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
This clause creates a conditional deletion obligation triggered by Gusto's awareness that a child under 13 submitted personal information, providing a protective measure for minors.
Interpretive note: The qualifier 'attempt to delete' rather than 'will delete' is preserved. The excerpt does not specify how Gusto learns of the child's age or what happens if deletion is not fully successful.
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 are a parent or guardian and a child under 13 has submitted personal information to Gusto, Gusto will attempt to delete it once it learns of this.
How other platforms handle this
We keep some data until you delete your Google Account, such as information about how often you use Gemini Apps.
If you decide to delete your Profile, it will no longer be visible to other Grindr users and your personal information will generally be deleted within 28 days.
We collect and keep personal data only as needed or allowed for the purposes set out in this Statement, based on the reason we collected the personal data in the first instance and what is permitted under the laws that apply to the processing.
"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.Excerpt from Gusto's Privacy Policy
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This clause creates a conditional deletion obligation triggered by Gusto's awareness that a child under 13 submitted personal information, providing a protective measure for minors.
If you are a parent or guardian and a child under 13 has submitted personal information to Gusto, Gusto will attempt to delete it once it learns of this.
ConductAtlas has identified this type of provision across 275 platforms. See the full comparison.
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