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.
View change record →How other platforms handle this
We do not use what you say in email, chat, video calls or voice mail, or your documents, photos or other personal files, to target advertising to you.
We use your personal information to send you newsletters and other promotional communications, including information about MyFitnessPal's new offerings, features, offers, events, webinars, and other information.
We may infer certain information from your interactions with the Lyft Platform and other personal information available to us. For example, if you frequently ride to or from airports, we may infer you are a frequent traveler.
"Gusto may create and use de-identified data, which we commit to maintaining and processing in a de-identified form and will not attempt to, directly or indirectly, re-identify...Excerpt from Gusto's Privacy Policy
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The clause states: “Gusto may create and use de-identified data, which we commit to maintaining and processing in a de-identified form and will not attempt to, directly or indirectly, re-identify...”
ConductAtlas has identified this type of provision across 279 platforms. See the full comparison.
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