61 Total
19 High severity
34 Medium severity
8 Low severity

Key Facts

What does Gusto use personal information to do?
Gusto uses personal information to develop and improve its business and Services, including evaluating, operating, and creating new products and features, which may include the use of AI.
What may Gusto do when you enable an AI-powered integration?
When you enable an AI-powered integration, Gusto may disclose your personal information to the applicable third-party provider to enable the features and functionality you requested.
What right do California residents have regarding their sensitive personal information?
Gusto recognizes California residents' right to limit the use and disclosure of their sensitive personal information.
What rights does Gusto recognize?
Gusto recognizes the right to opt out of the sale or sharing of personal information and the right to opt out of automated decision-making technology.
What will Gusto do if it learns that personal information it has received was submitted by a child under 13?
If Gusto learns that personal information it has received was submitted by a child under 13, Gusto will attempt to delete that information.
What does Gusto share with advertising partners?
Gusto shares commercial information, including your organization, with advertising partners, and this sharing qualifies as a sale or sharing for targeted advertising purposes.
Does this sharing qualify as a sale or sharing for targeted advertising purposes?
Gusto shares commercial information, including your organization, with advertising partners, and this sharing qualifies as a sale or sharing for targeted advertising purposes.
How does Gusto use personal information for advertising?
Gusto uses personal information to provide personalized and interest-based advertising through the use of cross-device tracking.
Does Gusto generate, review, verify, or endorse AI Outputs?
Gusto does not generate, review, verify, or endorse AI Outputs, makes no representations or warranties regarding their accuracy, completeness, or compliance, and shall not be liable for them.
Is Gusto liable for AI Outputs?
Gusto does not generate, review, verify, or endorse AI Outputs, makes no representations or warranties regarding their accuracy, completeness, or compliance, and shall not be liable for them.
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Summary

Gusto's Privacy Policy explains what Gusto does with your personal information, including using it to improve its services and deliver targeted ads across your devices. You have rights to limit how your sensitive data is used and to opt out of Gusto selling or sharing your information and of automated decision-making. If you use AI-powered features, Gusto is not responsible for the accuracy of AI outputs — you are responsible for reviewing them before acting on them.

Analysis

Gusto's Privacy Policy establishes how Gusto collects, uses, shares, and retains personal information in connection with its platform and services. It authorizes Gusto to use personal information for broad internal development purposes, including AI-related activities, and to provide personalized, interest-based advertising through cross-device tracking and sharing of commercial information with advertising partners, which Gusto classifies as a sale or sharing. The policy recognizes specific consumer rights, including the right to limit use and disclosure of sensitive personal information, the right to opt out of the sale or sharing of personal information, and the right to opt out of automated decision-making. With respect to AI, the policy disclaims Gusto's liability for AI Outputs, places sole responsibility for reviewing and approving those outputs on the user, and prohibits third-party AI and large language model providers from using personal information to train or improve their models.

What this means for you

This policy directly affects users by disclosing that Gusto uses personal information for service development including AI, tracks users across devices for targeted advertising, and shares commercial information with advertising partners in a manner classified as a sale or sharing. Users have the right to limit Gusto's use and disclosure of their sensitive personal information and the right to opt out of the sale or sharing of their personal information and of automated decision-making. Where applicable law requires it, Gusto will obtain opt-in consent before processing sensitive personal information such as precise geolocation, Social Security numbers, and biometric data. Users who activate AI-powered integrations should be aware that their personal information may be shared with third-party providers to enable those features, and that they bear sole responsibility for reviewing all AI Outputs before those outputs are executed or applied. To exercise your opt-out rights, you can contact Gusto directly as recognized under this policy.

Institutional Analysis
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Which mapped governance frameworks each document engages, tied to the specific provisions that engage them.

13 important changes detected

28 versions captured · Last updated: July 2026

What changed Gusto's privacy policy in an update detected on July 20, 2026 contained minor formatting and punctuation corrections across five sentences. The substantive policy language describing data collection, AI integration disclosures, and recipient categories remained unchanged. These appear to be editorial corrections with no operational impact on how Gusto collects, uses, or shares personal information.
Why this matters Gusto's privacy policy received formatting and punctuation corrections in an update detected on July 20, 2026. The substantive terms describing personal information collection, AI integration disclosure, and data recipient categories remain functionally identical. No changes to consumer rights, data practices, or obligations occurred.
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What changed Gusto updated its privacy policy in an update detected on July 18, 2026 to consolidate privacy request submission channels. The policy previously directed users to separate privacy portals for Gusto and Gusto Retirement services; the updated language now permits users to submit privacy requests through either the main Gusto Privacy Request Portal or the Gusto Retirement Privacy Request Portal from a single entry point. Additionally, the policy simplified language describing where the 'Your Privacy Choices' link appears, removing specific mention of the Gusto Retirement website as a separate location. The net effect is that privacy rights exercise procedures now reference unified submission options rather than service-specific portals.
Why this matters The updated policy clarifies how users can exercise privacy rights across Gusto's service suite. Previously, the policy referenced separate privacy request portals for Gusto and Gusto Retirement; the revised language now states users may submit privacy requests through either portal for any privacy right exercise, appeals, or general privacy inquiries. This consolidation simplifies the request submission process by reducing the number of entry points users need to navigate to exercise rights under state privacy laws.
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July 1, 2026 low

Gusto's Privacy Policy was updated on July 1, 2026 by adding one sentence to the table of contents. The document now lists 'Gusto Channel Partner Program Terms' in the legal …

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June 28, 2026 low

Gusto updated its Privacy Policy on June 28, 2026 with nine sentence-level edits, primarily formatting corrections and contact information updates. The substantive changes include correcting the contact email address from …

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June 21, 2026 low

Gusto updated three contact details in its Privacy Policy on June 21, 2026: the privacy email address changed from privacy@gusto.com to [email protected], and minor formatting corrections were made to …

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June 16, 2026 low

Gusto's Privacy Policy was updated on June 16, 2026, with one sentence modification detected in the document. The change involved updating a reference in the table of contents or document …

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June 13, 2026 low

Gusto updated its Privacy Policy on June 13, 2026 with primarily technical and administrative corrections. The changes include correcting email contact addresses from a generic format to privacy@gusto.com, fixing spacing …

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June 1, 2026 medium

Gusto updated its Privacy Policy effective June 1, 2026, to clarify scope and expand disclosure of data collection practices. The policy now explicitly covers retirement accounts (401k and SEP IRA/IRA …

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May 28, 2026 low

The change detected in Gusto's Privacy Policy on May 28, 2026 involves a modification to one sentence within the document. The specific nature of the modified sentence cannot be determined …

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May 21, 2026 low

Gusto updated its Privacy Policy on May 21, 2026 to change the email address listed for privacy inquiries and data requests from privacy@gusto.com to a masked email format displayed as …

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May 19, 2026 low

The diff provided shows Gusto's Privacy Notice with minimal substantive changes. One sentence was modified, though the visible change in the diff context appears to be a character encoding issue …

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May 1, 2026 low

Gusto updated contact email addresses in its privacy policy and related terms. The company replaced several branded email addresses (legal-opt-outs@gusto.com and support@gusto.com) with a generic inbox address ([email protected]). This …

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April 23, 2026 low

Gusto updated contact email addresses in its Privacy Policy on April 23, 2026. The policy now directs users to email legal-opt-outs@gusto.com for arbitration opt-outs and legal notices, and support@gusto.com for …

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Featured, High severity

Complete Provision Index

Every distinct legal provision identified in this document. Featured provisions appear above with analysis.

61 provisions
12 featured
14 clause types
19 high severity
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Mapped Governance Frameworks

CCPA/CPRA
California, USA
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Connecticut Data Privacy Act Amendments
US-CT
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CAN-SPAM
United States Federal
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FTC Act Section 5
United States Federal
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Indiana Consumer Data Protection Act
US-IN
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Kentucky Consumer Data Protection Act
US-KY
View official text ↗
Universal Opt-Out Mechanism Expansion 2026
US
View official text ↗
Archival ProvenanceSource & Archival Record
Last Captured July 20, 2026 00:48 UTC
Capture Method Automated scheduled archival capture
Document ID CA-D-000294
Version ID CA-V-005102
SHA-256 85cb6de4f36e8902fa757616c8afe7fa5ec42fe13de984392a8a4e4a713a7054
✓ Snapshot stored ✓ Text extracted ✓ Change verified ✓ Hash verified

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