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 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 →Developers who build integrations with Gusto's API are now required to resolve any disputes with Gusto through mandatory individual binding arbitration rather than pursuing class action lawsuits, which may limit their legal remedies and transparency into disputes with Gusto. Additionally, Gusto explicitly reserves the right to modify, restrict, or discontinue its developer tools and API access at any time without notice or liability, meaning developers could lose access to critical platform capabilities that their business depends on without warning or recourse. Developers should review Section 19 of these terms carefully and consider whether the arbitration requirements and lack of access guarantees are acceptable before continuing to build on the Gusto API.
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 receive some of the data mentioned above from third parties... If you connect your Spotify account to a third party application, service or device, we may collect and use information from them. This collection is to make the integration possible... We work with technical service partners that giv...
We do not share your personal data with any third-party advertisers or ad networks for their advertising except for: (i) hashed or device identifiers (to the extent they are personal data in some countries), (ii) with your separate permission (e.g., in a lead generation form) or (iii) data already v...
We may share personal information with third-party service providers and partners who support our business operations, including identity verification providers, payment processors, analytics providers, marketing partners, and blockchain analytics companies.
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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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