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
If you withdraw your consent (or if you decide not to provide certain personal information), you acknowledge that we may not be able to provide you with certain products, services, or information.
you have the obligation to provide to us evidence of such consent or authorization...the consent or authorization of the holder of parental responsibility for the minor...
If you choose not to provide information, we may not be able to provide you with requested products, services or information.
"Withdrawing consent may impact your ability to use our Services and will not affect processing of your personal information processed on another basisExcerpt from Gusto's Privacy Policy
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The clause states: “Withdrawing consent may impact your ability to use our Services and will not affect processing of your personal information processed on another basis”
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