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 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.
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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.
We may retain your Personal Data for a period of time consistent with the original purpose of collection...or as long as required to fulfill our legal and/or regulatory obligations.
Affirm will retain your information in accordance with our Privacy Policy and any applicable state or federal law, rule or regulation.
"Disconnecting an integration will stop future disclosures of personal information to that provider; however, any personal information previously shared with the provider will be subject to that provider's privacy policy...Excerpt from Gusto's Privacy Policy
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The clause states: “Disconnecting an integration will stop future disclosures of personal information to that provider; however, any personal information previously shared with the provider will be subject to that provider's privacy policy...”
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