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
Allow us and other advertisers to show you the most relevant products, offers, and advertisements on the site and third-party sites, or through emails or other message platforms.
They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser...
We use cookies, web beacons, and other similar technologies, including from third-party partners such as Google and Facebook, for measurement services, better targeting advertisements, marketing purposes and to improve the performance of the Sites.
"These Cookies enable us and third parties to gain a better understanding of your interests. This allows us to display personalized ads...not only on our Services but also on those of third-party partners.Excerpt from Gusto's Privacy Policy
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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: “These Cookies enable us and third parties to gain a better understanding of your interests. This allows us to display personalized ads...not only on our Services but also on those of third-party partners.”
ConductAtlas has identified this type of provision across 140 platforms. See the full comparison.
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