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
Output is for informational purposes only and is not a substitute for advice from a qualified professional.
CUSTOMER ACKNOWLEDGES THAT THE LEGAL STATUS OF GENERATIVE ARTIFICIAL INTELLIGENCE OUTPUT IS UNCERTAIN AND THAT OUTPUTS MAY NOT BE SUBJECT TO PROTECTION UNDER INTELLECTUAL PROPERTY LAW
This assignment does not transfer any rights in the underlying AI Features or models.
"The scope of personal information disclosed depends on the integration and provider; some integrations may allow you to select specific data categories, while others may require broader access to function.Excerpt from Gusto's Privacy Policy
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The clause states: “The scope of personal information disclosed depends on the integration and provider; some integrations may allow you to select specific data categories, while others may require broader access to function.”
ConductAtlas has identified this type of provision across 210 platforms. See the full comparison.
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