Privacy Policy and Federal Privacy Notice
Sapere LLC (“Sapere,” “we,” “us,” or “our”) is committed to protecting the privacy and confidentiality of the personal and financial information you share with us. This Privacy Policy explains what information we collect, how we use and protect it, and the choices you have.
This Policy applies to our website at saperetax.com, to the tax preparation, tax planning, and advisory services we provide, and to all communications between Sapere and our clients, prospective clients, and website visitors.
This document serves two purposes. It is (1) our general privacy policy, and (2) our privacy notice under the Gramm-Leach-Bliley Act (“GLBA”), which applies to tax preparers as “financial institutions.” The federally prescribed summary of our information-sharing practices appears in Appendix A, and controls over any inconsistent statement elsewhere in this document with respect to GLBA-covered sharing.
We intend this Policy to comply with applicable federal and state law, including Internal Revenue Code §§7216 and 6713 and Treasury Regulations §§301.7216-1 through 301.7216-3 governing the use and disclosure of tax return information; the GLBA Privacy Rule and the FTC Safeguards Rule (16 C.F.R. Parts 313 and 314); Treasury Department Circular No. 230; and applicable state privacy and data breach notification laws.
1. Information We Collect
In the course of providing tax preparation, planning, and related professional services, we may collect:
- Identifying information: name, address, date of birth, Social Security number or ITIN, phone number, email address, and government-issued identification.
- Financial information: income, wages, investment and retirement account data, business financial records, banking information, and other data contained in tax documents (Forms W-2, 1099, K-1, brokerage statements, closing statements, and similar records).
- Tax return information: any information you furnish, or that we prepare or obtain, in connection with the preparation of your tax return, as defined in Treasury Regulation §301.7216-1(b)(3). This includes your identity as our client.
- Household and dependent information: names, dates of birth, Social Security numbers, childcare and education expenses, and similar information about your spouse, dependents, and other household members, which you provide to us in your capacity as their parent, guardian, or authorized representative.
- Business client information: entity formation documents, ownership and beneficial ownership records, payroll records, and financial statements.
- Information from third parties: IRS and state tax authority account transcripts obtained under an authorization you sign (Form 2848 or Form 8821), records from your prior tax preparer where you have authorized their release, and information from third parties you direct us to contact.
- Website information: information submitted through contact or intake forms, and standard technical data such as IP address, device and browser type, referring page, and pages visited, recorded in server and security logs by our website hosting, authentication, and bot-protection providers. Our website does not set advertising or analytics cookies.
2. How We Use Your Information
We use the information we collect to:
- Prepare and file federal, state, and local tax returns and related filings;
- Provide tax planning, representation, and advisory services;
- Communicate with you about your account, engagement, filings, deadlines, and notices;
- Verify your identity and protect against fraud, identity theft, and unauthorized account access;
- Comply with legal, regulatory, and professional obligations, including IRS, Circular 230, and state licensing requirements;
- Establish, exercise, or defend legal claims, including responding to a professional liability claim or regulatory inquiry;
- Bill for and collect fees for our services; and
- Improve our services and website.
3. Special Protections for Your Tax Return Information
Federal law gives your tax return information protection beyond that afforded to ordinary personal information. We treat this as the most important commitment in this Policy.
3.1 The Section 7216 Rule
We do not use or disclose your tax return information for any purpose other than preparing and filing your return and providing the services you have engaged us to perform, except where the disclosure is expressly permitted by Treasury Regulation §301.7216-2 without consent, or where you have given us specific, separate, written consent that complies with Treasury Regulation §301.7216-3 and Revenue Procedure 2013-14. Unauthorized disclosure of tax return information is a federal crime under IRC §7216.
3.2 What a Valid Consent Looks Like
If we ever ask you to authorize a use or disclosure beyond return preparation, that request will:
- Appear on its own separate document — never bundled into an engagement letter, this Policy, or a click-through agreement;
- Identify the specific information to be disclosed, the specific recipient by name, and the purpose;
- Require your affirmative signature. Silence, inaction, or failure to opt out will never be treated as your consent;
- State how long the consent lasts, and default to one year if no period is specified; and
- Be signed and dated by you before any disclosure occurs. You will receive a copy.
You are never required to sign a consent in order to have us prepare your return.
3.3 No Offshore Preparation
We do not send your tax return information to any tax return preparer, service bureau, or contractor located outside the United States. If this ever changes, we will obtain your specific written consent in advance, in the enhanced form required by Treasury Regulation §301.7216-3(a)(3)(i), before any such disclosure.
3.4 Artificial Intelligence and Automated Tools
We do not upload your personal information or tax return information to any artificial intelligence service, and we do not use consumer or public AI products in our practice. Where we use AI-assisted tools, we do so only under enterprise agreements with the provider that contractually prohibit the use of our inputs to train the provider’s models. We do not make decisions about your tax position by automated means without professional review.
3.5 Practitioner Privilege
As Enrolled Agents, our communications with you regarding tax advice may be protected by the federally authorized tax practitioner privilege under IRC §7525. This privilege has real limits: it does not apply to tax return preparation itself, to criminal matters, to most state tax proceedings, or to communications regarding the promotion of tax shelters, and it can be waived if the communication is disclosed to a third party. If privilege is important to a particular matter, tell us before you share the information so we can advise you on how to preserve it.
4. How We Share Information
We do not sell your personal or tax return information, and we have not done so at any time. We may share information only in the following circumstances:
- Service providers: With vetted third parties who support our operations — such as tax preparation software providers, secure client portal and document management platforms, e-file transmission services, payment processors, website hosting, authentication, and bot-protection providers, and IT support — under written confidentiality and data security obligations, and only to the extent necessary to perform their function.
- Legal requirements: When required by law, subpoena, summons, court order, or to respond to a valid request from the IRS or a state taxing authority, or where necessary to report a crime, in each case as permitted by Treasury Regulation §301.7216-2.
- Our own professional advisors: With our attorneys, professional liability insurer, or peer reviewers, where permitted by Treasury Regulation §301.7216-2, and subject to confidentiality.
- With your consent: When you have provided specific written authorization identifying the named third party — for example, a mortgage lender, financial advisor, or attorney.
- Business transitions: In the event of a merger, acquisition, or sale of practice assets, we may transfer only limited contact information — name, mailing address, email address, phone number, entity type, and return form number — as expressly permitted by Treasury Regulation §301.7216-2(n). Your tax returns, workpapers, and other tax return information would not be transferred to any successor firm without your specific written consent. A general notice or an unanswered letter would not substitute for that consent.
We do not share your nonpublic personal information with unaffiliated third parties for their own marketing purposes. See Appendix A for the federally prescribed summary of our sharing practices.
5. How We Protect Your Information
Consistent with our obligations under the FTC Safeguards Rule (16 C.F.R. Part 314) and IRC §7216, we maintain a Written Information Security Program overseen by a designated Qualified Individual, and we implement administrative, technical, and physical safeguards including:
- Encryption of client information in transit over external networks and at rest in our systems;
- Multi-factor authentication for access to systems containing client information;
- Secure, access-controlled storage of physical and electronic client records;
- Role-based access limiting staff to the client information they need to perform their work;
- Written due diligence on, and contractual security obligations for, every service provider with access to client information;
- Periodic review of the program and of the risks to client information as our technology and tools evolve.
No method of electronic storage or transmission is completely secure, and we cannot guarantee absolute security. We can and do commit to maintaining the safeguards federal law requires of us.
6. Data Incidents and Notification
If we determine that your unencrypted personal information has been acquired, or is reasonably believed to have been acquired, by an unauthorized person, we will notify you in the most expedient time possible and without unreasonable delay, consistent with the requirements of Minnesota Statutes §325E.61 and the breach notification laws of the state in which you reside.
We will also make the reports required of us as a tax professional and as a financial institution, which may include notification to the Federal Trade Commission, the IRS Stakeholder Liaison, state taxing authorities, and state attorneys general. Our notice to you will describe what happened, what information was involved, what we are doing, and the steps you can take — including obtaining an IRS Identity Protection PIN and filing Form 14039 where appropriate.
7. Data Retention
We retain client tax and financial records in accordance with IRS recordkeeping requirements, applicable statutes of limitation, and our professional obligations as Enrolled Agents. Our general practice is:
- Tax returns and supporting workpapers: at least three years, as required by IRC §6107(b), and longer where we determine a longer period is appropriate — for example, to accommodate the six-year assessment period that applies where income is substantially understated.
- Refundable credit due diligence records (Form 8867 and supporting documentation): at least three years, as required by IRC §6695(g).
- Records with continuing tax significance: basis records, depreciation schedules, carryforwards, entity formation and ownership documents, retirement plan records, and like-kind exchange documentation — retained for as long as the record remains relevant to your tax position, because these affect returns long after the year in which they arise.
- Engagement and billing records: as long as needed for our business, legal, and professional purposes.
Longer retention applies where required by law, requested by you, or necessary in connection with an audit, examination, claim, or legal proceeding. After the applicable period, we securely destroy records containing personal information.
These are our retention floors, not a substitute for your own records. You should retain your own copies of all returns and supporting documentation indefinitely. We encourage you to download and store your documents from our client portal.
8. Your Choices and Rights
- You may request a copy of any tax return we prepared for you and of the records you provided to us. Under Treasury Circular No. 230 §10.28, we will promptly return your original records to you on request, even if fees remain outstanding. Documents we prepared may be withheld pending payment of fees for those documents where state law permits, as allowed by Circular 230 §10.28(b).
- You may withdraw a prior consent to use or disclose tax return information, prospectively, by notifying us in writing. Withdrawal does not affect disclosures already made in reliance on the consent.
- You may opt out of non-essential marketing communications at any time by contacting us or using the unsubscribe link in any marketing email. You will continue to receive communications necessary to your engagement.
- You may ask us to correct inaccurate contact information we hold about you. Where information appears on a filed return, correction may require an amended return, which we will discuss with you.
8.1 How to Raise a Concern
Contact us first — we would rather hear about a problem directly. You also have these external routes:
- Treasury Inspector General for Tax Administration (TIGTA), if you believe your tax return information has been disclosed or used improperly in a manner unauthorized by law or without your permission: 1-800-366-4484, or complaints@tigta.treas.gov.
- IRS Office of Professional Responsibility, regarding the conduct of an Enrolled Agent, using Form 14157.
- Federal Trade Commission, at reportfraud.ftc.gov, regarding privacy or data security practices.
- Minnesota Attorney General’s Office, regarding consumer protection or data breach matters.
9. State Privacy Rights
Most information we hold about you is subject to the GLBA and is therefore exempt from state consumer privacy statutes, including the Minnesota Consumer Data Privacy Act. Some information we hold — for example, data collected from website visitors who never become clients, or from job applicants — may not be GLBA-covered.
Where a state privacy law gives you rights we are required to honor, we will honor them to the extent that law applies to us and to the information at issue. Depending on your state of residence, those rights may include the right to know what personal information we hold, to obtain a copy, to correct inaccuracies, to request deletion, and to appeal a denial of a request. We do not sell personal information, do not share it for cross-context behavioral advertising, and do not use it for profiling that produces legal or similarly significant effects.
To exercise a state privacy right, contact us using the information in Section 15. We will verify your identity before acting on a request, and will respond within the period your state’s law requires. We will not discriminate against you for exercising a privacy right. Note that our ability to delete information is limited by the retention obligations described in Section 7.
10. Electronic Communications
Email is not a secure channel. Ordinary email is not encrypted end-to-end and can be intercepted, misdirected, or spoofed. We ask that you send documents containing Social Security numbers, financial account numbers, or other sensitive information through our secure client portal rather than by email, and we will send such documents to you the same way.
If you nonetheless choose to send sensitive information to us by unencrypted email or text message, you accept the risks of that channel. We will not ask you to send a Social Security number, password, or bank account number by email, and we will never ask you to wire funds based on emailed instructions. If you receive a message that appears to be from us making such a request, treat it as fraudulent and call our office at the number in Section 15 to verify.
If you provide a mobile number and opt in to text messages, we may send you appointment, deadline, and document-request messages. Message and data rates may apply. Reply STOP to any message to opt out, or HELP for assistance. We do not send marketing text messages without your separate express written consent, and we do not share mobile numbers with third parties for their marketing.
11. Website, Cookies, and Analytics
Our website does not use advertising cookies, analytics cookies, or cross-site tracking technologies. We do not use Google Analytics, tag managers, or social media pixels, and we do not permit third parties to collect information about your activity across other websites through our site. The site stores a single value in your browser recording your display theme preference.
Our website uses Google reCAPTCHA and Google Firebase App Check to confirm that requests come from legitimate users and to protect against automated abuse, and our website and client authentication are hosted on Google Firebase infrastructure. These services collect device and behavioral signals — including IP address, browser characteristics, and interaction patterns — and transmit them to Google for security analysis. This is a security function, not advertising, and this data is not used to build a marketing profile of you. Your use of our site is subject to Google’s Privacy Policy (policies.google.com/privacy) and Terms of Service (policies.google.com/terms). Our hosting and security providers maintain server logs that include IP addresses.
You can control cookies through your browser settings. We do not sell or share your personal information as those terms are defined under applicable state privacy laws. Because we do not engage in that activity, Global Privacy Control and similar opt-out signals do not change how we handle your information — you are effectively opted out at all times. Disabling cookies may affect certain website features but will not affect our ability to provide tax services to existing clients.
Our website may link to third-party sites, including the IRS and state tax authorities. We are not responsible for the privacy practices of those sites, and this Policy does not apply to them.
12. Children’s and Dependents’ Information
Our services are directed to adults, and our website is not directed to children. We do not knowingly collect personal information directly from children under 13 through our website.
We do collect information about minor children — including names, dates of birth, and Social Security numbers — where a parent, guardian, or authorized representative provides it to us in connection with a tax return claiming those children as dependents or reporting their income. We collect that information from the adult client, not from the child, and we protect it under the same safeguards and the same §7216 restrictions that apply to all tax return information.
13. Prospective, Former, and Deceased Clients
- Prospective clients: If you contact us but do not engage us, we retain your inquiry and any documents you provided only as long as needed to respond, and then securely destroy them. Information you provide during a consultation is treated as confidential whether or not you become a client.
- Former clients: We continue to apply this Policy to your information after our engagement ends, for as long as we retain it.
- Deceased clients: We release tax return information of a deceased client only to a personal representative, executor, trustee, or other fiduciary who provides documentation of authority, consistent with IRC §6103(e) and applicable state law.
14. Changes to This Policy
We may update this Privacy Policy to reflect changes in our practices or in legal requirements. The Version and Last Updated fields above reflect the current revision.
We will post any revised Policy on our website. If we make a material change — in particular, any change to the information-sharing practices described in Appendix A — we will deliver a revised notice directly to current clients by mail, secure portal, or email before the change takes effect, and not rely on website posting alone.
15. Contact Us
If you have questions about this Privacy Policy, wish to exercise a right described in it, or want a paper copy, please contact us:
Sapere LLC — Attn: Qualified Individual (Data Security)801 Twelve Oaks Center Dr, Suite 809
Wayzata, MN 55391
Email: info@saperetax.com
Phone: (952) 295-8945
Website: saperetax.com
Federal Privacy Notice (GLBA Model Form)
Rev. August 2026. This notice follows the model form prescribed in Appendix A to 16 C.F.R. Part 313. Deliver a copy to every client at the start of the engagement and retain proof of delivery.
- Why?
- Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
- What?
- The types of personal information we collect and share depend on the services you have with us. This information can include: Social Security number and income; account balances and transaction history; assets, investment holdings, and business financial records; and employment and dependent information. When you are no longer our client, we continue to handle your information as described in this notice.
- How?
- All financial companies need to share clients’ personal information to run their everyday business. In the table below, we list the reasons financial companies can share personal information, the reasons Sapere chooses to share, and whether you can limit that sharing.
| Reasons we can share your personal information | Does Sapere share? | Can you limit this sharing? |
|---|---|---|
| For our everyday business purposes — such as to prepare and file your returns, maintain your account, respond to court orders, subpoenas, and legal investigations, or respond to the IRS or a state taxing authority | Yes | No |
| For our own marketing purposes — to offer our tax and advisory services to you | Yes | No |
| For joint marketing with other financial companies | No | We don’t share |
| For our affiliates’ everyday business purposes — information about your transactions and experiences | No | We don’t share |
| For our affiliates’ everyday business purposes — information about your creditworthiness | No | We don’t share |
| For our affiliates to market to you | No | We don’t share |
| For nonaffiliates to market to you | No | We don’t share |
Questions? Call us at (952) 295-8945, email info@saperetax.com, or visit saperetax.com/privacy.
Who We Are and What We Do
- Who is providing this notice?
- Sapere LLC, a Minnesota limited liability company providing tax preparation, tax planning, and advisory services.
- How does Sapere protect my personal information?
- To protect your personal information from unauthorized access and use, we use security measures that comply with federal law and with the FTC Safeguards Rule. These measures include computer safeguards, encryption, multi-factor authentication, access controls, and secured files and buildings. We maintain a Written Information Security Program and a designated Qualified Individual responsible for it.
- How does Sapere collect my personal information?
- We collect your personal information, for example, when you engage us for tax or advisory services, provide us with tax documents, complete an intake questionnaire, authorize us to obtain IRS or state transcripts, or give us your contact information. We also collect information from others, such as the IRS, state taxing authorities, your prior tax preparer, or third parties you have authorized.
- Why can’t I limit all sharing?
- Federal law gives you the right to limit only: sharing for affiliates’ everyday business purposes (information about your creditworthiness); affiliates from using your information to market to you; and sharing for nonaffiliates to market to you. State laws and individual companies may give you additional rights to limit sharing. See the State Privacy Rights section of our full Privacy Policy.
Definitions
- Affiliates
- Companies related by common ownership or control. Sapere has no affiliates.
- Nonaffiliates
- Companies not related by common ownership or control. Sapere does not share your information with nonaffiliates so they can market to you. We do use service providers — such as tax software, secure portal, and e-file transmission providers — who act only on our instructions and under written confidentiality and security obligations.
- Joint marketing
- A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Sapere does not engage in joint marketing.
Other Important Information
Because Sapere does not share your personal information in any way that federal law allows you to limit, no opt-out election is required or offered. If our sharing practices ever change, we will deliver a revised notice and an opt-out method before the change takes effect.
Your tax return information receives additional protection under IRC §7216 that is separate from, and greater than, the protections described in this notice. See Section 3 of our full Privacy Policy.
