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.
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We will provide notice of significant updates, but please check our Privacy Notice periodically for changes. We'll always post the date our Privacy Notice was last updated at the top of the Notice.
If we make material changes to this Policy, we will notify you via the Services.
You will be notified by e-mail of any change to the Steam Wallet balance and usage limits within sixty (60) calendar days before the entry into force of the change.
"We will notify you of any material changes to this Privacy Notice as required by law. Changes to this Privacy Notice will be posted on the website where this appears.Excerpt from Gusto's Privacy Policy
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The clause states: “We will notify you of any material changes to this Privacy Notice as required by law. Changes to this Privacy Notice will be posted on the website where this appears.”
ConductAtlas has identified this type of provision across 289 platforms. See the full comparison.
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