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 policy states that Gusto discloses identifiers and internet or electronic usage data to advertising, business, and technology partners. Under U.S. state privacy laws, this disclosure constitutes a 'sale' or 'share' of personal information. The policy now explicitly describes this practice and provides an opt-out mechanism. You can opt out of the sale or sharing of personal information through the Cookies, Analytics, and Other Tracking Technologies section.
View change record →The updated privacy notice now explicitly covers retirement account access and use (401(k), SEP IRA, IRA), expanding the scope of activities governed by Gusto's privacy practices. The policy introduces optional AI-powered integrations that, when enabled, may disclose personal information to third-party AI providers such as OpenAI; Gusto states it will not permit these providers to use the data to train their models. The revised terms also clarify when the privacy notice does not apply (when Gusto acts as a processor or service provider) and direct users to the Employer Data Processing Addendum for those scenarios. You can review the specific AI providers and integration options available through your Gusto account settings before enabling any AI features.
View change record →How other platforms handle this
We will verify your identity first before we can fulfill your request. We will respond to your request within the timeframe as required or permitted by the local laws.
We may take reasonable steps to verify your identity before responding to your request, which may include verifying your name, email address, and other information regarding your use of our services...
Keep other people's personal information private and don't create content that poses privacy or security risks to any person.
"If you submit a privacy right request, we must verify your identity before fulfilling your requests. If we cannot initially verify your identity, we may request additional information...Excerpt from Gusto's Privacy Policy
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
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Companies change their terms without announcing it. We capture governance documents, compare each new version with the last, and publish what changed, with the source text behind it. One email a week on what we found and what we could not reach.
The clause states: “If you submit a privacy right request, we must verify your identity before fulfilling your requests. If we cannot initially verify your identity, we may request additional information...”
ConductAtlas has identified this type of provision across 277 platforms. See the full comparison.
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