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 conditions Gusto's processing of sensitive personal information on obtaining prior opt-in consent, but only where applicable law requires it, meaning consent is not universally guaranteed.
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 →In jurisdictions where law requires it, Gusto will ask for your opt-in consent before processing sensitive personal information including precise geolocation, Social Security numbers, and biometric data.
How other platforms handle this
Category A: Identifiers. Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number... Collected: Yes.
You may give us your Identity Data, Contact Data, Financial Data, Profile Data, and other information by filling in forms or by corresponding with us by post, phone, e-mail or otherwise.
if you place a restaurant order, our restaurant partner will collect and process your credit card or other payment information in order to fulfill the order.
"Where required by applicable law, we will obtain your opt-in consent before processing certain sensitive personal information such as precise geolocation, Social Security number, and biometric data.Excerpt from Gusto's Privacy Policy
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This clause conditions Gusto's processing of sensitive personal information on obtaining prior opt-in consent, but only where applicable law requires it, meaning consent is not universally guaranteed.
In jurisdictions where law requires it, Gusto will ask for your opt-in consent before processing sensitive personal information including precise geolocation, Social Security numbers, and biometric data.
ConductAtlas has identified this type of provision across 296 platforms. See the full comparison.
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