also work with third-party analytics providers who help us understand how users interact with our Services. These third parties may use cookies, web beacons, and similar tracking technolo...
We work with third-party advertising partners to market our Products, and we share personal data with advertising networks and social media companies to serve ads. We also use analytics providers to help us understand how users interact with our Products.
We may share your personal information with third-party vendors and service providers that perform services on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. We may also share your personal information with busines...
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"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 Upwork 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. GDPR Articles 6 and 7 require a lawful basis and, for behavioral advertising, typically require freely given, specific, and informed consent. The ePrivacy Directive governs cookie-based tracking used to enable third-party advertising. The FTC Act applies to deceptive or unfair data sharing practices. GOVERNANCE EXPOSURE: High. Sharing personal data with advertising partners for behavioral targeting is one of the most actively scrutinized data practices under both GDPR and CCPA/CPRA. Regulators in the EU have issued significant enforcement actions related to consent mechanisms for advertising cookies. California's CPRA expanded opt-out rights to cover sharing (not just sale), which means Upwork must provide a clear opt-out mechanism for California users. JURISDICTION FLAGS: EU/EEA users must be offered a genuine consent choice for behavioral advertising cookies under GDPR and the ePrivacy Directive. California residents have a statutory opt-out right. UK GDPR mirrors GDPR requirements in this area. Users in jurisdictions without comprehensive privacy law have fewer enforceable protections but may still benefit from Upwork's stated global privacy commitments. CONTRACT AND VENDOR IMPLICATIONS: Procurement teams should confirm that Upwork's advertising technology vendors are listed as subprocessors in any applicable DPA, and that data sharing with those vendors is governed by appropriate contractual terms. The use of de-identified or aggregated data for advertising should be assessed against re-identification risk standards. COMPLIANCE CONSIDERATIONS: Compliance teams should audit the consent mechanism presented to users for behavioral advertising cookies and confirm it meets GDPR Article 7 standards including the ability to withdraw consent as easily as it is given. A Do Not Sell or Share My Personal Information link should be verified as present and functional for California users.
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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 7 platforms. See the full comparison.
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