California residents have specific legal rights to access, delete, correct, and limit how Gusto uses their personal data, and Gusto cannot penalize you for exercising these rights.
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
These rights give California residents meaningful control over highly sensitive payroll, financial, and health data held by Gusto, including the ability to request deletion of that data.
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 →Provision renamed from 'California and Multi-State Privacy Rights' to 'California Resident Privacy Rights (CCPA/CPRA)' with added excerpt detailing specific consumer rights including right to correct and right to limit sensitive data use.
View full change record →If you live in California, you can formally request that Gusto tell you exactly what data it holds about you, correct errors, or delete your personal information, and Gusto is legally prohibited from retaliating against you for making these requests.
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.
"If you are a California resident, you have the following rights: The right to know about the personal information we collect, use, disclose, and sell. The right to delete personal information we have collected about you. The right to correct inaccurate personal information. The right to opt out of the sale or sharing of your personal information. The right to limit the use and disclosure of sensitive personal information. The right to non-discrimination for exercising your rights.Excerpt from Gusto's Privacy Policy
1) REGULATORY LANDSCAPE: This provision directly implements CCPA as amended by CPRA, enforceable by the California Privacy Protection Agency (CPPA) and the California Attorney General.
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Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
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These rights give California residents meaningful control over highly sensitive payroll, financial, and health data held by Gusto, including the ability to request deletion of that data.
If you live in California, you can formally request that Gusto tell you exactly what data it holds about you, correct errors, or delete your personal information, and Gusto is legally prohibited from retaliating against you for making these requests.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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