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 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 change record →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 change record →How other platforms handle this
We will verify your identity first before we can fulfill your request. We will respond to your request within the timeframe as required or permitted by the local laws.
In certain states, you can designate an authorized agent to make a rights request on your behalf. You or the agent must provide written authorization acceptable to us.
Before accepting a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.
"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
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
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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 277 platforms. See the full comparison.
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