Good morning! I'm a low-time commercial rated pilot just starting training with a banner company for my first job.

My question is about doing sightseeing tours on the side:
Can I tell people about sightseeing tours on my own? I know this is holding out but since we aren't going "from place to place" (we are landing back at the same location within 25NM) I thought this might be ok/legal?

This would be in a plane I rent, I don't own a plane. And this wouldn't be for a company, just me doing it on the side. The regulation of holding out seems to have those 4 requirements needed so if I'm not going "from place to place" then I'm good?

Thanks for any advice