Gusto shares your personal information with third-party service providers, financial partners, and in some cases marketing affiliates to operate its services and for targeted advertising purposes.
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 provision establishes the operational framework for employer-initiated third-party service integrations and allocates responsibility for legal compliance and data accuracy to the employer rather than to Gusto when employer data is shared with third-party service providers.
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 →The updated terms make explicit that using Gusto's background check service constitutes a binding agreement. Previously, the terms of the service relationship may have been less clearly stated. Now, the agreement clarifies that an authorized signatory represents they have authority to bind the organization, and that three actions trigger binding acceptance: checking a box, initiating a background check, or accessing the service. This means employers should ensure the person clicking through has actual authority to commit the organization to the full Background Check Customer Agreement before proceeding.
View change record →The updated terms now explicitly state that employers accept mandatory individual arbitration and waive the right to participate in class-action lawsuits or pursue relief in court with a jury trial. This significantly limits employers' ability to challenge Gusto's practices collectively or seek resolution through the court system. Any disputes employers have with Gusto must be resolved individually through arbitration, which typically involves private, binding proceedings with limited appeal options and discovery rights compared to court litigation.
View change record →Your data may flow to companies you've never heard of, including advertising partners. California residents and users in certain other states can opt out of this sharing of personal information.
How other platforms handle this
We may share your personal information with third parties in the following circumstances: With service providers who perform services on our behalf, such as data analytics, marketing, customer service, and technology services. With financial partners, including banks, brokerage firms, and payment pr...
We may share your information with third parties that perform services on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. We may also share your information with business partners who offer products or services that...
In order to provide you with services, Valve needs to share some data with the publisher or developer of the game (for example to verify your ownership of the game and register your Steam ID with the publisher), or with other third parties that Valve works with to provide services to you. Valve will...
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"Employer will be able to elect to receive services from our third party partners (each a 'Third-Party Service')... If Employer chooses to and authorizes Gusto to share Employer Data with a Third-Party Service ('Shared Employer Data') then Employer (a) represents it has obtained all legal rights to do so, (b) assumes all risks related to such Shared Employer Data, (c) acknowledges it is solely responsible for the accuracy of such Shared Employer Data, and (d) agrees that it is solely responsible for the lawfulness of sharing such Shared Employer Data with the applicable Third-Party Service.— Excerpt from Gusto's Gusto Privacy Policy
Sharing data with marketing and advertising partners may constitute a 'sale' or 'sharing' of personal information under CCPA/CPRA and similar state laws, triggering opt-out obligations and requiring disclosure. Legal teams should confirm whether a DPIA or data sharing agreement is in place for each partner category.
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This provision establishes the operational framework for employer-initiated third-party service integrations and allocates responsibility for legal compliance and data accuracy to the employer rather than to Gusto when employer data is shared with third-party service providers.
Your data may flow to companies you've never heard of, including advertising partners. California residents and users in certain other states can opt out of this sharing of personal information.
ConductAtlas has identified this type of provision across 1 platforms. See the full comparison.
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