Hold ("Company," "we," "us," or "our") operates the website located at hold.tax (the "Site") and provides IRS collection intervention services (the "Services"). This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you visit our Site or use our Services.

By using our Site or Services, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree, please do not use our Site or Services.

1. Information We Collect

1.1 Information You Provide Directly

When you submit a request, contact us, or purchase our Services, we may collect:

• Full name
• Email address
• Phone number
• Information about your IRS collections situation, including the nature of the collections action, urgency, and approximate amount owed
• Payment information (processed securely through Stripe; we do not store full card numbers)
• Any information you voluntarily share in forms, emails, calls, or text messages

1.2 Information Collected Automatically

When you visit our Site, we automatically collect certain technical information, including:

• IP address
• Browser type and version
• Operating system
• Pages visited and time spent on each page
• Referring URL (the page that linked you to our Site)
• Scroll depth and interaction data
• Session identifiers
• UTM parameters and advertising campaign identifiers
• Device type (desktop, mobile, tablet)

1.3 Cookies and Tracking Technologies

We use cookies, local storage, and similar technologies to operate our Site, remember your preferences, analyze traffic, and measure the effectiveness of advertising campaigns. You may control cookies through your browser settings, although disabling them may affect Site functionality.

We use the following types of tracking:

• Essential cookies: Required for the Site to function, including session management and security.
• Analytics: We collect first-party analytics data (pageviews, scroll depth, time on page) stored in our own database to understand how visitors use our Site.
• Advertising: We may use tracking pixels or identifiers from Google Ads to measure conversions and optimize advertising campaigns. This data is governed by Google's privacy policy.
• Session storage: We store UTM campaign data in your browser's session storage to properly attribute how you found us. This data is not shared with third parties.

2. How We Use Your Information

We use the information we collect for the following purposes:

• To contact you about your IRS situation and provide our Services
• To process payments and fulfil service requests
• To communicate with the IRS on your behalf as part of the Services you have engaged
• To send you service-related communications, including confirmation emails, status updates, and follow-up messages
• To send marketing communications if you have opted in (you may opt out at any time)
• To improve our Site and Services through analytics and user feedback
• To detect, prevent, and address fraud, abuse, or technical issues
• To comply with legal obligations
• To measure the effectiveness of our advertising and marketing campaigns

3. How We Share Your Information

We do not sell your personal information. We may share your information in the following limited circumstances:

3.1 Service Providers

We use third-party vendors who process data on our behalf under strict confidentiality obligations, including:

• Stripe: Payment processing. Your payment data is transmitted directly to Stripe and governed by Stripe's Privacy Policy.
• Resend: Transactional email delivery.
• Neon / Vercel: Database and cloud infrastructure hosting.
• Google Ads / Google Analytics: Advertising measurement and analytics.

3.2 The IRS

In order to provide the Services, we will use your name, contact information, and relevant tax situation details to communicate with the Internal Revenue Service on your behalf. You authorize this disclosure when you engage our Services.

3.3 Legal Requirements

We may disclose your information if required by law, court order, subpoena, or governmental authority, or if we believe disclosure is necessary to protect the rights, safety, or property of Hold, our clients, or the public.

3.4 Business Transfers

In the event of a merger, acquisition, sale of assets, or bankruptcy, your information may be transferred as part of the transaction. We will notify you via email or a prominent notice on our Site if such a transfer occurs.

4. Data Retention

We retain your personal information for as long as necessary to provide the Services, comply with legal obligations, resolve disputes, and enforce our agreements. Lead and contact data is retained for up to 3 years from the date of last contact. Payment records are retained for 7 years in accordance with standard accounting and tax record requirements. Analytics data is retained in aggregated form indefinitely.

You may request deletion of your personal information at any time by contacting us at support@hold.tax. We will process deletion requests within 30 days, subject to legal obligations that require retention.

5. Your Rights and Choices

5.1 Access and Correction

You have the right to access the personal information we hold about you and to request correction of inaccurate data. Contact us at support@hold.tax to make such a request.

5.2 Opt-Out of Marketing Communications

If you have opted in to receive marketing emails or SMS messages, you may opt out at any time by clicking "unsubscribe" in any email we send, replying STOP to any text message, or contacting us directly. Service-related communications (such as status updates about your case) are not marketing and cannot be opted out of while Services are active.

5.3 Do Not Track

Our Site does not currently respond to browser Do Not Track signals. However, you may control cookies and tracking through your browser settings.

6. California Residents — CCPA / CPRA

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including:

• Right to Know: You have the right to request disclosure of the categories and specific pieces of personal information we have collected about you, the sources from which it was collected, the purpose for collection, and the categories of third parties with whom we share it.
• Right to Delete: You have the right to request deletion of your personal information, subject to certain exceptions permitted by law.
• Right to Correct: You have the right to request correction of inaccurate personal information we maintain about you.
• Right to Opt-Out of Sale or Sharing: We do not sell or share your personal information for cross-context behavioral advertising. No opt-out is required, but you may contact us to confirm.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.
• Right to Limit Use of Sensitive Personal Information: We do not use sensitive personal information for purposes beyond those permitted under the CPRA.

To exercise any of these rights, please contact us at support@hold.tax or call (310) 598-3759. We will verify your identity before processing your request and respond within 45 days (with one possible 45-day extension if needed).

California residents may also designate an authorized agent to submit requests on their behalf. We may require written authorization and identity verification in such cases.

7. Virginia Residents — VCDPA

If you are a Virginia resident, the Virginia Consumer Data Protection Act (VCDPA) grants you the following rights with respect to your personal data:

• Right to access personal data we process about you
• Right to correct inaccuracies in your personal data
• Right to delete personal data provided by or obtained about you
• Right to obtain a copy of your personal data in a portable format
• Right to opt out of the processing of personal data for targeted advertising, sale, or profiling

To exercise these rights, contact us at support@hold.tax. We will respond within 45 days. If we decline your request, you may appeal our decision by contacting us and we will respond to the appeal within 60 days.

8. Colorado, Connecticut, and Texas Residents

Residents of Colorado (CPA), Connecticut (CTDPA), and Texas (TDPSA) have similar rights to access, correct, delete, and port their personal data, as well as the right to opt out of targeted advertising and profiling. We honor these rights and will respond to verified requests within the timeframes required by applicable law. To submit a request, contact us at support@hold.tax.

9. Nevada Residents

Nevada residents have the right to opt out of the sale of certain covered information. We do not sell covered information as defined under Nevada Revised Statutes Chapter 603A. If you have questions, contact us at support@hold.tax.

10. Children's Privacy

Our Site and Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If you believe we have inadvertently collected information from a child, please contact us immediately at support@hold.tax and we will delete such information promptly.

11. Data Security

We implement industry-standard technical and organizational measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. These measures include encrypted data transmission (TLS/SSL), access controls, and secure database hosting. However, no method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.

In the event of a data breach that affects your rights or freedoms, we will notify you and applicable regulatory authorities as required by applicable law.

12. Third-Party Links

Our Site may contain links to third-party websites, including the IRS website (irs.gov) and Stripe's checkout. We are not responsible for the privacy practices of those websites. We encourage you to review their privacy policies before providing any personal information.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will update the effective date at the top of this page and, where required by law, notify you by email or prominent Site notice. Your continued use of the Site or Services after changes are posted constitutes your acceptance of the updated Privacy Policy.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us: