Privacy Policy

TMG Tools Portal ("the Service") is operated by The Moderate Genius, SFWP US LLC, a company registered in the United States ("we," "us," or "our"). We are the data controller responsible for your personal information. This Privacy Policy describes how we collect, use, and protect your information when you use our platform.

We collect information that you provide directly, that your connected integrations make available, and that is generated through your use of the Service:

• Account information - name, email address, and password (stored in hashed form).
• Consent records - the date and version of the policies you accepted at signup.
• Business data - contacts, deals, and engagement data imported from CRM integrations you connect (e.g., HubSpot, GoHighLevel), as well as transcripts and conversation content you submit or import for analysis through connected meeting providers.
• Usage and session data - functional cookies, local storage for UI preferences, IP address, and action timestamps used for security and platform operations.

We use the information we collect to:

• Provide and operate our AI-powered analysis tools.
• Authenticate your identity and manage access controls.
• Maintain, improve, and secure the platform.
• Send service-related communications and updates.

Legal bases for processing (for users in the European Economic Area):

• Contract performance - processing your account data, business data, and integrations is necessary to provide the Service you signed up for.
• Legitimate interest - we process usage data to maintain security, prevent abuse, and improve the platform. We balance these interests against your rights and freedoms.
• Consent - where required, such as when you explicitly agree to these policies at signup. You may withdraw consent at any time by contacting us.

We use third-party AI services to power the analysis features of the Service. Before text content is sent to an AI provider for analysis, we automatically remove personally identifiable information so the model does not see names, contact details, financial identifiers, or other sensitive data. Data sent to AI providers is processed under their API data usage policies and is not used to train their models.

Depending on which integrations you connect, your data may also be retrieved from or shared with:

• CRM providers - HubSpot, GoHighLevel
• Meeting and transcript providers - Fireflies.ai, Fathom, Read.ai, Otter.ai, Granola, Zoom
• Email delivery services - for sending reports and notifications
• Infrastructure providers - for secure data hosting

We do not sell, rent, or share your personal information with third parties for their marketing purposes.

The Service is hosted in the United States, and our third-party service providers may process data in the United States or other countries outside the European Economic Area (EEA). When your data is transferred outside the EEA, we ensure appropriate safeguards are in place, including standard contractual clauses approved by the European Commission or equivalent measures required by applicable law.

We use only functional session cookies necessary to keep you logged in, and browser local storage for UI preferences such as your theme setting. We do not use analytics, advertising, or third-party tracking cookies.

We retain your data for as long as your account is active or as needed to provide the Service. You may request deletion of your account and associated data at any time by contacting us. We will process deletion requests within 30 days. Upon deletion, your personal information and organization data will be removed, though aggregated, anonymized statistics may be retained for operational purposes.

Depending on your jurisdiction, you may have the right to access, correct, delete, export, or restrict the processing of your personal data, or to object to certain processing. To exercise any of these rights, please contact us using the information in Section 13.

For users in the European Economic Area: you have the right to lodge a complaint with your local data protection supervisory authority if you believe your data has been processed in violation of applicable law.

For California residents: under the CCPA, you may request disclosure of the data we have collected or request its deletion. We do not sell or share your personal information. We will not discriminate against you for exercising these rights.

We implement appropriate technical and organizational measures to protect your information, including encryption of data at rest and in transit, automatic removal of personally identifiable information before AI processing, encrypted storage of integration credentials, organization-level data isolation, role-based access controls, rate limiting, and audit logging.

In the event of a data breach affecting your personal information, we will notify affected users and, where applicable, the relevant supervisory authority without undue delay and within the timeframe required by applicable law (including 72 hours where required under GDPR). Notification will include the nature of the breach, the steps we are taking, and recommended actions you can take to protect yourself.

Our Service is not directed to individuals under the age of 16 (or the applicable age of digital consent in your jurisdiction). We do not knowingly collect personal information from children.

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy with a revised "Last updated" date. Where required by law, we will seek your consent before applying material changes to how we process your data.

If you have questions or concerns about this Privacy Policy or wish to exercise your data protection rights, please contact us at: