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.
Consumers: Users are now told explicitly that their personal data may be sold or shared with advertising and business partners for consideration or behavioral advertising purposes.
Consumers: Users now have a documented path to opt out of personal data sales and sharing through cookie and tracking technology controls.
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.
→ Review the Cookies, Analytics, and Other Tracking Technologies section of Gusto's privacy policy to locate and use the opt-out mechanism if you wish to decline sales or sharing of your personal information.
→ If you are a California resident or resident of another U.S. state with privacy laws, verify that you understand which categories of personal information Gusto may sell or share (identifiers and electronic usage data) and consider exercising your opt-out right if available.
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.
Across all monitored documents, Gusto has made 4 significant changes.
Explicitly discloses that Gusto sells or shares identifiers and electronic usage data with business, advertising, and technology partners in compliance with state privacy law definitions.
References an opt-out mechanism in the Cookies, Analytics, and Other Tracking Technologies section for users to decline sales or sharing of personal information.
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
Gusto has added explicit disclosures of personal information sales and sharing practices in compliance with U.S. state privacy laws (CCPA, CPRA, VCDPA, CPA, UCPA, MCDPA). The language aligns with statutory definitions of 'sale' and 'share' …
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-C-004703.
The diff provided shows only a truncated list of linked terms and documents, not substantive policy language. The BEFORE and …
The provided diff shows only truncated header/table-of-contents text from Gusto's Terms of Service and does not reveal the specific substantive …
Gusto's privacy policy in an update detected on July 20, 2026 contained minor formatting and punctuation corrections across five sentences. …
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