California residents have rights under CCPA/CPRA to know, access, delete, correct, and opt out of the sale or sharing of their personal information. Residents of Virginia, Colorado, Connecticut, Texas, Montana, and other states have similar rights under their respective state privacy laws.
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 provision operationalizes Gusto's compliance obligations under state privacy regimes, establishing the legal framework governing data collection, processing, retention, and user access/deletion/opt-out rights. This determines the substantive privacy protections and consumer controls available under the service agreement.
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 →If you live in California or one of several other states, you have legally enforceable rights to access, correct, delete, and limit the use of your personal data. Gusto is required to respond to verified requests within statutory timeframes.
How other platforms handle this
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).
Not be Discriminated Against by us for exercising your privacy rights.
You may contact our privacy team with any requests of disclosure, correction, or deletion of your personal information. You may also request suspension of use or suspension of sharing of your personal information with certain third parties.
This provision implicates CCPA/CPRA, Virginia CDPA, Colorado CPA, Connecticut CTDPA, Texas TDPSA, and Montana CDPA.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
Search "[your state] attorney general consumer complaint" to find your state's direct complaint form
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
Get the research letter
Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean.
The provision operationalizes Gusto's compliance obligations under state privacy regimes, establishing the legal framework governing data collection, processing, retention, and user access/deletion/opt-out rights. This determines the substantive privacy protections and consumer controls available under the service agreement.
If you live in California or one of several other states, you have legally enforceable rights to access, correct, delete, and limit the use of your personal data. Gusto is required to respond to verified requests within statutory timeframes.
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.