Privacy Policy

1. Who We Are

The Smart Guides LLC is a dental practice consulting and technology company headquartered in Wesley Chapel, Florida. We provide two primary offerings:

• The TSG Method — a structured consulting engagement that installs a business operating system in dental practices through phased advisory services, team development, and strategic planning.
• TSG Momentum — a Software-as-a-Service (SaaS) platform available at tsgmomentum.com that provides dental practices with KPI tracking, financial intelligence, structured meeting frameworks, practice management system integrations, team assessments, and 90-day execution management.

2. Information We Collect

2.1 Information You Provide Directly

We collect information you voluntarily submit to us, including:

• Contact information: name, email address, phone number, practice name, and mailing address submitted through contact forms, booking requests, or account registration.
• Business Value Health Assessment responses: answers to our diagnostic assessment questions about your practice's operations, financials, team structure, and strategic goals.
• Consulting engagement information: information shared during strategy calls, onboarding, and ongoing advisory sessions, including practice financials, team structure, operational data, and growth goals.
• TSG Momentum account information: username, password (encrypted), practice information, billing details, and user preferences.
• Financial data you upload: accounting software exports (CSV files) that you voluntarily upload to TSG Momentum to enable financial KPI tracking.
• Team assessment data: responses to DiSC and Kolbe A assessments completed by you or your team members through our platform or affiliated assessment providers.
• Communications: emails, support tickets, chat messages, and any other communications you send to us.

2.2 Information We Collect Automatically

When you visit our website or use TSG Momentum, we automatically collect:

• Device and technical information: IP address, browser type and version, operating system, device identifiers, and screen resolution.
• Usage data: pages visited, features used, time spent, click patterns, and navigation paths within our website and platform.
• Session data: login times, session duration, and activity logs within TSG Momentum.
• Cookies and similar technologies: see Section 6 for our full cookie policy.

2.3 Information We Receive From Third Parties

We may receive information about you from third-party sources, including:

• Practice Management System (PMS) integrations: when you connect your dental practice management system to TSG Momentum through our DentalBridge API integration, we receive operational and scheduling data that you authorize us to access. We support integrations with more than 20 PMS platforms. The specific data received depends on the permissions you grant during integration setup.
• Assessment providers: DiSC and Kolbe assessment results returned by Wiley (Everything DiSC) and Kolbe Corp when your team members complete assessments linked to your TSG account.
• Payment processors: transaction confirmation data from our payment processor (Stripe). We do not receive or store your full payment card numbers.
• Referral sources: if you were referred to us by a partner or affiliate, we may receive your name and contact information from that referral source.

2.4 A Critical Note: We Are Not a HIPAA Business Associate for Patient Data

The Smart Guides and TSG Momentum are practice management and operational tools. We are not designed to receive, store, or process Protected Health Information (PHI) as defined under HIPAA. Our PMS integrations through DentalBridge are scoped to operational, scheduling, and production data — not patient clinical records or personally identifiable patient health information.

If you are a dental practice using TSG Momentum, you remain the data controller for any patient information within your practice management system. You are responsible for ensuring that any data you share with or through our platform does not include PHI beyond what is operationally necessary and authorized. We strongly recommend reviewing your own HIPAA compliance obligations with qualified legal counsel.

If you believe PHI has been inadvertently transmitted to us, contact us immediately at mina+privacy@thesmartguides.com.

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1 Delivering Our Services

• Creating and managing your TSG Momentum account.
• Delivering consulting services, strategy calls, and Results Review sessions.
• Processing and displaying your financial and operational KPIs within TSG Momentum.
• Facilitating PMS integrations and returning operational data to your dashboard.
• Administering team assessments and returning results to authorized account holders.
• Conducting and returning results from the Business Value Health Assessment.

3.2 Communications

• Responding to your inquiries, support requests, and feedback.
• Sending service-related notifications such as account updates, billing confirmations, and platform alerts.
• Sending marketing communications, newsletters, and practice growth content — only where you have opted in or where we have a legitimate interest. You may opt out at any time (see Section 8).

3.3 Platform Improvement

• Analyzing usage patterns to improve the functionality, reliability, and design of TSG Momentum.
• Diagnosing and resolving technical issues.
• Developing new features and service offerings informed by how our users engage with the platform.

3.4 Business Operations

• Processing payments and managing billing relationships.
• Maintaining records required for legal, tax, and accounting purposes.
• Enforcing our Terms of Service and other agreements.
• Protecting against fraud, unauthorized access, and security threats.

3.5 Legal Compliance

• Complying with applicable laws and regulations, including Florida law and federal requirements.
• Responding to lawful requests from government authorities or courts.

4. Legal Basis for Processing

We process your personal information based on the following legal grounds:

• Contract performance: processing necessary to fulfill our consulting engagements, TSG Momentum subscriptions, and assessment services you have contracted with us.
• Legitimate interests: processing necessary for our legitimate business interests, including platform security, fraud prevention, service improvement, and marketing to existing clients — where those interests are not overridden by your rights.
• Consent: where you have given explicit consent, such as opting in to marketing communications or authorizing specific data integrations.
• Legal obligation: processing required to comply with applicable laws and regulations.

5. How We Share Your Information

We do not sell your personal information. We do not share your information with third parties for their own marketing purposes. We share information only in the following circumstances:

5.1 Service Providers

We work with trusted third-party vendors who process data on our behalf to deliver our services. These providers are contractually bound to protect your data and may only use it as directed by us. Current categories of service providers include:

• Cloud hosting and infrastructure (platform hosting and data storage).
• Payment processing (Stripe — processes billing transactions; does not receive full card data from us).
• Email and communication platforms (for transactional and marketing communications).
• Assessment providers (Wiley/Everything DiSC and Kolbe Corp — for assessment administration and results delivery).
• Analytics tools (for website and platform usage analysis — see Section 6).
• Customer relationship management software (for managing client engagement records).

5.2 Practice Management System Integration Partners

When you authorize a PMS integration through DentalBridge, data is exchanged between your practice management system and TSG Momentum. The scope of that exchange is limited to what you explicitly authorize. We do not share that data with any party other than you and the infrastructure providers necessary to deliver the integration.

5.3 Assessment Providers

When your team members complete DiSC or Kolbe assessments through our platform, their responses are transmitted to and processed by the respective assessment providers (Wiley and Kolbe Corp). Those providers operate under their own privacy policies, which govern how they handle assessment data. Results are returned to your TSG account and accessible only to authorized account administrators.

5.4 Business Transfers

If The Smart Guides LLC is acquired, merged, or transfers all or a portion of its assets, your information may be transferred as part of that transaction. We will notify you of any such change via email or a prominent notice on our website and will describe your options at that time.

5.5 Legal Requirements

We may disclose your information if required to do so by law, court order, or government authority, or if we believe in good faith that disclosure is necessary to protect our rights, prevent fraud, or protect the safety of our users or the public.

6. Cookies and Tracking Technologies

Our website and TSG Momentum use cookies and similar technologies to enable core functionality, analyze usage, and improve your experience.

6.1 Types of Cookies We Use

• Essential cookies: required for the website and platform to function. These cannot be disabled without breaking core features such as login sessions and security protections.
• Analytics cookies: used to understand how visitors use our site and platform, which pages are most visited, and where users experience friction. We use this data to improve our services.
• Marketing cookies: used to track the effectiveness of our marketing efforts and, where you have consented, to deliver relevant content. These are only activated with your explicit consent.
• Preference cookies: used to remember your settings and preferences within TSG Momentum so you do not have to re-enter them on each visit.

6.2 Your Cookie Choices

When you first visit our website, you will be presented with a cookie consent banner that allows you to accept or decline non-essential cookies. You may update your preferences at any time through your browser settings or by contacting us at mina+privacy@thesmartguides.com.

Please note that disabling certain cookies may affect the functionality of our website or platform.

7. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required by law. Our general retention practices are:

• Active account data: retained for the duration of your TSG Momentum subscription or consulting engagement, plus a reasonable period thereafter to support reactivation or dispute resolution.
• Business Value Health Assessment results: retained for up to three years from the date of completion, or longer if you become an active client.
• Financial and KPI data uploaded to TSG Momentum: retained for the duration of your active subscription. Upon account termination, you may request export of your data prior to deletion.
• Billing and transaction records: retained for seven years from the transaction date to comply with applicable tax and accounting laws.
• Communications and support records: retained for up to three years from the last interaction.
• Marketing contact records: retained until you opt out or request deletion, subject to applicable law.

When data is no longer required, we securely delete or anonymize it.

8. Your Rights and Choices

Depending on your location and applicable law, you may have the following rights with respect to your personal information:

8.1 Access and Portability

You may request a copy of the personal information we hold about you and, where technically feasible, receive it in a portable, machine-readable format.

8.2 Correction

You may request that we correct inaccurate or incomplete personal information we hold about you. TSG Momentum account holders may update most account information directly within the platform.

8.3 Deletion

You may request that we delete your personal information. We will honor deletion requests subject to our obligation to retain certain data for legal, tax, or contractual purposes. Upon verified deletion request, we will remove or anonymize your data within 30 days.

8.4 Opt-Out of Marketing

You may opt out of marketing communications at any time by clicking the unsubscribe link in any email we send, updating your communication preferences in your TSG Momentum account settings, or contacting us directly at mina+privacy@thesmartguides.com. Opting out of marketing does not affect transactional or service-related communications necessary to maintain your account.

8.5 Restriction and Objection

You may request that we restrict how we process your data in certain circumstances, or object to processing based on our legitimate interests where your rights override those interests.

8.6 Withdrawing Consent

Where we process your data based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.

8.7 How to Exercise Your Rights

To exercise any of these rights, contact us at mina+privacy@thesmartguides.com. We will respond to verified requests within 30 days. We may need to verify your identity before processing certain requests to protect your security.

9. Florida Residents — Additional Rights

The Smart Guides LLC is a Florida-based business and complies with the Florida Digital Bill of Rights (FDBR) and applicable provisions of the Florida Unfair and Deceptive Trade Practices Act (FDUTPA). Florida residents have the right to:

• Know what personal data we collect and how it is used.
• Access and correct their personal data.
• Delete their personal data subject to legal retention requirements.
• Opt out of the sale or sharing of their personal data for targeted advertising. We do not sell personal data.
• Not be subject to solely automated decision-making that produces significant legal or similarly significant effects.

To exercise these rights, contact us at mina+privacy@thesmartguides.com with "Florida Privacy Request" in the subject line.

10. Data Security

We implement technical, administrative, and physical safeguards designed to protect your personal information against unauthorized access, loss, misuse, alteration, or destruction. These measures include:

• Encryption of data in transit using TLS/SSL protocols.
• Encryption of sensitive data at rest within our platform infrastructure.
• Role-based access controls limiting who within The Smart Guides can access client data.
• Secure credential storage using industry-standard hashing.
• Regular security reviews of our platform and vendor relationships.

No security system is impenetrable. While we work diligently to protect your information, we cannot guarantee that unauthorized parties will never be able to defeat our security measures. In the event of a data breach that affects your rights or freedoms, we will notify you and applicable authorities as required by law.

11. Third-Party Links and Integrations

Our website and TSG Momentum may contain links to third-party websites, or integrate with third-party services such as practice management systems, assessment platforms, and payment processors. This Privacy Policy applies only to The Smart Guides LLC and TSG Momentum. We are not responsible for the privacy practices of third-party websites or services and encourage you to review their privacy policies before providing any personal information.

12. Children's Privacy

Our services are designed for dental practice owners, operators, and business professionals. We do not knowingly collect personal information from individuals under the age of 18. If we become aware that we have inadvertently collected information from a minor, we will delete it promptly. If you believe a minor has provided us with personal information, contact us at mina+privacy@thesmartguides.com.

13. International Visitors

The Smart Guides LLC is headquartered in the United States and our services are primarily directed at dental practices operating in the United States. If you access our services from outside the United States, please be aware that your information will be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your country. By using our services, you consent to this transfer.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or business operations. When we make material changes, we will:

• Post the updated policy on our website with a revised "Last Updated" date.
• Notify active TSG Momentum subscribers via email or an in-platform notice.

Your continued use of our website or services after the effective date of any changes constitutes your acceptance of the updated Privacy Policy. If you do not agree to the updated terms, you should discontinue use of our services and contact us to close your account.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal information, please contact us:

We will respond to all legitimate privacy inquiries within 30 days.

© 2025 The Smart Guides LLC. All rights reserved.

This Privacy Policy was prepared for The Smart Guides LLC and reflects its specific services and data practices.