This analysis describes what Gusto's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
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.
View change record →The updated Privacy Policy now explicitly states it covers retirement account management (401k, SEP IRA, IRA accounts) and adds Stripe alongside Plaid as a third-party service provider that collects financial institution data. The policy restructures how it describes Gusto's role in different contexts: when Gusto acts as a service provider processing payroll or other data on behalf of employers, when it acts as an employer itself, or when it operates as a co-employer under a professional organization (PEO) arrangement, with separate privacy notices applying in each case. The policy introduces a new commitment that de-identified data will not be re-identified except to verify compliance with applicable law. If you connect a bank account through Stripe, that data will be treated under Stripe's Privacy Policy, which you should review separately.
View change record →How other platforms handle this
You have the right to submit a request through an authorized agent, but we will require the agent to provide us with your written permission, and we may need to confirm your identity before processing the agent's request.
we may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.
When you use them, we'll validate your request by verifying your identity (for example, by confirming that you're signed in to your Google Account).
"If you designate an authorized agent to submit a request on behalf, we will also need to verify your identity, which may require proof of your written authorization or evidence of a power of attorney.Excerpt from Gusto's Privacy Policy
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The clause states: “If you designate an authorized agent to submit a request on behalf, we will also need to verify your identity, which may require proof of your written authorization or evidence of a power of attorney.”
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Gusto.