“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.”
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 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 →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
When you use our paid Services, including redeeming voucher codes or purchasing paid Services, we collect information related to the payment transaction (with your consent). This may include payment card details (e.g. card account number), billing information, order details, the Services you purchas...
We collect payment and billing information when you register for certain paid Services. We use external secure payment processing services to collect and process payment information, such as payment card details.
When Connected Vehicle Information is transmitted from the vehicle, it is generally associated with a VIN or other unique identifiers, and the VIN or other unique identifiers can be linked to you.
"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 286 platforms. See the full comparison.
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