Data Processing Policy

Data Processing Policy

Data Processing Policy

TERMS OF SERVICE

Last Updated: February 7, 2026

IMPORTANT: THESE TERMS CONTAIN A MANDATORY ARBITRATION PROVISION AND CLASS ACTION WAIVER. PLEASE READ CAREFULLY.

1. Acceptance of Terms

TGB Holdings Inc. (dba "Team Growth Brokerage," "Company," "we," or "us") provides a Real Estate Operating System, Fintech tools, and Brokerage Services (collectively, the "Platform") via our website teamgrowthbrokerage.com and associated applications.

By accessing the Platform, creating an account, or signing a Service Agreement, you ("User," "Team Leader," or "Agent") agree to be bound by these Terms. If you do not agree, you must immediately stop using the Platform.

2. The Relationship: Brokerage-as-a-Service (BaaS)

Unlike traditional brokerages, TGB operates primarily as a Technology Platform Provider.

  • Independent Contractor Status: You acknowledge that you are an Independent Contractor, not an employee of TGB. Nothing in these Terms creates a partnership, joint venture, or employment relationship. You are responsible for your own taxes, withholdings, and business expenses.

  • The Team Leader as CEO: You acknowledge that TGB provides the infrastructure (License, Banking, Compliance), but you retain sole ownership of your brand, your leads, and your business operations.

3. Account Eligibility & Security

  • Licensure: You represent that you hold a valid, active Real Estate License in your jurisdiction. You must immediately notify us if your license is suspended, revoked, or expires.

  • Credentials: You are responsible for maintaining the confidentiality of your TGB Hub login. Any action taken under your credentials (e.g., approving a commission disbursement) is legally binding on you.

4. SaaS Subscription & Billing

A. Subscription Fees Access to the TGB Platform is governed by your selected Plan (e.g., "Momentum," "Squad," "Scale"). You agree to pay the Recurring Subscription Fees associated with your Plan level.

  • Auto-Renewal: Your subscription will automatically renew at the end of each billing cycle (Monthly or Annual) unless canceled in writing 30 days prior.

  • Seat Limits: Plans are priced based on "Agent Seats." If you add agents beyond your Plan's limit, you agree that we may automatically upgrade your Plan and bill the difference to your file.

B. Transaction Fees In addition to SaaS fees, you agree to pay the Transaction Efficiency Fees as outlined in your Independent Contractor Agreement (ICA). These fees are deducted automatically from commission proceeds via the Closing/Title Company.

C. No Refunds All SaaS fees are non-refundable. There are no refunds for partial months of service or unused "Seats."

D. Payment Failure If your credit card on file fails, we reserve the right to: (i) Suspend your access to the Platform; (ii) Withhold pending commission disbursements until the balance is paid; and (iii) Terminate this Agreement.

5. Financial Products & Rewards programs

A. Momentum Vault Credits "Vault Credits" are promotional loyalty rewards, not cash. They have no cash value until they are vested and redeemed according to Company policy.

  • Forfeiture: If your TGB account is terminated for any reason (voluntary or involuntary) before the Vesting Date, all unredeemed Vault Credits are immediately forfeited.

  • Non-Transferable: Credits cannot be transferred to another brokerage or agent.

B. Channel Partner Program (CPP) The CPP is a SaaS Reseller Program.

  • Active Status Requirement: To receive CPP recurring commissions, you must maintain an Active TGB Subscription in good standing.

  • Termination: If you cancel your subscription or transfer your license to another brokerage, your right to receive future CPP payments terminates immediately. You cannot "vest" into a lifetime income stream while competing against TGB.

C. Fee Arbitrage (RevCapture) You acknowledge that TGB charges a wholesale Platform Fee. Any additional fees you charge to your agents or clients (e.g., "Admin Fee," "Tech Fee") are your sole responsibility to disclose in compliance with RESPA and state laws. TGB acts solely as the payment processor for these fees.

6. Artificial Intelligence (AI) Disclaimers

A. No Legal Advice Our AI tools (Compliance Agents, Contract Parsers) are designed to assist with workflow, not to provide legal advice. An AI "Approval" on a file does not constitute a guarantee that the file is legally perfect.

  • Verification: You are solely responsible for reviewing all contracts, addendums, and AI outputs for accuracy before submission.

B. AI Hallucinations You acknowledge that Large Language Models (LLMs) may occasionally generate incorrect or "hallucinated" data. TGB is not liable for errors in commission calculations or contract drafting generated by AI tools.

7. Electronic Signatures (E-SIGN Consent)

By using the Platform, you consent to transact business electronically. You agree that your electronic signature (or the click of an "Approve" button) on the TGB Hub is the legal equivalent of your manual signature.

8. Intellectual Property & Data Ownership

  • Your Data: You retain ownership of your customer lists (CRM data) and transaction history ("Your Data"). You grant TGB a license to host and process Your Data to provide the Services.

  • Our Tech: TGB retains all rights to the Platform code, the "CompBuilder" logic, the "RevCapture" methodology, and all benchmarking data (anonymized). You may not reverse engineer or copy our SaaS workflows.

9. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW: TGB HOLDINGS INC. SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, OR ANY LOSS OF PROFITS OR REVENUES, WHETHER INCURRED DIRECTLY OR INDIRECTLY.

  • Cap on Liability: Our total liability for any claim arising out of these terms shall not exceed the amount you paid us in the past 12 months.

  • Banking Delays: We are not liable for delays in Real-Time Payments (RTP) caused by third-party banking networks or the Federal Reserve.

10. Indemnification

You agree to defend and indemnify TGB against any claims arising from: (i) Your violation of Real Estate Laws (e.g., Fair Housing, RESPA); (ii) Your breach of these Terms; or (iii) Any disputes between you and your team members regarding commission splits.

11. Dispute Resolution: Arbitration & Class Action Waiver

Binding Arbitration: Any dispute arising under these Terms shall be resolved by binding arbitration administered by the American Arbitration Association (AAA) in accordance with its Commercial Arbitration Rules.

  • Venue: Arbitration shall take place in Chelan County, Washington (or virtually if agreed).

  • Class Action Waiver: You agree to resolve disputes only on an individual basis and waive any right to participate in a class action lawsuit against TGB.

12. Governing Law

These Terms are governed by the laws of the State of Washington, without regard to its conflict of laws principles.

Contact Us

TGB Holdings Inc. 7 N Wenatchee Ave. Suite 300 Wenatchee, WA 98801 support@teamgrowthbrokerage.com

PRIVACY POLICY

Effective Date: February 7, 2026

TGB Holdings Inc. (dba "Team Growth Brokerage," "Company," "we," "our," or "us") respects your privacy. This Privacy Policy describes how we collect, use, and share Personal Data through our digital brokerage platform (the "TGB Operating System"), website, and financial tools (collectively, "Services").

Scope: This policy applies to Team Leaders, Agents, Consumers, and Visitors. References to "Agents" in this Policy mean licensed real estate professionals acting as independent contractors of TGB, not employees.

1. Information We Collect

A. Information You Provide

  • Identity & Verification: Name, email, phone, Real Estate License number, and Driver’s License (for KYC/AML banking compliance).

  • Financial & Tax Data: SSN/EIN for 1099 tax reporting, bank routing numbers for Real-Time Payments (RTP), and credit card details for SaaS billing.

  • Beneficiary Information: If you participate in the Channel Partner Program (CPP), we may collect information about your designated beneficiary to inherit your recurring revenue rights in the event of death, subject to our Terms of Service.

  • Transaction Data: Real estate contracts, commission disbursement authorizations (CDAs), and agent roster data uploaded to the TGB Hub.

B. Information Collected Automatically

  • Usage Data: We collect logs of how you interact with our Dashboards, including "CompBuilder" logic and "RevCapture" settings.

  • AI Interaction Logs: When you use our AI Compliance Agents or Chatbots, we collect the conversation logs, metadata, and inputs to improve the model accuracy.

C. Tracking Technologies

  • Pixels & Analytics: We use cookies, web beacons (Pixels), and Google Analytics to analyze usage and facilitate "Retargeting" advertisements on platforms like Facebook and LinkedIn.

2. Artificial Intelligence (AI) Disclosures

A. Use of AI Tools

TGB Nexus utilizes Artificial Intelligence (including Large Language Models) to automate compliance review, contract parsing, and commission calculations.

  • Not Legal Advice: AI outputs (e.g., a "Green Light" on a file review) are for informational purposes only and do not constitute legal or regulatory advice. You are responsible for verifying the accuracy of AI outputs.

  • No Fair Housing Guarantee: AI models are not foolproof. We do not guarantee that AI outputs are perfectly compliant with the Fair Housing Act or RESPA.

  • Data Usage: We may use anonymized interaction data to train and refine our internal models. We do not use your confidential client data to train public models (like ChatGPT) for general use.

3. Financial Products & "Vault" Data

A. Underwriting & Eligibility

We use your transaction volume, revenue data, and team size to determine your eligibility for specific financial products, including Momentum Vault Credits, Commission Advances, and CPP Payout Tiers.

  • Banking Partners: We share necessary data with our banking partners to facilitate Real-Time Payments and "Wallet" features.

  • RevCapture Analysis: We analyze your P&L data to suggest "Ancillary Fee" opportunities. This data is strictly confidential and used solely to improve your business margins.

4. How We Share Information

We do not sell your Personal Data. We disclose it only as follows:

  • Service Providers: To vendors who support our infrastructure (AWS, Stripe, Skyslope).

  • Legal Compliance: To comply with subpoenas or audits from State Real Estate Commissions (e.g., WA DOL, TREC).

  • Corporate Transactions: If TGB Holdings Inc. is acquired or merges with another entity, your data (including your "Vault" balance and "CPP" rights) may be transferred as a business asset.

5. Your Rights & Choices

A. Marketing & Communications

  • Opt-Out: You may unsubscribe from marketing emails via the link in the footer.

  • Text Messaging (TCPA): By providing your number, you consent to receive business SMS (e.g., "Deal Closed"). Reply STOP to opt out.

B. State-Specific Rights

  • California/Washington Residents: You may have the right to request access to or deletion of your data. Note that state real estate laws often require us to retain transaction files for 3-7 years, which overrides a deletion request.

6. Data Security

We implement enterprise-grade security measures (encryption, access controls) to protect your data. However, no internet transmission is 100% secure. You are responsible for keeping your TGB Hub password confidential.

7. Contact Us

TGB Holdings Inc. dba Team Growth Brokerage 7 N Wenatchee Ave. Suite 300 Wenatchee, WA 98801

Email: support@teamgrowthbrokerage.com Phone: (509) 670-5532

Brokerage Information: Licensed Real Estate Brokerage in Washington. 

DMCA COPYRIGHT POLICY

Effective Date: February 7, 2026

TGB Holdings Inc. (dba "Team Growth Brokerage") respects the intellectual property rights of others and expects its users to do the same. In accordance with the Digital Millennium Copyright Act of 1998, 17 U.S.C. § 512 (the “DMCA”), we will respond promptly to claims of copyright infringement reported to our Designated Agent.

1. Reporting Claims of Copyright Infringement

If you are a copyright owner (or authorized to act on behalf of one) and believe that your work’s copyright has been infringed by content appearing on teamgrowthbrokerage.com or our Platform, please report your notice of infringement to us by providing a written notification that includes all of the following information:

  1. Signature: A physical or electronic signature of a person authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.

  2. Identification of Work: A description of the copyrighted work that you claim has been infringed.

  3. Location: A description of where the material that you claim is infringing is located on our Platform (e.g., the specific URL of the listing or page).

  4. Contact Info: Your address, telephone number, and email address.

  5. Good Faith Belief: A statement that you have a good faith belief that the use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law.

  6. Perjury Statement: A statement that the information in the notification is accurate, and under penalty of perjury, that you are authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.

2. Designated Copyright Agent

Notices of copyright infringement should be sent to:

TGB Holdings Inc. Attn: DMCA Copyright Agent 7 N Wenatchee Ave. Suite 300 Wenatchee, WA 98801

Email: support@teamgrowthbrokerage.com Phone: (509) 670-5532

3. Counter-Notification Procedures

If you believe that material you posted was removed by mistake or misidentification, you may file a counter-notification with us (a "Counter-Notice"). To be effective, a Counter-Notice must be a written communication provided to our Designated Agent that includes substantially the following:

  1. Signature: Your physical or electronic signature.

  2. Identification: Identification of the material that has been removed or to which access has been disabled and the location at which the material appeared before it was removed or access disabled.

  3. Perjury Statement: A statement under penalty of perjury that you have a good faith belief that the material was removed or disabled as a result of mistake or misidentification of the material to be removed or disabled.

  4. Consent: Your name, address, and telephone number, and a statement that you consent to the jurisdiction of the Federal District Court for the judicial district in which the address is located (or if you are outside of the United States, for any judicial district in which TGB Holdings Inc. may be found), and that you will accept service of process from the person who provided the original notification of infringement or an agent of such person.

4. Repeat Infringers

It is our policy in appropriate circumstances to disable and/or terminate the accounts of users who are repeat infringements

1. ACCESSIBILITY STATEMENT

Effective Date: February 7, 2026

TGB Holdings Inc. (dba Team Growth Brokerage) is committed to providing a website that is accessible to the widest possible audience, regardless of technology or ability. We are actively working to increase the accessibility and usability of our website and in doing so adhere to many of the available standards and guidelines.

1. Conformance Status Our goal is to conform to the Web Content Accessibility Guidelines (WCAG) 2.1 at Level AA. These guidelines explain how to make web content more accessible for people with disabilities. Conformance with these guidelines will help make the web more user-friendly for all people.

2. Accessibility Features We are continuously implementing technology improvements to enhance accessibility on our site, including:

  • Alt Text: Ensuring images have alternative text for screen readers.

  • Keyboard Navigation: Ensuring the site can be navigated without a mouse.

  • Contrast Ratios: Maintaining high color contrast for readability.

3. Feedback & Assistance We welcome your feedback on the accessibility of the Team Growth Brokerage website. If you encounter accessibility barriers or need assistance accessing any content, please contact our Accessibility Officer:

  • Email: support@teamgrowthbrokerage.com

  • Phone: (509) 670-5532

  • Mailing Address: 7 N Wenatchee Ave. Suite 300, Wenatchee, WA 98801

We try to respond to feedback within 2 business days.

ACCEPTABLE USE POLICY (AUP)

Last Updated: February 7, 2026

This Acceptable Use Policy ("AUP") outlines the prohibited uses of the Team Growth Brokerage Operating System (the "Platform"). This Policy is in addition to our Terms of Service.

1. No Spam or Unsolicited Outreach You may not use the Platform's email, SMS, or dialer tools to send unsolicited bulk messages ("Spam").

  • Consent Required: You agree that you will only message contacts who have given you explicit prior consent (opt-in) to be contacted.

  • Compliance: You must comply with the CAN-SPAM Act, the Telephone Consumer Protection Act (TCPA), and all carrier guidelines (10DLC).

  • Opt-Outs: You must honor all "STOP" and "Unsubscribe" requests immediately.

2. Prohibited Content You may not use the Platform to upload, post, or transmit:

  • Illegal Content: Material that violates Fair Housing laws or any local, state, or federal law.

  • Harmful Code: Viruses, Trojan horses, or any code designed to disrupt the Platform.

  • Hate Speech: Content that promotes violence or discrimination based on race, religion, gender, or sexual orientation.

3. Violation & Termination We reserve the right to investigate any violation of this AUP. If we determine that you have violated this Policy, we may immediately suspend or terminate your account without refund and refer the matter to law enforcement if necessary.

© 2026 Team Growth Brokerage. All rights reserved.

Equal Housing Opportunity TGB Holdings Inc. (dba Team Growth Brokerage) is a licensed real estate broker and pledges to conduct business in accordance with the Federal Fair Housing Law (Fair Housing Amendments Act of 1988). We do not discriminate on the basis of race, color, religion, sex, handicap, familial status, or national origin. All information provided is deemed reliable but is not guaranteed and should be independently verified.

© 2026 Team Growth Brokerage. All rights reserved.

Equal Housing Opportunity TGB Holdings Inc. (dba Team Growth Brokerage) is a licensed real estate broker and pledges to conduct business in accordance with the Federal Fair Housing Law (Fair Housing Amendments Act of 1988). We do not discriminate on the basis of race, color, religion, sex, handicap, familial status, or national origin. All information provided is deemed reliable but is not guaranteed and should be independently verified.