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 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 →How other platforms handle this
Whenever we transfer personal data internationally, we use tools and transfer agreements to: make sure the data transfer complies with applicable law; and help to give your data the same level of protection as it has in the EU...
we may share data between our affiliates for the safety and security of our users and may take necessary actions if we believe you have violated these Terms, including banning you from our Services and/or our affiliates' services...
Each payment processor uses and processes your complete payment information in accordance with its applicable privacy policy (Stripe and PayPal).
"If your personal information is transferred to a country other than your home country, we will take measures to protect your personal information, for example, by implementing appropriate contractual clauses.Excerpt from Gusto's Privacy Policy
ConductAtlas detected a major restructuring of Meta’s privacy policy that removed detailed consumer rights disclosures and relocated them to separate documents.
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The clause states: “If your personal information is transferred to a country other than your home country, we will take measures to protect your personal information, for example, by implementing appropriate contractual clauses.”
ConductAtlas has identified this type of provision across 288 platforms. See the full comparison.
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