Privacy Policy

Effective Date: 07/15/2026

Last Updated: 07/15/2026

This Privacy Policy explains how Gabby Dade & Co, LLC dba Sumvera Advisory ("Sumvera Advisory," "Firm," "we," "us," or "our") collects, uses, shares, stores, and protects personal information when you visit sumveraadvisory.com, contact the Firm, book an appointment, pay for a consultation, upload documents, use the secure portal, or otherwise interact with us online.

This Policy is written as a national baseline for a U.S.-based firm serving clients in multiple states. Privacy obligations and consumer-rights requirements often apply based on where the consumer resides and whether a state law applies to the Firm's activities or thresholds, not simply where the Firm is located.

Because privacy requirements can vary by state, additional notices or rights may apply depending on where a user lives, including under Texas privacy law, California privacy law, and other state comprehensive privacy laws, if applicable to the Firm's activities and thresholds.

1. Information We Collect

Depending on how you interact with the website or Firm, we may collect:

A. Contact and identity information

Name; email address; phone number; mailing address; business name; other identifiers you choose to provide.

B. Scheduling and communication information

Appointment details; consultation subject matter; call recordings; call transcripts; messages sent through forms, portal, SMS, email, or voicemail.

C. Payment and transaction information

Billing details; payment status; transaction history; limited payment-related information provided by our payment processors.

The Firm does not typically store full payment card numbers on its own systems unless specifically stated. Payment processing is generally handled by third-party providers.

D. Tax, financial, and business information

If you become a client or submit information for evaluation, we may collect tax return information, government-issued identifiers, income information, bookkeeping records, payroll information, entity information, ownership information, banking or financial records, and related supporting documentation.

E. Device and website usage information

IP address; browser type; device identifiers; operating system; referral pages; site activity and interactions; cookies and similar tracking data, if and when used.

F. Sensitive information

Some information handled by the Firm may be sensitive, such as Social Security numbers, tax return data, financial account information, or information relating to IRS matters. Please do not submit sensitive information through general website forms unless directed to do so through a secure process.

2. How We Use Information

We may use personal information to:

• Operate, maintain, and improve the website.
• Schedule appointments and provide consultations.
• Communicate with you about inquiries, bookings, services, invoices, and support.
• Process payments and prevent fraud.
• Evaluate whether the Firm can accept an engagement.
• Provide tax, bookkeeping, advisory, formation, or representation services after engagement.
• Create, maintain, and review records, notes, transcripts, and internal workflow materials.
• Train staff, monitor service quality, and improve workflows.
• Comply with legal, regulatory, ethical, insurance, and recordkeeping obligations.
• Protect the security, rights, property, or safety of the Firm, clients, and others.
• Enforce our Terms and other agreements.

We may also use de-identified or aggregated information for internal analytics, reporting, or process improvement where permitted by law.

3. How We Share Information

We do not sell personal information in the ordinary commercial-broker sense. We may share information as reasonably necessary in the following situations:

A. Service providers and subprocessors

We use third-party service providers to help operate the website and business. These may include providers for: CRM and practice management; online scheduling; payment processing; email and communications; secure portal and document exchange; cloud storage and document management; call recording and transcription; workflow automation; analytics and website performance, if enabled; AI-assisted note-taking, research, or workflow support.

Based on the Firm's current operations, these may include SuiteDash, Chase, QuickBooks Online, Google Workspace, MyTAXPrepOffice, Pabbly, and other similar vendors actually used in the Firm's workflows.

B. Workflow automation tools

The Firm may use workflow automation tools, such as Pabbly, to organize lead and contact information, move data between business systems, and support internal operations. Based on the current workflow, Pabbly may be used to move contact details such as names and email addresses into Google Sheets or other internal tracking systems. These automations should not be used for tax return information unless separately reviewed and approved under the Firm's compliance procedures.

C. AI and transcription tools

The Firm may use AI-assisted tools and transcription services to support note-taking, quality control, document handling, research, workflow efficiency, and internal operations.

The Firm's current practice is that client tax return information and personally identifiable client data are not entered into consumer AI tools used for general research or drafting. The Firm may also use approved commercial AI tools under business terms and applicable data-protection arrangements for limited internal support workflows, subject to internal restrictions and separate review of any workflow that could implicate tax return information rules.

D. Professional coordination and referrals

When appropriate and authorized, the Firm may coordinate with attorneys, other accountants, bookkeepers, financial professionals, or similar service providers. Legal services, if needed, are referred to licensed attorneys and are not provided by the Firm itself.

E. Legal and compliance disclosures

We may disclose information when required or appropriate to comply with law, regulation, subpoena, court order, tax authority request, professional standards, insurance obligations, or to protect legal rights and security.

F. Business transfers

If the Firm undergoes a merger, acquisition, financing, reorganization, sale of assets, or similar transaction, information may be disclosed as part of that process, subject to applicable confidentiality and legal restrictions.

G. With your direction or consent

We may share information with other parties when you ask us to do so or authorize us in writing.

4. Tax Return Information and Sensitive Data

The Firm handles tax return information and sensitive personal information with heightened care. Tax return information may be subject to federal confidentiality rules, including Internal Revenue Code section 7216 and related regulations, which can restrict how a tax return preparer may use or disclose that information beyond tax return preparation without specific taxpayer consent.

The distinction between a use of tax return information and a disclosure of tax return information matters, and different rules may apply depending on the purpose, the recipient, whether the activity is part of tax return preparation, and whether data is shared with a provider inside or outside the United States.

Because these rules are highly fact-specific, any separate taxpayer consent needed for tax return information will be requested in a standalone form or workflow where required, and not solely through acceptance of this Privacy Policy.

5. Cookies and Tracking Technologies

The website does not currently use non-essential analytics cookies, advertising pixels, or similar non-essential tracking technologies, based on the current information provided by the Firm.

If the Firm later activates analytics, advertising, remarketing, session-replay, or other non-essential tracking technologies, the Firm will update this Privacy Policy and implement any required cookie banner, consent-management, or opt-out controls before those tools are activated.

If non-essential tracking tools are later added and applicable law requires it, users will be able to manage those preferences through a visible Manage Privacy Preferences or similar control.

If a recognized Global Privacy Control (GPC) signal is received and applicable law requires the Firm to treat it as a valid opt-out signal for sale, sharing, or targeted advertising, the Firm will honor that signal to the extent those activities are triggered by the technologies then in use.

6. Your Privacy Rights

Depending on your state of residence and applicable law, you may have some or all of the following privacy rights under U.S. state comprehensive privacy laws:

• Access / Right to know: Request confirmation of whether we process your personal information and request access to it.
• Correction: Request correction of inaccurate personal information.
• Deletion: Request deletion of personal information, subject to legal exceptions.
• Portability: Request a copy of certain personal information in a portable and, where required, readily usable format.
• Opt-out: Opt out of the sale of personal information, the sharing of personal information for cross-context behavioral advertising, and/or targeted advertising, where those concepts apply under the relevant state law.
• Appeal: Appeal a denial of your privacy request, where state law provides that right.

These rights are not absolute and may be limited by legal exceptions, professional obligations, identity-verification requirements, tax recordkeeping duties, fraud prevention needs, or other lawful reasons.

To exercise any applicable privacy rights, you may contact the Firm by:

Email: legal@sumveraadvisory.com
Online: sumveraadvisory.com/privacy
Phone: 469-443-4048

Please state that your request is a privacy rights request and describe the right you want to exercise. The Firm may need to verify your identity before acting on the request. Authorized agents may submit requests on behalf of consumers where permitted by law, subject to verification of authority.

The Firm will respond within the time required by applicable law. If a request is denied in whole or in part and state law provides a right to appeal, the response will describe how to submit an appeal.

7. Global Privacy Control

If your browser or extension sends a recognized Global Privacy Control (GPC) signal, the Firm will treat that signal as a request to opt out of sale, sharing, or targeted advertising, where required by applicable law and to the extent those activities are in use.

Because the Firm does not currently use non-essential analytics or advertising trackers, this section is included mainly as a future-facing compliance statement and should be revisited before those technologies are turned on.

8. Data Retention

We retain information for as long as reasonably necessary for the purposes described in this Policy, including to provide services, maintain records, comply with legal or professional obligations, resolve disputes, enforce agreements, and protect the Firm.

Retention periods may vary depending on the type of information, whether you become a client, applicable IRS or state requirements, insurance recommendations, litigation holds, and operational needs.

9. Security

We use administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, loss, misuse, or alteration. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

Please use caution when sending information online and follow any secure-upload instructions we provide.

If the Firm becomes aware of a security incident affecting personal information, the Firm will investigate and provide any notice required by applicable law.

10. Children's Privacy

The website is not directed to children under 13, and the Firm does not knowingly collect personal information from children through the public website except where a parent, guardian, or taxpayer provides information in connection with legitimate tax or related services.

11. Third-Party Websites

The website may contain links to third-party websites or services. We are not responsible for their privacy practices, content, or security. Please review their policies before providing information to them.

12. California and State-Law Review Note

If the Firm later enables technologies or workflows that trigger state-specific requirements, including California notice-at-collection, category tables, service-provider or contractor descriptions, sale/sharing analysis, or universal opt-out handling, this Policy should be updated before launch of those features.

13. Changes to This Policy

We may update this Privacy Policy from time to time. The updated version will be posted with a revised "Last Updated" date. Material changes may also be communicated by additional notice where appropriate.

14. Contact Us

For questions, privacy requests, or concerns, contact:

Gabby Dade & Co, LLC dba Sumvera Advisory
Legal and privacy contact: legal@sumveraadvisory.com
Phone: 469-443-4048
Online request page: sumveraadvisory.com/privacy

Note: The email above is intended for legal notices and privacy-rights requests. General service inquiries should be routed through the Firm's booking and intake workflow.