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 explicitly discloses that Gusto sells or shares personal information (defined under state privacy laws) with third parties including business, advertising, and technology partners. The company describes 'sale' as providing information in exchange for valuable consideration, and 'share' as providing information for cross-context behavioral advertising. This disclosure formalizes practices that may have been permitted under previous language but were not explicitly described. You can opt out of sales or sharing of personal information through the Cookies, Analytics, and Other Tracking Technologies section.
View change record →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
We cannot respond to Your request or provide You with the required information if We cannot: Verify Your identity or authority to make the request And confirm that the personal information relates to You
While we strive to prioritize the protection of personal data and comply with all applicable laws, we may decline a request from you if we have a lawful reason for doing so.
Microsoft reserves the right to restrict the export of data that may compromise the security of the services or Microsoft's intellectual property.
"We may deny certain requests, or only fulfill some in part, as permitted or required by law. For example, if you request to delete your personal information, we may retain some or all of it for legal purposes.Excerpt from Gusto's Privacy Policy
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The clause states: “We may deny certain requests, or only fulfill some in part, as permitted or required by law. For example, if you request to delete your personal information, we may retain some or all of it for legal purposes.”
ConductAtlas has identified this type of provision across 263 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Gusto.