Hold My Seat Inc.

1. INTRODUCTION AND SCOPE

Hold My Seat Inc. ("Hold My Seat," "we," "us," or "our") is a corporation incorporated under the laws of the State of Georgia, United States. We operate the platform located at www.holdmyseatinc.com (the "Platform"), which provides a fee-based flight seat reservation and installment repayment service to customers throughout the United States.

We take the privacy of our users seriously. This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you access or use the Platform. It also describes your rights with respect to that information and how you may exercise them.

This Privacy Policy applies to all visitors, registered account holders, and active customers of the Platform. It is incorporated by reference into our Terms and Conditions. By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the data practices described herein.

If you do not agree with this Privacy Policy, you must discontinue your use of the Platform.

2. INFORMATION WE COLLECT

We collect personal information through three channels: information you provide directly, information collected automatically, and information received from third-party service providers.

2.1 Information You Provide Directly

When you register an account, submit a booking request, make a payment, or contact us, we may collect:

• Full legal name
• Date of birth
• Email address
• Phone number
• U.S. billing address
• Payment details, processed exclusively through Stripe, Inc. (Hold My Seat does not store full card numbers on its servers)
• Travel details including passenger name, destination, travel dates, and flight preferences
• Any messages or communications you submit to us through the Platform or by email

2.2 Information Collected Automatically

When you visit or interact with the Platform, we automatically collect certain technical data through cookies and similar technologies, including:

• IP address
• Device type and operating system
• Browser type and version
• Pages viewed and time spent on each page
• Referring and exit URLs
• Approximate geographic location derived from IP address
• Session identifiers and interaction logs

2.3 Information from Third Parties

• Stripe, Inc.: We receive payment status confirmations, transaction identifiers, and fraud risk signals from Stripe in connection with payment processing. We do not receive or retain your full card details.
• Fraud Monitoring Tools: Stripe's built-in fraud prevention features may generate automated risk assessments in connection with payment attempts on the Platform.

3. HOW WE USE YOUR INFORMATION

We use the personal information we collect only for legitimate operational purposes, as follows:

• Service Delivery: To process booking requests, purchase refundable flight tickets on your behalf, manage installment payment schedules, send payment reminders, and release airline confirmation details upon receipt of full payment.
• Identity Verification and Fraud Prevention: To verify user eligibility, authenticate accounts, and detect and prevent fraudulent or unauthorized activity.
• Payment Processing: To collect upfront service fees and installment payments through Stripe, manage failed payments, and process refunds where applicable.
• Customer Communications: To send booking confirmations, payment receipts, failure notices, cancellation confirmations, and responses to support inquiries.
• Legal Compliance: To comply with applicable federal, state, and local laws, respond to lawful authority requests, and maintain records as required.
• Platform Improvement: To monitor performance, analyze usage trends, and improve the user experience.
• Enforcement: To enforce our Terms and Conditions and protect the rights, property, and safety of Hold My Seat and its users.

We do not sell, rent, trade, or license your personal information to any third party for marketing or commercial purposes.

4. LEGAL BASIS FOR PROCESSING

Where applicable under U.S. state privacy laws, we process your personal data on the following bases:

• Contractual Necessity: Processing required to fulfill your booking, manage your installment plan, and deliver our services.
• Legal Obligation: Processing required to comply with applicable federal, state, and local law.
• Legitimate Interests: Fraud prevention, security, and the general improvement and protection of our Platform and business operations, balanced against your privacy interests.
• Consent: Where you have expressly consented to a specific use of your data, such as receiving marketing communications.

You may withdraw consent at any time where consent is the basis for processing, without affecting the lawfulness of processing carried out prior to withdrawal.

5. HOW WE SHARE YOUR INFORMATION

Hold My Seat does not sell or commercially distribute your personal information. We share your data only in the following limited and necessary circumstances:

5.1 Payment Processor

Your payment information is shared with Stripe, Inc. solely for the purpose of processing transactions. Stripe operates as an independent data processor under its own Privacy Policy, available at stripe.com/privacy.

5.2 Airlines and Travel Providers

Your name and travel details are shared with the applicable airline or travel provider as strictly necessary to complete the booking made on your behalf. No additional personal data is shared beyond what is required to issue and manage your reservation.

5.3 Legal and Regulatory Authorities

We may disclose your information to law enforcement agencies, courts, regulators, or government bodies where required by applicable law, court order, or legal process, or where we have a good-faith belief that disclosure is necessary to protect the rights, property, or safety of Hold My Seat, our customers, or the public.

5.4 Professional Advisors

We may share your information with attorneys, auditors, accountants, or other professional advisors where necessary in connection with legal, financial, or regulatory matters, subject to strict confidentiality obligations.

5.5 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of all or substantially all of our assets, your personal information may be transferred to the successor entity. We will provide reasonable notice of any such transfer and the applicable privacy practices going forward.

5.6 With Your Consent

We may share your personal information with a third party where you have provided prior written or electronic consent to such sharing.

We do not share your information with third parties for advertising, behavioral profiling, or any purpose beyond those expressly stated in this Policy.

6. PAYMENT DATA AND STRIPE

All payment transactions on the Platform are processed by Stripe, Inc., a third-party payment processor. Hold My Seat does not collect, store, or have access to your full payment card number, CVV, or bank account credentials. These details are transmitted directly to and stored by Stripe in accordance with Payment Card Industry Data Security Standards (PCI DSS).

By making a payment through the Platform, you agree to Stripe's Terms of Service and Privacy Policy, available at stripe.com. Hold My Seat is not responsible for Stripe's data practices or security measures beyond our contractual obligations with Stripe as a merchant.

7. DATA RETENTION

We retain your personal information for as long as reasonably necessary to fulfill the purposes for which it was collected, subject to the following guidelines:

• Active account and booking data: Retained for the duration of your account and any active booking.
• Transaction and payment records: Retained for a minimum of 7 years from the date of the transaction to satisfy tax, financial, and legal record-keeping obligations.
• Fraud prevention records: Retained for up to 5 years from the date of any flagged, investigated, or terminated account activity.
• Customer communications: Retained for up to 3 years from the date of the communication.
• Inactive accounts: Accounts with no activity for 24 consecutive months may be deactivated, and associated data may be archived or deleted at our discretion.

When your data is no longer required for any lawful purpose, we will securely delete or anonymize it in accordance with our internal data management procedures.

8. DATA SECURITY

Hold My Seat implements commercially reasonable technical, administrative, and physical safeguards to protect your personal information from unauthorized access, loss, misuse, disclosure, alteration, or destruction. Our security measures include:

• SSL/TLS Encryption: All data transmitted between your device and the Platform is encrypted using industry-standard secure protocols.
• PCI DSS Compliant Payment Processing: All payment data is handled by Stripe, which maintains PCI DSS Level 1 compliance. Hold My Seat does not store payment card data on its own servers.
• Access Controls: Access to personal data is restricted to authorized personnel who require it to perform their job functions, on a strict need-to-know basis.
• System Monitoring: Our Platform is monitored for security vulnerabilities, unusual activity, and potential threats on an ongoing basis.

No method of electronic transmission or storage is entirely secure. While we take all reasonable precautions, Hold My Seat cannot guarantee absolute security and encourages you to protect your own account credentials. You should notify us immediately at support@holdmyseatinc.com if you suspect any unauthorized access to your account.

9. DATA BREACH NOTIFICATION

In the event of a data breach that is reasonably likely to result in risk to the rights and freedoms of affected individuals, Hold My Seat will take prompt action to contain and assess the breach. Where required by applicable federal or state data breach notification laws, we will notify affected users and relevant regulatory authorities within the timeframes prescribed by law.

Notification will be provided via the email address associated with your account. It is your responsibility to maintain a current and accessible email address on file with Hold My Seat.

10. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies on the Platform to support core functionality, maintain session security, prevent fraud, and improve user experience. Our use of these technologies is governed in full by our Cookie Policy, which is incorporated into this Privacy Policy by reference.

By using the Platform, you consent to our use of cookies as described in the Cookie Policy. You may manage your cookie preferences at any time through your browser settings, though doing so may limit certain Platform functionality.

11. CHILDREN'S PRIVACY

The Platform is intended exclusively for users who are 18 years of age or older. Hold My Seat does not knowingly solicit, collect, or retain personal information from individuals under the age of 18. Age verification is a condition of account registration.

If we become aware that personal information has been collected from a user under 18 without verified parental or guardian consent, we will take prompt steps to delete that information and close the associated account.

If you believe a minor has registered or submitted personal information through the Platform, please contact us immediately at legal@holdmyseatinc.com.

12. YOUR PRIVACY RIGHTS

Depending on your state of residence, you may have the following rights with respect to your personal information held by Hold My Seat:

12.1 Right to Know and Access

You may request a copy of the personal information we hold about you and information about how it is used and shared.

12.2 Right to Correction

You may request correction of any inaccurate or incomplete personal information in our records.

12.3 Right to Deletion

You may request deletion of your personal information, subject to exceptions where retention is required by law, necessary to complete an active transaction, or needed to enforce our legal rights.

12.4 Right to Opt Out of Sale

Hold My Seat does not sell your personal information. No opt-out is currently required, but should this practice change, this Policy will be updated and an opt-out mechanism will be provided in compliance with applicable law.

12.5 Right to Non-Discrimination

We will not discriminate against you for exercising your privacy rights. Exercising your rights will not result in denial of service, different pricing, or a reduced level of service.

12.6 California Residents

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including the right to limit use of sensitive personal information and the right to correct inaccurate data. To exercise these rights, please contact us using the details in Section 20.

12.7 Residents of Other U.S. States

Residents of Virginia, Colorado, Connecticut, Texas, and other states with applicable consumer privacy legislation may have comparable rights under their respective state laws. Hold My Seat will honor such rights to the extent required by applicable law.

To submit a privacy rights request, please contact us in writing at legal@holdmyseatinc.com. We will acknowledge receipt within 5 business days and respond to verified requests within 45 days, extendable by a further 45 days where reasonably necessary, with notice to you.

13. DO NOT SELL OR SHARE MY INFORMATION

Hold My Seat does not sell, share for cross-context behavioral advertising, or otherwise commercially exploit your personal information. As of the effective date of this Policy, no opt-out mechanism for the sale of personal data is required because no such sale occurs.

Should our practices change, we will update this Policy and provide clear opt-out options in compliance with the CCPA, CPRA, and any other applicable state privacy laws.

14. DO NOT TRACK SIGNALS

Certain web browsers may transmit "Do Not Track" signals to websites. The Platform does not currently alter its data collection or processing practices in response to Do Not Track signals, as there is no uniform industry standard for interpreting such signals. We will monitor regulatory and industry developments in this area and update our practices accordingly.

15. THIRD-PARTY LINKS AND EXTERNAL SERVICES

The Platform may contain links to third-party websites, airline booking portals, or external travel providers. These third-party services are independently operated and governed by their own privacy policies. Hold My Seat does not control, endorse, or assume responsibility for the data practices of any third-party service.

We encourage you to review the privacy policies of any third-party service before submitting personal information to them. Your interactions with third-party services are entirely at your own risk and are not governed by this Privacy Policy.

16. INTERNATIONAL USERS

The Platform is intended for use by residents of the United States only. Hold My Seat does not knowingly solicit users located outside the United States. All personal data collected through the Platform is processed and stored within the United States.

If you access the Platform from outside the United States, you do so at your own risk and acknowledge that your personal information will be transferred to, processed in, and stored in the United States, where data protection laws may differ from those in your jurisdiction. By using the Platform from outside the United States, you consent to such transfer and processing.

17. MARKETING COMMUNICATIONS

Hold My Seat may send you service-related communications, including booking confirmations, payment notices, and policy updates. These communications are necessary for the operation of the service and cannot be opted out of while you maintain an active account or booking.

Where we send optional marketing or promotional communications, we will do so only with your prior consent. You may opt out of marketing communications at any time by following the unsubscribe instructions included in any such communication or by contacting us at support@holdmyseatinc.com.

Opting out of marketing communications will not affect your receipt of service-related notices.

18. AUTOMATED DECISION-MAKING

Hold My Seat uses automated tools, including Stripe's fraud detection systems, to evaluate payment risk and identify potentially fraudulent bookings. These tools may result in the automated decline or flagging of a booking request based on risk signals.

We do not use automated decision-making for any purpose that produces significant legal effects beyond payment risk assessment. Where a booking is declined due to an automated risk assessment, you may contact us at support@holdmyseatinc.com to request a manual review of the decision.

We do not perform credit scoring, credit checks, or any automated financial profiling of our users.

19. CHANGES TO THIS PRIVACY POLICY

Hold My Seat reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, applicable law, or business operations. When material changes are made, we will notify you by email to the address associated with your account, or by posting a prominent notice on the Platform, at least 7 days before the changes take effect.

The revised Privacy Policy will be identified by an updated "Last Updated" date at the top of this document. Your continued use of the Platform after the effective date of any revision constitutes your acceptance of the updated Policy.

If you do not agree with any changes, you must discontinue use of the Platform before the changes take effect.

The most current version of this Privacy Policy will always be available at www.holdmyseatinc.com/privacy-policy.

20. CONTACT US

For any questions, concerns, or formal requests relating to this Privacy Policy or our data practices, please contact us in writing at:

All formal privacy requests must be submitted in writing to the email address above. We will acknowledge receipt within 5 business days and provide a substantive response within 45 days of receiving a verified request.

This Privacy Policy was last reviewed and updated on March 3, 2026. Hold My Seat Inc. reserves all rights not expressly granted herein.