Generated by a model from the captured document; not read by a person
MediumNeutral for users
Affected users
All usersUS usersCalifornia residents
Gusto's updated privacy policy now explicitly discloses that it engages in the 'sale' or 'sharing' of personal information as defined under U.S. state privacy laws. The policy clarifies that 'sale' includes making personal information available to third parties for valuable consideration (not limited to money), and 'share' includes making information available for cross-context behavioral advertising. Gusto states it discloses identifiers and internet or electronic usage data to business, advertising, and technology partners, and provides an opt-out mechanism in the Cookies, Analytics, and Other Tracking Technologies section.
1 obligation expanded
Consumers: Gusto is now clearly stating that it shares your personal data with third parties for advertising purposes, and you can opt out if you choose.
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Generated by a model from the captured document; not read by a person
The updated policy states that Gusto discloses identifiers and internet or electronic usage data to advertising, business, and technology partners. Under U.S. state privacy laws, this disclosure constitutes a 'sale' or 'share' of personal information. The policy now explicitly describes this practice and provides an opt-out mechanism. You can opt out of the sale or sharing of personal information through the Cookies, Analytics, and Other Tracking Technologies section.
What you can do
→ Review the Cookies, Analytics, and Other Tracking Technologies section to locate and exercise the opt-out mechanism if you wish to limit the sale or sharing of your personal information.
Historical Context
This is the 2nd significant Data Collection Expansion change Gusto has made since ConductAtlas began monitoring.
ConductAtlas has recorded 2 material changes to this document
over 89 days of monitoring
(since June 2026).
Key Clauses Affected
Generated by a model from the captured document; not read by a person
Personal Data Sale and Sharing Disclosure
Gusto now explicitly states it engages in 'sale' or 'sharing' of identifiers and internet or electronic usage data with advertising, business, and technology partners, with an opt-out mechanism provided.
Full clause-by-clause analysis available with Insight.
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This change record describes what was added, removed, or modified in the document. Analysis reflects what the updated agreement states or permits. It does not constitute a legal determination about enforceability. Applicability may vary by jurisdiction. Methodology
Wording edits to this record that do not change what it claims. Changes to a claim are published as corrections.
2026-10-11 · Feed summary edited · summary regenerated by summarize_events
Previous text Adds disclosure that personal data is sold or shared with advertising and business partners; opt-out mechanism available.
2026-10-11 · Impact summary edited · summary regenerated by summarize_events
Previous text The updated policy explicitly discloses that Gusto sells or shares personal information (defined under state privacy laws) with third parties including business, advertising, and technology partners. The company describes 'sale' as providing information in exchange for valuable consideration, and 'share' as providing information for cross-context behavioral advertising. This disclosure formalizes practices that may have been permitted under previous language but were not explicitly described. You can opt out of sales or sharing of personal information through the Cookies, Analytics, and Other Tracking Technologies section.
2026-10-11 · Summary edited · summary regenerated by summarize_events
Previous text Gusto's updated privacy policy adds explicit language describing how the company sells or shares personal information under U.S. state privacy laws. The policy defines 'sale' to include providing personal information to third parties for valuable consideration (not limited to money), and 'share' to include providing information for cross-context behavioral advertising. The company states it engages in these practices when disclosing identifiers and internet/electronic usage data to business, advertising, and technology partners. Users can opt out through the Cookies, Analytics, and Other Tracking Technologies section.
2026-10-07 · Change line edited · change line rewritten to the 2026-10-07 template: no detection date, no sentence counts
Previous text Gusto updated their Gusto Privacy Policy on August 29, 2026. Change detected: 5 sentence(s) added, 1 sentence(s) modified. Document contained 147 sentences after update.
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
For legal and compliance teams
Institutional Analysis
Generated by a model from the captured document; not read by a person
Assessment
Gusto has added explicit disclosure language describing its practice of disclosing personal data (identifiers and usage data) to third-party advertising, business, and technology partners. This disclosure aligns with obligations under California's CCPA/CPRA and similar state …
🔒Full institutional analysis
Regulatory exposure, obligation change, escalation trigger, board-ready language, and recommended action for legal and compliance teams.
ConductAtlas provides verified policy intelligence sourced directly from platform documents. All analysis is intended to support, not replace, legal and compliance review. Record CA-X-004703.
Gusto expanded its privacy notice to explicitly cover 401(k) and SEP IRA/IRA accounts, clarified when the notice does not apply …
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