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 provides an explicit prohibition on a specific category of data sharing, limiting how mobile information can be used by external parties for commercial outreach.
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 →The updated terms make explicit that using Gusto's background check service constitutes a binding agreement. Previously, the terms of the service relationship may have been less clearly stated. Now, the agreement clarifies that an authorized signatory represents they have authority to bind the organization, and that three actions trigger binding acceptance: checking a box, initiating a background check, or accessing the service. This means employers should ensure the person clicking through has actual authority to commit the organization to the full Background Check Customer Agreement before proceeding.
View change record →The updated terms now explicitly state that employers accept mandatory individual arbitration and waive the right to participate in class-action lawsuits or pursue relief in court with a jury trial. This significantly limits employers' ability to challenge Gusto's practices collectively or seek resolution through the court system. Any disputes employers have with Gusto must be resolved individually through arbitration, which typically involves private, binding proceedings with limited appeal options and discovery rights compared to court litigation.
View change record →Your mobile information will not be shared by Gusto with third parties or affiliates for marketing or promotional purposes.
How other platforms handle this
we may use, retain or share information with law enforcement or others in circumstances where a person's vital interests require protection, such as in the case of emergencies.
Any such de-identified genetic information and phenotypic information we share with third parties for research purposes is done in accordance with Part 46 (beginning with Section 46.101) of Title 45 of the Code of Federal Regulations.
if you are accessing and using Lime Services under a corporate account...you acknowledge and agree that Lime may share certain of your usage information with whomever provided you with access to the Lime Services
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"No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent...— Excerpt from Gusto's Gusto Privacy Policy
ConductAtlas detected a major restructuring of Meta’s privacy policy that removed detailed consumer rights disclosures and relocated them to separate documents.
Your genetic data may be transferred to a new owner as a business asset. Here is what the Terms of Service actually say and what you can do right now.
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This clause provides an explicit prohibition on a specific category of data sharing, limiting how mobile information can be used by external parties for commercial outreach.
Your mobile information will not be shared by Gusto with third parties or affiliates for marketing or promotional purposes.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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