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.
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.
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.
→ 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.
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). An additional minor or cosmetic changes were excluded.
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.
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.
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 …
Regulatory exposure, obligation change, escalation trigger, board-ready language, and recommended action for legal and compliance teams.
Unlock the full institutional analysis — InsightConductAtlas 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.
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