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 restricts a specific and significant secondary use of personal data by third-party AI providers, offering protection against user data being incorporated into external AI model development.
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 →Your personal information will not be used by Gusto's third-party AI or large language model providers to train, fine-tune, or improve their AI models.
How other platforms handle this
This is still Your Content, and you are responsible for it and its accuracy, as well as your use of it on our Services and any and all decisions made, actions taken, and failures to take action based on Your Content.
We generate new information from other data we collect to derive likely preferences or other characteristics. For instance, we infer your general geographic location based on your IP address.
You are responsible for any content, data, or instructions submitted to the Services via any Automated System. Instacart's license to use user content...includes content submitted by or through Automated Systems...
"Gusto does not permit its third-party artificial intelligence and large language model service providers to use your personal information to train, fine-tune, or improve their AI models.Excerpt from Gusto's Privacy Policy
How Meta, TikTok, and Supabase restructured governance language across documents, jurisdictions, and consent frameworks through incremental document updates.
How 10 AI platforms describe the use of user data for model training, improvement, and development, based on archived governance provisions.
Get the research letter
Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean.
This clause restricts a specific and significant secondary use of personal data by third-party AI providers, offering protection against user data being incorporated into external AI model development.
Your personal information will not be used by Gusto's third-party AI or large language model providers to train, fine-tune, or improve their AI models.
ConductAtlas has identified this type of provision across 216 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Gusto.