Gusto can use anonymized versions of your data for internal research and product improvement purposes, and this use is not covered by the privacy rights described elsewhere in the notice.
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
There is no opt-out described for this use, and the exclusion of de-identified data from the privacy notice means consumers have no stated rights over how this derived data is used.
Interpretive note: The legal validity of the de-identification exemption depends on the technical standards applied, which are not disclosed in the policy; CPRA's conditions for this exemption create interpretive uncertainty.
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 →This new provision clarifies that aggregated and de-identified data is excluded from privacy protections, which could allow broader use of user data for analytics and product development without individual consent.
View full change record →Patterns and insights derived from your payroll, HR, and benefits data may be used to develop Gusto's products and conduct research, with no opt-out mechanism disclosed and no privacy rights applicable to this data category according to the policy.
How other platforms handle this
to request that your data be transferred to a third party (data portability)
Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.
Further, you may take legal actions in relation to any potential breach of your rights regarding the processing of your Personal Information, as well as to lodge complaints before the competent data prot...
"We may use aggregated and/or de-identified information about our users and our services for research, analytics, product development, and other business purposes. This information is not personal information and is not subject to this Privacy Notice.Excerpt from Gusto's Privacy Policy
1) REGULATORY LANDSCAPE: CCPA/CPRA provides that de-identified data is exempt from consumer rights obligations, but only if the company implements technical safeguards and public commitments to non-re-identification.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
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There is no opt-out described for this use, and the exclusion of de-identified data from the privacy notice means consumers have no stated rights over how this derived data is used.
Patterns and insights derived from your payroll, HR, and benefits data may be used to develop Gusto's products and conduct research, with no opt-out mechanism disclosed and no privacy rights applicable to this data category according to the policy.
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.