60 Total

Key Facts · in the document’s own words

What does Gusto use personal information to do?
“Develop and improve our business and Services, including evaluating, operating, and creating new products and features, which may include the use of AI”
Version CA-V-007002, captured Sept. 17, 2026 · live source ↗
Our reading, not the document’s words
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 integrations, we may disclose your personal information to the applicable third-party provider to enable the features and functionality you requested.”
Version CA-V-007002, captured Sept. 17, 2026 · live source ↗
Our reading, not the document’s words
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?
“The right to limit the use and disclosure of your sensitive personal information.”
Version CA-V-007002, captured Sept. 17, 2026 · live source ↗
Our reading, not the document’s words
Gusto recognizes California residents' right to limit the use and disclosure of their sensitive personal information.
What rights does Gusto recognize?
“The right to opt out of the sale or sharing of your personal information, and the right to opt out of automated-decision making technology.”
Version CA-V-007002, captured Sept. 17, 2026 · live source ↗
Our reading, not the document’s words
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 a child under 13 submits personal information to Gusto and we learn that the information is from a child under 13...we will attempt to delete the information.”
Version CA-V-007002, captured Sept. 17, 2026 · live source ↗
Our reading, not the document’s words
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?
“Commercial Information...Your organization; service providers; advertising partners Yes (to advertising partners)”
Version CA-V-007002, captured Sept. 17, 2026 · live source ↗
Our reading, not the document’s words
Gusto shares commercial information, including your organization, with advertising partners, and this sharing qualifies as a sale or sharing for targeted advertising purposes.
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Summary
Generated by a model from the captured document; not read by a person

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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2 important changes detected

32 versions captured · Latest change detected by ConductAtlas: August 2026

What changed 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.
Why this matters 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.
View full change record →

June 1, 2026

medium
What changed Gusto expanded its privacy notice to explicitly cover 401(k) and SEP IRA/IRA accounts, clarified when the notice does not apply (adding separate guidance for employer and processor contexts), added Stripe as a financial data collection partner alongside Plaid, and introduced a new section on AI-powered features and integrations. The updated terms state that when users enable optional AI integrations, their personal information may be disclosed to third-party AI providers (such as OpenAI), though Gusto commits not to permit those providers to use the data to train their models. The policy also describes how Gusto processes personal information through automated and manual methods when users interact with AI-powered features on the platform.
Why this matters The updated privacy notice now explicitly covers retirement account access and use (401(k), SEP IRA, IRA), expanding the scope of activities governed by Gusto's privacy practices. The policy introduces optional AI-powered integrations that, when enabled, may disclose personal information to third-party AI providers such as OpenAI; Gusto states it will not permit these providers to use the data to train their models. The revised terms also clarify when the privacy notice does not apply (when Gusto acts as a processor or service provider) and direct users to the Employer Data Processing Addendum for those scenarios. You can review the specific AI providers and integration options available through your Gusto account settings before enabling any AI features.
View full change record →

Clauses withheld

We withheld clauses we had published from this document. Each withholding is recorded in our correction log:

Featured provisions
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Complete Provision Index

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

60 provisions
12 featured
14 clause types
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Archival ProvenanceSource & Archival Record
This version captured September 17, 2026 00:45 UTC
Last successful capture October 17, 2026 00:39 UTC
Date stated by the document August 29, 2026 (as printed in this version)
Capture Method Automated scheduled archival capture
Document ID CA-D-000294
Version ID CA-V-007002
SHA-256 (extracted text, extractor v5) 08d215e11f6fb82e58cbab5fe7f99736e7e1f61718cd1418991c4c08df2e3fa7
Archived bytes SHA-256 (anchor) 7772b1dfecfa9a4bde543e4ffedbae4aaf66238702c1d2c764d4aae3afc927d9
✓ Snapshot stored ✓ Archived bytes anchored (verified Sept. 17, 2026)

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