“If a child under 13 submits personal information to Gusto and we learn that the information is from a child under 13...we will attempt to delete the information.”
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
This clause creates a conditional deletion obligation triggered by Gusto's awareness that a child under 13 submitted personal information, providing a protective measure for minors.
Interpretive note: The qualifier 'attempt to delete' rather than 'will delete' is preserved. The excerpt does not specify how Gusto learns of the child's age or what happens if deletion is not fully successful.
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 →If you are a parent or guardian and a child under 13 has submitted personal information to Gusto, Gusto will attempt to delete it once it learns of this.
How other platforms handle this
We may continue to retain some information even after you delete your account if we are required to do so in order to comply with applicable laws.
After you submit a request to delete your account, we initiate a deletion process to safely and completely remove your data from our servers or retain it only in anonymized form.
If you close your account, we will delete your account data within 180 days...
"If a child under 13 submits personal information to Gusto and we learn that the information is from a child under 13...we will attempt to delete the information.Excerpt from Gusto's Privacy Policy
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This clause creates a conditional deletion obligation triggered by Gusto's awareness that a child under 13 submitted personal information, providing a protective measure for minors.
If you are a parent or guardian and a child under 13 has submitted personal information to Gusto, Gusto will attempt to delete it once it learns of this.
ConductAtlas has identified this type of provision across 268 platforms. See the full comparison.
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