This Privacy Policy explains how and why Upwork collects, uses, and shares personal information when

you interact with

or use our Site or Service. It also includes any information Upwork collects offline in connection with the Service, which we
may combine with information from the Site and Service.

When we say “Upwork”, we mean Upwork Global Inc., and any of its affiliates, including Upwork Payments, Inc. When we
say “Site”, we mean www.upwork.com, and when we say “Service”, we mean the Site plus any websites, features,
applications, widgets, or online services owned or controlled by Upwork.

As part of the Service, Upwork provides a marketplace which results in platform information pertaining to different parties
to an interaction. Users of the Service may be Clients, Freelancers, Agencies, or Site Visitors (as each is defined in the
User Agreement). This Privacy Policy applies to Upwork’s processing of personal information of Users where Upwork
determines the purposes and means of processing. It does not apply to processing of information by Users themselves,
who may be controllers of the personal information they access through the Service. For information about how Users
process your personal information, please contact them directly.

Accessibility: This Privacy Policy uses industry-standard technologies and was developed in connection with the World
Wide Web Consortium's Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so
from your web browser or by saving the page as a PDF.

TABLE OF CONTENTS
1. INFORMATION COLLECTION

2. USE OF INFORMATION

3. DATA RETENTION

4. INFORMATION SHARING AND DISCLOSURE

5. YOUR CHOICES AND RIGHTS

6. SECURITY

7. CROSS-BORDER DATA TRANSFERS

8. LINKS TO OTHER SITES

9. CHANGES TO THIS POLICY

10. CONTACT US

1. INFORMATION COLLECTION
a. Information You Provide to Us
When you use the Service, you may provide us with information about you. This may include your name and contact
information, financial information to make or receive payment for services obtained through the Upwork platform, or
information to help us fill out tax forms. When you use the Service, we may also collect information related to your use of
the Service and aggregate this with information about other users. This helps us improve our Services for you. You may
also provide us with information about your contacts or friends if, for example, you’d like to add those contacts to a
message room. Agencies may also provide us with information about Freelancers associated with the Agency.

Depending upon our relationship with you, we may collect the following categories and types of personal information from
and about you:

Categories of Examples of Personal Categories of Sources of Business Purpose for

Personal Information Collected Personal Information Collection of Personal
Information We Information
Collect

Identifiers Name, Date of Birth, Social Directly from You or Your use Developing, Improving,
Media Account Information, of the Service; Cookies and and Providing the Service,
Profile Data, IP Address Other Tracking Technologies; Identification,
Third Parties (such as Communications,
affiliates, agents, service Marketing, Analytics,
providers and other users) Security, Legal,
Compliance and
Regulatory Obligations.

Contact / Email Address, Home Directly from You or Your use Developing, Improving,
Account Profile Address, Billing Address, of the Service; Third Parties and Providing the Service,
Information Phone Number (such as affiliates, agents, Identification,
service providers and other Communicating with You,
users) Marketing, Analytics,
Security, Legal,
Compliance and
Regulatory Obligations.

Sensitive Social Security Number, Directly from You Improving and Providing
Personal Driver’s License, State the Service, Verifying Your
Information / Identification or Passport Identity and Detecting
Government Number, VAT Identification Fraud, Identity Theft, or
Issued Number, Tax Identification Other Misuse of Your
Identification Number, Immigration Status, Account, Legal,
Numbers Citizenship Information Compliance and
Regulatory Obligations.

Commercial Transaction Data including Directly from You or Your use Developing, Improving,
Information services offered, of the Service; Third Parties and Providing the Service,
considered, or purchased (such as affiliates, agents, Identification,
service providers and other Communications,
users) Marketing, Analytics,
Security, Legal,
 Compliance and
Regulatory Obligations.

Financial Credit card or other financial Directly from You or Your use Improving and Providing
Data/Payment account information of the Service; Third Parties the Service, Identification,
Information (such as affiliates, agents, Communications, Security,
service providers and other Legal, Compliance and
users) Regulatory Obligations.

Internet or Other Unique device and app Directly from You or Your use Developing, Improving,
Network or identifiers, browsing history of the Service; Cookies and and Providing the Service,
Device Activities or other usage data, the Other Tracking Technologies; Identification,
Including browser and operating Third Parties (such as Communications,
Information from system you are using, the affiliates, agents, service Marketing, Analytics,
Cookies URL or advertisement that providers and other users) Security, Legal,
referred you to the Service, Compliance and
the search terms you Regulatory Obligations.
entered into a search engine
that led you to the Service,
areas within the Service that
you visited, which links you
clicked on, which pages or
content you viewed and for
how long, other similar
information and statistics
about your interactions,
such as content response
times, download errors and
length of visits to certain
pages and other information
commonly shared when
browsers communicate with
websites

Approximate Your approximate location Directly from You or Your use Developing, Improving,
Geolocation of the Service; Cookies and and Providing the Service,
Information Other Tracking Technologies; Identification,
Third Parties (such as Communications,
affiliates, agents, service Marketing, Analytics,
providers and other users) Security, Legal,
Compliance and
Regulatory Obligations.

Sensory Audio recordings if you call Directly from You or Your use Providing and Improving
Information our customer service, video of the Service; Service the Service, Identification,
recording (if you provide Providers; Third Parties (such Communications,
 permission). as affiliates) Marketing, Security, Legal,
Compliance and
Regulatory Obligations.

Platform Communication Information Directly from You, Your use of Providing the Service,
Communications (e.g., your name, contact the Service, and Users with Security, Legal,
information, and the whom you communicate Compliance and
contents of any messages Regulatory Obligations.
you send) With your consent, the
contents of any messages
you send may be used to
Develop and Improve the
Service.

Professional Previous place(s) of Directly from You or Your use Developing, Improving,
Information employment, position(s), of the Service; Service and Providing the Service,
work history, earnings, Providers; Third Parties (such Marketing, Analytics,
resume as other users) Security, Legal,
Compliance and
Regulatory Obligations.

Other User-generated content, Directly from You or Your use Developing, Improving,
information that (e.g., community posts, of the Service; Service and Providing the Service,
identifies or can feedback, ratings and job Providers; Third Parties (such Identification,
be reasonably postings), photographs, as affiliates, agents, and other Communications,
associated with examples of your work, users) Marketing, Analytics,
you information on work Security, Legal,
previously performed via the Compliance and
Service and outside the Regulatory Obligations.
Service, skills, tests taken,
test scores, hourly pay rates
and earnings information.

b. Non-Identifying Information and De-Identified Information

Non-Identifying Information/Usernames: We also may collect other information that does not identify you
directly, such as zip codes, demographic data, information about your use of the Service, and general project-
related data (“Non-Identifying Information”). We may combine information collected from Upwork users, whether
they are registered or not (“Upwork Users”). In some cases, we may render Personal Information (generally,
email address) into a form of Non-Identifying Information referred to in this Privacy Policy as “Hashed
Information.” This is typically accomplished using a mathematical process (commonly known as a hash function)
to convert information into a code. While the code does not identify you directly, it may be used by Upwork’s
partners to connect your activity and interests.

Combination of Personal and Non-Identifying Information: We may combine your Personal Information with
 Non-Identifying Information, but Upwork will treat the combined information as Personal Information.

De-Identified Information: We may also de-identify or aggregate information and convert it into non-personal
information so that it can no longer reasonably be used to identify you (“De-Identified Information”). We may use
De-Identified Information for any of the purposes described in the “We Use Information We Collect” section below.
We will maintain and use De-Identified Information in de-identified form and will not attempt to reidentify the
information, except to confirm our de-identification processes or unless required by law.

c. Information Collected Automatically

Like other online companies, we receive technical information when you use our Services. We use these technologies to
analyze how people use the Service, to improve how our Site functions, to save your log-in information for future
sessions, and to serve you with advertisements that may interest you.

Upwork and its partners use cookies or similar technologies to analyze trends, administer the website, track users’
movement around the website, the desktop app, and the mobile app, and to gather demographic information about our
user base as a whole. The technology used to collect information automatically from Upwork Users may include cookies,
web beacons, and embedded scripts. In addition, we and our marketing partners, affiliates, analytics, and service
providers may use a variety of other technologies (such as tags) that collect similar information for security and fraud
detection purposes and we may use third parties to perform these services on our behalf.

For further information on cookies and how they are used for the Service, please visit our Cookie Policy at
www.upwork.com/legal#cookie-policy.

d. Work Diaries and Work View

With your permission, we collect information about a Freelancer’s work for a Client, including automatically collected
information about work on a particular project. If a Freelancer enables Work Diaries, we will share Work Diaries with the
relevant Client and Agency. We tell Freelancers when we are capturing information for the Work Diary and allow
Freelancers to block such data sharing.

As part of the Service, when enabled by a Freelancer, we collect information about a Freelancer’s work on a project for a
Client, including information that may be considered personal information. This feature is known as Work Diary. Work
Diaries include information provided by the Freelancer, such as a memo, as well as automatically gathered information
about work on a project, such as number of mouseclicks and keyboard strokes and regularly taken screenshots (which
may include a webcam picture of you if you have enabled this feature in your settings). In order to use Work Diaries, you
must download and install the Team App software from www.upwork.com .

We will share information contained in Work Diaries with the relevant Client and with any manager or administrator of any
applicable Freelancer Agency. We inform Freelancers each time we capture information for Work Diary. As set forth in our
Terms of Service, End User License Agreement, and help pages on the Site, a Freelancer may choose to block or delete
the screen shot and associated data for a recorded work interval, but then the Freelancer may not be paid for that work
interval.

e. Analytics Providers, Ad Servers and Similar Third Parties

We may work with advertising agencies and vendors who use technology to help us understand how people use our Site.
These vendors may use technologies to serve you advertisements that may interest you. You can choose to opt out of
receiving certain interest-based advertising.

Upwork works with ad networks, ad agencies, analytics service providers and other vendors to provide us with information
regarding traffic on the Service, including pages viewed and the actions taken when visiting the Service; to serve our
advertisements on other websites, within mobile apps and elsewhere online; and to provide us with information regarding
the use of the Service and the effectiveness of our advertisements. Our service providers may collect certain information
about your visits to and activity on the Service as well as other websites or services, they may set and access their own
tracking technologies on your device (including cookies and web beacons), and may use that information to show you
targeted advertisements. Some of these parties may collect Personal Information when you visit the Service or other
online websites and services. We may also share certain Non-Identifying Information with these parties, including Hashed
Information, in connection with the services they provide to us. If you wish to opt out of interest-based advertising from
participating companies, click here (or if located in the European Union, click here). You must opt out on each device and
each browser where you want your choice to apply. If you choose to opt out, please note you will continue to receive
advertisements, but they may be less relevant to you.

While we may use a variety of service providers to perform advertising services, some of these companies are members
of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online
Behavioral Advertising. You may want to visit http://www.networkadvertising.org/managing/opt_out.asp, which provides
information regarding targeted advertising and the “opt-out” procedures of NAI members. You may also want to visit
http://www.aboutads.info/choices/, which provides information regarding targeted advertising and offers an “opt-out” by
participating companies in the DAA Self-Regulatory Program.

f. Do Not Track Signals and GPC

Please note that your browser setting may allow you to automatically transmit a “Do Not Track” signal to websites and
online services you visit. Upwork does not generally alter its practices when it receives a “Do Not Track” signal from a
visitor’s browser. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Global Privacy Control (GPC) is a technical specification that you can use to inform websites of your privacy preferences
regarding ad trackers. If you do choose to set up GPC, it may impact the functionality of the Site, but we honor the GPC
signal on a per-browser basis automatically in your cookie preferences.

g. Children
The Service is general audience and intended for users 18 and older. We do not knowingly collect Personal Information
from anyone younger than age 18. If we become aware that a child younger than 18 has provided us with Personal
Information, we will use commercially reasonable efforts to delete such information from our files. If you are the parent or
legal guardian of a child younger than age 18 and believe that Upwork has collected Personal Information from your child,
please contact us at: legalnotices@upwork.com.

2. USE OF INFORMATION
We use information collected through the Service to provide and improve the Service, develop new Services and
products, process your requests, prevent fraud, provide you with information and advertising that may interest you,
comply with the law, and as otherwise permitted with your consent.

a. We Use Information We Collect:

To develop, provide, and improve the Service, complete your transactions, address your inquiries, process your
registration, verify the information you provide is valid, and for compliance and internal business purposes.

To contact you with administrative communications and Upwork newsletters, marketing or promotional materials
(on behalf of Upwork or third parties) and other information that may be of interest to you. If you decide at any time
that you no longer wish to receive such communications from us, please follow the instructions in the Your Choices
and Rights section, below.

To tailor content we display to you and offers we may present to you, both on the Service and elsewhere online.

To administer and develop our business relationship with you and, if applicable, the corporation or other legal
entity you represent.

To assess your proposal to perform a freelance project on Upwork and prepare related governmental and internal
statistics reports.

To enforce and comply with the law, including to conduct an investigation, to protect the property and rights of
Upwork or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may
consider to be, or to pose a risk of being, illegal, fraudulent, unethical or legally actionable activity. We may also
use Device Identifiers to identify Upwork Users.

For the purposes disclosed at the time you provide your information, with your consent, and as further described in
this Privacy Policy.

To Honor Our Contractual Commitments to You. Much of our processing of Personal Information is to meet our
contractual obligations to our investors, or to take steps at Users' request in anticipation of entering into a contract
with them.

For Our Legitimate Interests. In many cases, we handle Personal Information on the grounds that it furthers our
legitimate interests in commercial activities, such as the following, in ways that are not overridden by the interests
or fundamental rights and freedoms of the affected individuals:

Providing our Site and Service.

Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and
prosecuting those responsible for that activity.

Measuring interest and engagement in our Services.

Short-term, transient use, such as contextual customization of ads.

Improving, upgrading or enhancing our Services.

Developing new products and services.

Ensuring internal quality control and safety.

Authenticating and verifying individual identities.

Debugging to identify and repair errors with our Services.

Auditing relating to interactions, transactions and other compliance activities.

Enforcing our agreements and policies.

 Analyzing and improving our business.

Communications, including marketing and responding to your inquiries about our services.

Addressing information security needs and protecting our Users, Upwork, and others.

Managing legal issues.

To Comply with Legal Obligations. We need to use and disclose Personal Information in certain ways to comply
with our legal obligations.

3. DATA RETENTION
Unless you request that we delete certain information (see Your Choices and Rights below), we will only retain your
personal information for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes
of satisfying any legal, regulatory, accounting, or reporting requirements, as well as ongoing fraud prevention, backup, and
business continuity purposes.

4. INFORMATION SHARING AND DISCLOSURE

We do not sell your Personal Information for monetary consideration, and we do not share your Personal
Information with third parties for those third parties’ marketing purposes unless we first provide you with the opportunity to
opt-in to or opt-out of such sharing.However, we may use technologies on our Site for the purposes of advertising or
marketing to you and understanding how you interact with our ads. This may be considered a “sale” or “sharing” of
personal information for targeted advertising under applicable data protection laws. We may also share information we
have collected about you, including Personal Information, as disclosed at the time you provide your information, with your
consent, as otherwise described in this Privacy Policy, or for the following business or commercial purposes:

Upwork Users For Freelancers who have entered into a contract with a Client or who have elected to
participate in Upwork Payroll, we may share their information with Clients, Agencies, and
Upwork payroll vendors. For Freelancers who choose to view a job post or submit a proposal
via the Service, we may share their information with the applicable Client(s). For Freelancers
who have made their profiles publicly visible, we may share their information with Clients,
Agencies, Partners, and Developers.
Note that if a Freelancer is suspended from the Upwork Service, we may share that
information with Clients for whom that Freelancer has worked or submitted proposals for
work. We may also share information with Agencies to whom Freelancers are associated for
a particular work project.
For clients who have entered into a service contract or agreed to use Upwork Payroll with
another user, we may share your information in order to complete the transaction or to
facilitate the resolution of a claim or dispute. The user receiving your information is not
allowed to use it for purposes unrelated to the transaction, such as to contact you for
marketing purposes, unless you have expressly consented to it.

Service Providers We may employ service providers and individuals to facilitate our Service, to provide the
Service on our behalf, to perform Service-related services (e.g., without limitation,
maintenance services, database management, web analytics and online advertising,
 payment processing, fraud detection and improvement of Upwork’s features) or to assist us
in analyzing how our Service is used. These Service providers may include analytics
companies, advertising partners, payment processors, identity verification companies,
security companies, generative AI partners, or other merchants. These third parties may
have access to your Personal Information in order to perform these tasks on our behalf.

Generative AI We provide certain features of our Service by integrating trusted generative AI service
Partners providers. We may share the information you provide while using these features with these
generative AI service providers, as well as additional information necessary to utilize the
feature.
Where Upwork uses this information to power features, we leverage certain treatments of the
data appropriate for the feature, including but not limited to, first removing personal
information and only using public data.
The Service includes a two-sided marketplace, which results in platform information
pertaining to both parties on either side of an interaction. For example, a Client’s review is
inherently about a Freelancer, a Client job post is work history for a Freelancer, and Client
spend is part of earning history for a Freelancer. Thus, if a Client or Freelancer chooses to
use our generative AI features, the platform information associated with that user’s account –
including information described above – may be used to power those features.

Legal and Upwork will share information with government agencies as required by law including
Investigative (without limitation) in response to lawful requests by public authorities to meet national
Purposes security or law enforcement requirements and in connection with reporting earnings. We
cooperate with government and law enforcement officials and private parties to enforce and
comply with the law.
We will disclose information about you to government or law enforcement officials or private
parties as we, in our sole discretion, believe necessary or appropriate to respond to claims
and legal process (including but not limited to subpoenas), or, at the request of governmental
authorities or other third parties conducting an investigation where we determine in our sole
discretion the disclosure is necessary to (a) protect the property and rights of Upwork or a
third party, (b) protect the safety of the public or any person, or (c) prevent or stop activity we
may consider to be, or pose a risk of being, illegal, fraudulent, unethical or legally actionable
activity.

Internal and Upwork may share information, including Personal Information, with its parent company
Business Upwork Inc., and any current or future subsidiaries or affiliates, primarily for business and
Transfers operational purposes, including activities such as IT management, for them to provide
services to you, or support and supplement the Services we provide. We may sell, transfer,
or otherwise share some or all of our assets, including your Personal Information, in
connection with a merger, acquisition, reorganization or sale of assets (including, in each
case, as part of the due-diligence process with any potential acquiring entity) or in the event
of bankruptcy.

Upwork If you choose to participate in The Upwork Foundation Initiative as a Freelancer, we may
Foundation share information relevant to your participation in the program with partners of Upwork who
Initiative provide support to Freelancers through that program.
Sweepstakes, We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) that may
Contests, and require registration.
Promotions

Non-Identifying We may share aggregated Non-Identifying Information and we may otherwise disclose Non-
Information and Identifying Information (including, without limitation, Hashed Information) or De-Identified
De-Identified Information to third parties.
Information

Categories of Personal Categories of Third Parties with Whether This Category is Used
Information We Have Shared in whom We Share Personal for Targeted Advertising
the Preceding 12 Months Information

Identifiers Analytics Companies, Identity Yes

Verification Companies, Advertising
Partners, Payment Processors,
Other Merchants, Upwork Users,
Government Agencies (as required
by law)

Contact Information Analytics Companies, Advertising Yes

Partners, Payment Processors,
Other Merchants, Upwork Users,
Government Agencies (as required
by law)

Sensitive Personal Information / Identity Verification Companies, No

Government Issued Identification Security Companies, Other
Numbers Merchants, Upwork Users,
Government Agencies (as required
by law)

Commercial Information Payment Processors, Security No

Companies, Analytics Companies,
Other Merchants, Upwork Users,
Government Agencies (as required
by law)

Financial Data/Payment Information Payment Processors, Security No

Companies, Other Merchants,
Upwork Users, Government
Agencies (as required by law)

Internet or Other Network or Device Analytics Companies, Advertising Yes

 Activities Including Information from Partners, Other Merchants,
Cookies Government Agencies (as required
by law)

Approximate Geolocation Analytics Companies, Advertising Yes

Information Partners, Other Merchants, Upwork
Users, Government Agencies (as
required by law)

Sensory Information Other Merchants, Upwork Users, No

Government Agencies (as required
by law)

5. YOUR CHOICES AND RIGHTS

You may have certain choices and rights associated with your personal information, including opting out of targeted
advertising or other disclosures to third parties. Residents of certain locations may have the right to have an authorized
agent submit requests on your behalf. You or your authorized agent may request that Upwork honor these rights by
contacting us as outlined in the “Contact Us” section below, or submitting a request here. Depending on your location, you
may also opt out of targeted advertising here.

Non-Discrimination: You will not receive any discriminatory treatment by us for the exercise of your privacy rights.

Verifying Your Request: Only you, or a person that you authorize to act on your behalf, may make a request related to
your personal information. In the case of access and deletion, your request must be verifiable before we can fulfill such
request. Verifying your request will require you to provide sufficient information for us to reasonably verify that you are the
person about whom we collected personal information or a person authorized to act on your behalf. We will only use the
personal information that you have provided in a verifiable request in order to verify your request. We cannot respond to
your request or provide you with personal information if we cannot verify your identity or authority. Please note that we
may charge a reasonable fee or refuse to act on a request if such request is excessive, repetitive or manifestly
unfounded.

For Individuals Located in the European Economic Area

(EEA), United Kingdom (UK) or Switzerland:
You have a number of rights under applicable data protection laws in relation to your personal information. Under certain
circumstances, you have the right to:

Have access to your personal information by submitting a request to us;

Have your personal information deleted;

Have your personal information corrected if it is wrong;

Have the processing of your personal information restricted;

Object to further processing of your personal information, including to object to marketing from us;

Make a data portability request;

 Withdraw any consent you have provided to us;

Restrict any automatic processing of your personal information; and

Complain to the appropriate Supervisory Authority.

To exercise any of these rights, please contact us as outlined in the “Contact Us” section below.

Notice for California Residents

“Shine the Light” and “Eraser” Laws: Residents of the State of California may request a list of all third parties to which
we have disclosed certain information during the preceding year for those third parties’ direct marketing purposes.

California Consumer Privacy Act (CCPA)/California Privacy Rights Act (CPRA): The CCPA, as amended by the
CPRA, provides California residents and/or their authorized agents with specific rights regarding the collection and
processing of their personal information.

Your Right to Know: California residents have the right to request that we disclose the following information to you about
our collection and use of your personal information over the past twelve (12) months. We may ask you to provide certain
information to identify yourself so that we may compare it with our records in order to verify your request. Upon
verification, we will disclose to you:

1. The categories of personal information we have collected about you.

2. The categories of sources for the personal information we have collected about you.

3. The specific pieces of personal information we have collected about you.

4. Our business or commercial purpose for collecting or “selling” your personal information as defined by the
CCPA.

5. The categories of third parties to whom we have sold or shared your personal information, if any, and the
categories of personal information that we have shared with each third-party recipient.

Your Right to Opt-Out of “Sale” or “Sharing” of Personal Information: California residents have the right to opt-out of the
“sale” or “sharing” of their personal information as defined by the CCPA by clicking here or by contacting us using the
information in the “Contact Us” section below.

Please note that we do not knowingly “sell” the personal information of any individuals under the age of 18.

Where we are “sharing” your personal information with third parties for the purposes of cross-context behavioral
advertising or profiling, you may opt-out of such sharing at any time by submitting a request as directed on the homepage
of our website or by contacting us using the information in the “Contact Us” section below.

Your Right to Limit Use of Sensitive Personal Information: California residents may have the right to request that
businesses limit the use of any sensitive personal information to those uses which are necessary to perform the Services
or for other specifically-enumerated business purposes under the CCPA, as amended by the CPRA. Please note that we
do not use sensitive personal information other than as necessary to perform the Services or as specifically permitted
under the CCPA.

Your Right to Delete: California residents have the right to request that we delete any of the personal information collected
from you and retained by us, subject to certain exceptions. We may ask you to provide certain information to identify
yourself so that we may compare it with our records in order to verify your request. Once your request is verified and we
have determined that we are required to delete the requested personal information in accordance with the CCPA, we will
delete, and direct our service providers to delete your personal information from their records. Your request to delete
personal information that we have collected may be denied if we conclude it is necessary for us to retain such personal
information under one or more of the exceptions listed in the CCPA.

Your Right to Correct: Under the CCPA, as amended by the CPRA, California residents have the right to request that we
correct any inaccurate personal information we maintain about you, taking into account the nature of the personal
information and the purposes for which we are processing such personal information. We will use commercially
reasonable efforts to correct such inaccurate personal information about you.

Non-Discrimination: You will not receive any discriminatory treatment by us for the exercise of your privacy rights
conferred by the CCPA.

Notice for Nevada Residents

Under Nevada law, certain Nevada residents may opt out of the sale of “personally identifiable information” for monetary
consideration to a person for that person to license or sell such information to additional persons. “Personally identifiable
information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier
that allows a specific person to be contacted either physically or online.

We do not engage in such activity; however, if you are a Nevada resident who has purchased or leased goods or services
from us, you may submit a request to opt out of any potential future sales under Nevada law by emailing
privacyrequests@upwork.com. Please note we will take reasonable steps to verify your identity and the authenticity of the
request. Once verified, we will maintain your request in the event our practices change.

Notice for Residents of Certain Other States

The laws of your state of residence (“Applicable State Law”) may provide you with certain rights, including the following:

Your Right to Confirm and Access: You have the right to confirm whether we are processing personal information about
you and access the personal information we process about you.

Your Right to Portability: You have to right to obtain a copy of the personal information we maintain and process about you
in a portable and, to the extent technically feasible, readily-usable format.

Your Right to Delete: You have the right to request that we delete the personal information we maintain or process about
you.

Your Right to Correct: You have the right to request that we correct inaccuracies in the personal information we maintain
or process about you, taking into consideration the nature and purpose of such processing.

Your Rights to Opt-Out: You have the right to opt-out of certain types of processing of personal information, including:

Opt-Out of the “sale” of personal information as defined by Applicable State Law;

Opt-Out of targeted advertising by us;

Opt-Out of automated profiling for the purposes of making decisions that produce legal or similarly significant
effects.
Please note, as explained above, we do not “sell” personal information as that word is traditionally defined. However, we
do share personal information with third parties to provide you with personalized advertising from us and to better
understand how you interact with our Services. Through the use of cookies, we may also make available certain personal
information to third parties for targeted advertising. You may opt-out from any of these disclosures under Applicable State
Law by clicking here.

Appeals Process & Other Concerns

Certain information may be exempt from the rights described above under applicable law. If we deny your request in
whole or in part, you may have the right to appeal the decision. In such circumstances, we will provide you with
information regarding the appeals process. Depending on your location, you may also email legalnotices@upwork.com
with the subject “Data Privacy Request Appeal” to provide us with details about why you are appealing the decision.

If you have an unresolved privacy or data use concern that we have not addressed to your satisfaction, please contact our
U.S.-based third-party dispute resolution provider free at https://feedback-form.truste.com/watchdog/request.

6. SECURITY
We take a number of steps to protect your data, but no security is guaranteed.

Upwork takes reasonable steps to help protect and secure the information it collects and stores about Upwork Users. We
maintain reasonable administrative, technical, and physical safeguards designed to protect personal information that we
receive against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure or use.

7. CROSS-BORDER DATA TRANSFERS

Because we are a U.S. company, we process and store your information in the United States and our service providers
may process and store it elsewhere.

Upwork may transfer your personal information to a third party that is located in a jurisdiction other than the one from
which we collected your personal information, including to countries that have not been deemed to have an adequate
level of protection for the rights and freedoms of data subjects. If we do transfer your personal information to another
jurisdiction, we will do so following due diligence and provided that the data recipient is subject to contractual agreements
imposing obligations on it to ensure appropriate technical and organizational are implemented and maintained at all times
to prevent the unauthorized and unlawful processing of personal information, and the accidental loss or destruction of, or
damage to, personal information, consistent with our obligations under applicable data protection laws.

We will use appropriate legal transfer mechanisms, including Standard Contractual Clauses, where required by law. In
addition, Upwork Global Inc. is self-certified under the U.S. Department of Commerce’s Data Privacy Framework, as
described below. Personal information from EU, Swiss, and UK residents will be treated in accordance with the Data
Privacy Framework Principles. To exercise any legal right to see copies of the data transfer mechanism documents that
Upwork uses to transfer data to third parties, please contact us.

Data Privacy Framework Notice

Upwork Global Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-
U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of
Commerce. Upwork Global Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data
Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the
European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.
Upwork Global Inc. has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy
Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from
Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-
U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data
Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

When Upwork Global Inc. receives Personal Information under the DPF and then transfers it to a third party service
provider acting as an agent on their behalf, Upwork Global Inc. may have certain responsibilities under the DPF if both (i)
the agent processes the information in a manner inconsistent with the DPF and (ii) Upwork or its affiliate is responsible for
the event giving rise to the damage.

Covered European residents should contact Upwork at the contact information below regarding Upwork Global Inc.’s
compliance with the DPF. Upwork will attempt to answer your questions and satisfy your concerns in a timely and
complete manner as soon as possible. If, after discussing the matter with Upwork, your issue or complaint is not resolved,
Upwork Global Inc. has agreed to participate in the DPF independent dispute resolution mechanisms listed below, free of
charge to you. PLEASE CONTACT UPWORK FIRST.

For other Personal Information Upwork Global Inc. receives under the DPF, we have committed to refer unresolved
privacy complaints under the DPF Principles to an independent dispute resolution mechanism, JAMS Data Privacy
Framework Dispute Resolution, operated by JAMS. If you do not receive timely acknowledgment of your complaint, or if
your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/dpf-dispute-resolution for more
information and to file a complaint.

If your complaint still is not resolved through these channels, under limited circumstances, an additional binding arbitration
option may be available before a DPF panel, as described at https://www.dataprivacyframework.gov/s/. Every individual
also has a right to lodge a complaint with the relevant supervisory authority.

The Federal Trade Commission has jurisdiction over Upwork Global Inc.’s compliance with the EU-U.S. DPF and the UK
Extension to the EU-U.S. DPF and the Swiss-U.S. DPF. In cases of onward transfers to third parties, Upwork Global Inc.
has responsibility for the processing of personal information we receive under the DPF Principles and subsequently
transfers to a third party acting as an agent on our behalf. To the extent required by the DPF, Upwork Global Inc. shall
remain liable under the DPF Principles if our agent processes such personal information in a manner inconsistent with the
DPF Principles, unless we are able to prove that we are not responsible for the event giving rise to the damage.

8. LINKS TO OTHER SITES

Our Service contains links to other websites. If you choose to click on a third-party link, you will be directed to that third
party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation
with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not
exercise control over third party websites. These other websites may place their own cookies or other files on your
computer, collect data or solicit Personal Information from you. We encourage you to read the privacy policies or
statements of the other websites you visit.

9. CHANGES TO THIS POLICY

We may change this Privacy Policy. If we make substantial changes, we will provide notice.

This Privacy Policy is effective as of the date stated at the top of this page. Upwork may update this Privacy Policy at any
time and any changes will be effective upon posting. By accessing or using the Service after we notify you of such
changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy
on a regular basis.

10. CONTACT US
To request that Upwork honor any of the rights described in this Policy submit a request here, or contact us as
outlined below.

If you have any questions about this Privacy Policy, please contact us at https://support.upwork.com or
legalnotices@upwork.com, or by mail addressed to Upwork, Attn: Legal, 655 Montgomery Street Suite 490, DPT 17022,
San Francisco, CA 94111-2676, USA. You may also contact us by phone at 866-262-4478.

If you are in the United Kingdom and contacting us does not resolve your inquiry, you may contact our UK representative
under the following contact details via mail at: VeraSafe United Kingdom Ltd. 37 Albert Embankment, London SE1 7TL,
United Kingdom.

If you are located in the EEA, for the purposes of Article 27 of the GDPR, you may contact our EU representative under
the following contact details via mail at: VeraSafe Ireland Ltd. Unit 3D North Point House, North Point Business Park, New
Mallow Road, Cork T23AT2P, Ireland.

You may also reach our UK and/or EEA Representatives via completing this form.