The following terms and conditions govern the use of Seedbox Technologies, Inc., ATR Asset Management, Inc.’s, and ATRAM Trust Corporation website, online investment platform, and mobile applications, collectively known as "Seedbox Philippines". By using Seedbox Philippines, you (the "User") agree to be bound by these Terms and Conditions, as well as by the Data Privacy Statement published on the Seedbox Philippines Web site. If you do not agree to these Terms and Conditions or the Data Privacy Statement, your access to Seedbox Philippines will be revoked.

1. GENERAL INFORMATION

Welcome! SEEDBOX is owned and operated by Seedbox Technologies, Inc., a corporation duly organized and existing under and by virtue of the laws of the Republic of the Philippines, with office address at 8F 8 Rockwell Drive, Hidalgo Drive Rockwell Center, Makati City, Philippines (hereinafter referred to "Seedbox", "us" or "we").

2. TERMS AND CONDITIONS

These Terms & Conditions, which includes the Privacy Policy, (these "Terms") contain the terms and conditions on which we supply content, products or services listed on www.seedbox.ph (the "Website"), through our mobile applications (the "Apps") or via other delivery methods to you (the Website and such content, products, services, and the Apps are collectively referred to herein as the "Service" or "Services"). Please read these Terms, carefully before accessing or using any Services from the Website or third party Apps. The word "Device" refers to the device which is used to access the Services including but not limited to computers, smart phones and tablets. The word "you" refers to the user of the Services. When you directly or indirectly cause the use or access the Services, you agree to be bound by these Terms and all applicable laws, rules and regulations and you warrant to be fully and wholly bound by these Terms in your own free will and deed; and that you fully understand and acknowledge the contents, meaning, implications and effects of these Terms. You warrant that you would not use or access our Services if you had any claim or reservation against any matter in these Terms. You may also be asked to click "I accept" at the appropriate place prior to your use of access to Services. At such time, if you do not click "I accept", you may not be able to complete such access. By using or accessing the Services, you indicate that you accept these Terms and that you agree to abide by them. If you do not agree to these Terms, please refrain from using the Service.

Except as otherwise indicated, these Terms and the Privacy Policy set out the whole agreement between you and us for the supply of the Services. In order to participate in certain Services, you may be required to agree to additional terms and conditions; those additional terms are hereby incorporated into these Terms. Where such terms are inconsistent with these Terms, the additional terms shall control.

We reserve the right to suspend or terminate the Services and any contractual relations with you upon notice. In case you have breached any term or condition herein, we may suspend, terminate or in any way modify our Services and our contractual relations without notice. These are without prejudice to our rights and remedies under these Terms, in law or in equity.

3. CHANGES TO TERMS

You undertake to periodically visit and review these Terms for updates and changes. You agree to be bound by these Terms and its subsequent updates, revisions or modifications. Seedbox reserves the right to change or update these Terms, or any other of our policies or practices, at any time, and will notify users by posting such changed or updated Terms on this page. Any changes or updates will be effective immediately upon posting to the Website or the Apps. Your continued use of the Services constitutes your agreement to abide by the Terms as changed. Under certain circumstances we may also elect to notify you of changes or updates to our Terms by additional means, such as pop-up or push notifications within the Services or email.

4. DEFINITION OF TERMS

1. Account ("Account") refers to an account owned by a user. This could either be an Individual Account, a Business Account, an Advisor Account, or a Vendor Account.
2. Business Account ("Corporate Account") refers to an Account owned by a juridical person.
3. Authorized Person ("Authorized Person") refers to an individual that is authorized by a Business Account owner to bind the corporation, partnership, or other juridical entity to any and all Transactions that may be done by such Authorized Person.
4. Currency ("Currency") refers to Philippine Peso, or any other Fiat Currency that may be added to the Service in the future.
5. Fiat Currency ("FC") refers to the Philippine Peso and the United States Dollar, each a government-issued currency that is designated as legal tender in its country of issuance through government decree, regulation, or law;
6. Know-Your-Customer ("KYC") refers to procedures undertaken by Seedbox to identify and verify the identity of the Vendor Accounts' customers.
7. Login Credentials ("Credentials") refer to your username and password.
8. Related Parties ("Related Parties") refer to subsidiaries, affiliates, related parties, and their respective directors, shareholders, officers, employees, consultants, agents and assignees.
9. Registration Form ("Form") refers to a form within the Website or the Apps that requires information from the user for the purposes of identity verification and authentication.
10. Transaction ("Transaction") refers to any and all business that may be conducted by an Account owner or Authorized Person within the Services.
11. Transaction Limit ("Transaction Limit") refers to the maximum amount a user may transact as set by the Vendor Accounts.
12. Vendor Account ("Vendor Account") refers to an Account, either individual or juridical, that promotes, offers, or sells various financial products on Seedbox; and
13. You ("you," "your," or the "Owner") are an entity that uses the Website or the Apps through an Account in connection with its Services.

5. ACCEPTABLE USE POLICY

1. You agree to use any and all of the Services in accordance with all applicable and current laws, regulations, and other guidelines issued by government agencies.
2. You understand and agree that Seedbox may require you to divulge the nature of the transaction being facilitated by your use of our Services if Seedbox determines, at its sole discretion, that it is necessary to comply with any applicable law.
3. You agree not to use any and all of the Services for the following purposes:
   1. To violate any law, regulation, or issuance by any competent legal authority;
   2. To directly or indirectly cause loss or damage to Seedbox or any entity;
   3. To facilitate the sale of any object that is outside the commerce of man;
   4. To facilitate transactions involving illegal drugs, drug paraphernalia and other controlled substances in accordance with applicable law;
   5. To facilitate transactions involving the sale of products which endanger the safety, health, and well-being of individuals;
   6. To facilitate transactions that encourage or incentivize illegal activities;
   7. To facilitate transactions involving stolen, smuggled, or otherwise illegally acquired goods and/or services;
   8. To facilitate transactions involving firearms, explosives, ammunition and any other weapon or accessories of the aforementioned items that are prohibited under applicable law;
   9. To facilitate the infringement of any intellectual property right;
   10. To facilitate Cybercrimes as defined in R.A. 10175 and other applicable laws;
   11. To facilitate Child-Pornography as defined in R.A. 9775 and other applicable laws;
   12. To facilitate prostitution and other sexually-oriented services;
   13. To facilitate transactions relating to pornography;
   14. To facilitate Money-Laundering as defined in R.A. 9160;
   15. To facilitate a "get rich quick" schemes such as pyramid schemes, or Ponzi schemes;
   16. To facilitate bribery or corruption of public officers;
   17. To facilitate any form of ethical, legal, or illegal hacking; and
   18. To facilitate any form of larceny, theft, robbery, or embezzlement.

If you have any doubts as to the compliance of any transaction you wish to conduct using any of our Services you may contact us at support@seedbox.ph. We strongly advise you to report any and all violations even perceived violations of this Acceptable Use Policy to SEEDBOX at the soonest possible time. To report a violation please contact us at support@seedbox.ph.

6. GENERAL PROVISIONS

1. You are required to register if you want to use any of the Services.
2. By registering, you warrant that you have the capacity to enter into valid contracts under Philippine law.
3. If you own a Business Account or a Vendor Account, you warrant that any person you authorize to access and transact using your Account is fully clothed with authority to bind your corporation, partnership, or other juridical entity, as the case may be, under applicable law to whatever Transaction. The authority to access and transact through a Business Investor Account is deemed given at the moment you share your Credentials to another entity.
4. You are bound by these Terms at the moment you register as a user of the Service.
5. Seedbox may amend, change, or delete any part of this Terms at its sole discretion and without prior notice. Changes, amendments, or deletions shall take effect at the moment they are posted. Your continued use of the Services shall be considered acceptance to these changes, amendments, or deletions. If you disagree, you must stop the use of the Service.

7. CANCELLATION OF ACCOUNT AND SITE BANNING

1. Seedbox reserves the right to cancel, suspend, limit or modify in any respect your Account, which in its sole discretion, is found to be in violation of the Terms, Privacy Policy, other relevant agreements, or any law, regulation, or issuance from a competent legal authority (the "Regulations") without need of any prior notice.
2. Seedbox reserves the right to ban certain individuals, businesses, or entities, which in its sole discretion, is found to be in violation of the Terms or Regulations without need of any prior notice.
3. You may voluntarily cancel your Account or discontinue your use of the Services at any time. However, you grant Seedbox the right to retain any or all of your information and transactional records, without prejudice to the Privacy Policy and your rights under the Data Privacy Act of 2012. For any issues regarding the closing of an Account please email us at support@seedbox.ph.
4. In all cases of cancellation, suspension, limitation and modification of your Account, you undertake to continue to be fully liable for any and all outstanding obligations to Seedbox and accessory obligations thereto such as interests, fees and damages.

8. ASSUMPTION OF RISK

1. You accept the risks associated with the use of a website or software such as, but not limited to:
   1. Failure of software;
   2. Hacking of servers;
   3. Failure or interruption of internet connection;
   4. The introduction of malicious software;
   5. Failure of security of your Wallet address and Private Keys;
   6. Exchange Rate fluctuations;
   7. Failure of communication; and
   8. Service disruptions.
2. To mitigate these risks Seedbox will exert reasonable efforts to secure its system and to verify the accuracy of the information on its Services.

9. THE ACCOUNTS

1. You must register in order to be given an Account.
2. You are required to register using your actual legal name, surname, address, phone number, mobile number, email address, date of birth and all other information required by the Form. Seedbox reserves the right to require more information as it deems necessary.
3. You may only have one Account. You cannot open an account on behalf of another or cause another to open an account for you. You are liable for any and all obligations arising from and related to your account.
4. By registering, you warrant that the information you provide are true, correct, up to date, and that you have not provided any information for the purpose of evasion or for the purpose of concealing or committing a crime or a fraudulent scheme.
5. If you have entered any incorrect information in the Form, you undertake to correct the error immediately after its discovery.
6. You agree that Seedbox will not be liable for any injury or damage caused by incorrect information that you provided.
7. Seedbox will require you to supply your own Credentials upon registration subject to certain requirements imposed by the site for better security
8. The security of your account is equally your concern and responsibility as it is ours. You are hereby bound to protect and keep confidential your Credentials. You agree not to divulge either your username or your password to anyone. Moreover, you understand that Seedbox cannot stop you from divulging your Credentials to other individuals. Thus, you agree that any Transaction made using your Credentials is valid and binding on you.
9. You understand that any contract you enter into with accredited third-party merchants and accredited banks and remittance centers is between you and them alone.
10. You agree that Seedbox will not be liable for any injury or damage caused by any unauthorized disclosure of your Credentials.

10. THE BUSINESS ACCOUNT

1. You agree to the covenants and provisions under Clause 9.
2. You are required to register using your corporation, partnership, or other juridical entity's actual legal name, address, phone number, mobile number, email address, date of incorporation as registered with the appropriate government agency and all other information required by the Form. Seedbox reserves the right to require more information as it deems necessary.
3. You may be required to submit further documentation as part of the registration process.

11. THE VENDOR ACCOUNT

1. You agree to the covenants and provisions under Clause 9 & 10.
2. You understand that you may be required to submit documents similar to those submitted by Business Accounts.
3. You agree that the content you will be making available on the Website and Apps is exclusively yours. You likewise agree that the content posted by other users are exclusively that of the users. The negotiations and Transactions between and among the users shall exclude Seedbox or any of its Related Parties.
4. You represent and warrant that you have an absolute right over the content, or any portion thereof, that you will be making available on the Platform and that your use of the content will not violate any law, regulation, third party intellectual property rights, or other rights.
5. You undertake not to cancel or withdraw any transaction for the purpose of contracting separately with the user and therefore results in the user avoiding paying Seedbox any fees and charges.
6. You represent and warrant that (i) you are compliant and will comply with all applicable national and local laws, rules, and regulations and all applicable self-regulatory guidelines in the conduct of its business and in the performance of its obligations under this Terms and other relevant agreements; (ii) your content does not contain, promote, or advocate pornographic, hate, violence, obscene, excessively profane, racist, ethnically offensive, threatening, infringing, libelous, illegal drugs, gambling, terrorist-supporting, human trafficking, arms trafficking or any other similar content; (iii) your content does not encourage any activity that (iii.1) would be considered a criminal offense in any territory wherein Seedbox is accessible or could give rise to civil liability, or violate any applicable law, regulation or order of any court or tribunal including, but not limited to, collecting, using or disclosing personal information in violation of applicable law, including without limitation personal information of minors; and (iii.2) affect the security or privacy of Seedbox users.

12. THE ADVISOR ACCOUNT

1. You agree to the covenants and provisions under Clauses 9, 10 and 11.
2. You understand that you may be required to submit documents similar to those submitted by Business Accounts.
3. You agree that the content you will be making available on the Website and Apps is exclusively yours. You likewise agree that the content posted by other users are exclusively that of the users. The negotiations and Transactions between and among the users shall exclude Seedbox or any of its Related Parties.
4. You represent and warrant that you have an absolute right over the content, or any portion thereof, that you will be making available on the Platform and that your use of the content will not violate any law, regulation, third party intellectual property rights, or other rights.
5. You undertake not to cancel or withdraw any transaction for the purpose of contracting separately with the user and therefore results in the user avoiding paying Seedbox any fees and charges.
6. You represent and warrant that (i) you are compliant and will comply with all applicable national and local laws, rules, and regulations and all applicable self-regulatory guidelines in the conduct of its business and in the performance of its obligations under this Terms and other relevant agreements; (ii) your content does not contain, promote, or advocate pornographic, hate, violence, obscene, excessively profane, racist, ethnically offensive, threatening, infringing, libelous, illegal drugs, gambling, terrorist-supporting, human trafficking, arms trafficking or any other similar content; (iii) your content does not encourage any activity that (iii.1) would be considered a criminal offense in any territory wherein Seedbox is accessible or could give rise to civil liability, or violate any applicable law, regulation or order of any court or tribunal including, but not limited to, collecting, using or disclosing personal information in violation of applicable law, including without limitation personal information of minors; and (iii.2) affect the security or privacy of Seedbox users.
7. You represent and warrant that (i) you and any agents in your employ are duly qualified and licensed by a competent authority; and that (ii) you and any agents in your employ possess the appropriate licenses for the products you sell.
8. You represent and warrant that Transactions you initiate on behalf of your clients accurately represent their expressed instructions to you. Seedbox may ask you to provide documentation to this effect.
9. You acknowledge that your continued access to the Services is contingent on your adherence to the Acceptable Use Policy as well as other agreements and professional standards. You agree not to hold Seedbox liable for any injury or damage resulting from the loss of your access to the Services.

13. IDENTITY VERIFICATION AND KNOW-YOUR-CUSTOMER (KYC) REQUIREMENTS

1. Seedbox may require sensitive personal information to verify the identity of its users. This information will at minimum follow the requirements set forth by the Anti-Money Laundering Council (AMLC), the Bangko Sentral ng Pilipinas (BSP), and/or the Securities and Exchange Commission (SEC) in various circulars.
2. Further, Seedbox may request additional documentation to establish an account owner's true and correct identity.
3. Your disclosure of this information is at all times governed by the Privacy Policy and adheres to the standards set forth in the Data Privacy Act of 2012.
4. Failure to provide proper and truthful documentation may result in delays or outright denial of your Transaction. Seedbox reserves the right to exercise its own discretion as to the determination of authenticity of the documents required under this section. Seedbox further reserves its right to delay or deny any desired Transaction if it determines, through its sole discretion, that the identity and the authority of the person processing the said Transaction has not been duly verified.
5. Vendor Accounts that rely on Seedbox to perform KYC agree that Seedbox shall act as the former's agent for this limited purpose. The Vendor further agrees and understands that the ultimate responsibility for identifying the customer and keeping identification documents remain with the Vendor.
6. Seedbox will, from time to time, request users to update and verify their data.
7. Seedbox may at any point in time revise the data requirements as needed to comply with regulatory mandates.

14. DATA PRIVACY

You acknowledge that you have read and understood Seedbox’s Data Privacy Statement. You consent and agree to the collection, processing, and sharing of your personal data, consistent with Seedbox’s Data Privacy Statement, as may be updated from time to time.

15. INTELLECTUAL PROPERTY RIGHTS

You acknowledge and agree that the materials on the Service, including without limitation, the text, software, scripts, graphics, photos, sounds, music, videos, interactive features and the like ("Materials") and the trademarks, service marks and logos contained therein ("Marks"), are owned by or licensed to Seedbox, and are subject to copyright and other intellectual property rights under Philippine laws, foreign laws and international treaties and/or conventions.

The Service may display certain trademarks belonging to third parties. Use of these trademarks may be subject to license granted to us by third parties. You shall not reverse engineer, decompile, or disassemble such trademarks and nothing herein shall be construed to grant you any right in relation to such trademarks. Materials on the Service are provided to you "as is" for your information and personal viewing only and may not be used, copied, reproduced, distributed, transmitted, broadcast, displayed, sold, licensed, or otherwise exploited for any other purposes whatsoever without the prior written consent of the respective owners.

We reserve all rights not expressly granted herein to the Service and the Materials. You agree to not engage in the use, copying, or distribution of any of the Materials other than as expressly permitted herein, including any use, copying, or distribution of Materials of third parties obtained through the Service for any commercial purposes. If you download or print a copy of the Materials for personal use, you must retain all copyright and other proprietary notices contained therein. You agree not to circumvent, disable or otherwise interfere with security related features of the Service or features that prevent or restrict use or copying of any Materials or enforce limitations on use of the Service or the Materials therein.

The Service is protected to the maximum extent permitted by copyright laws, other laws, and international treaties and/or conventions. Content displayed on or through the Service is protected by copyright as a collective work and/or compilation, pursuant to copyrights laws, other laws, and international conventions. Any reproduction, modification, creation of derivative works from or redistribution of the Service, the Materials, or the collective work or compilation is expressly prohibited. Copying or reproducing the Service, the Materials, or any portion thereof to any other server or location for further reproduction or redistribution is expressly prohibited.

You further agree not to reproduce, duplicate or copy content or Materials from the Service, and agree to abide by any and all copyright notices and other notices displayed in the Service. You may not decompile or disassemble, reverse engineer or otherwise attempt to discover any source code contained in the Service. Without limiting the foregoing, you agree not to reproduce, duplicate, copy, sell, resell or exploit for any commercial purposes, any aspect of the Service.

Our intellectual property rights to our resources in any of its forms, including the Seedbox logo, belong to us and may not be used without our express written consent.

16. WARRANTIES AND LIMITATIONS

1. We warrant to you that any Service directly and exclusively from us will reasonably conform with its description and be of reasonable quality.
2. We warrant that we will use reasonable skill and care in making the Services available to you during your subscription.
3. The Services and their content are otherwise provided on an "as is" basis and we make no representations or warranties of any kind with respect to them, including as to the accuracy, completeness or currency of the Services or their content. We assume no liability or responsibility for any errors or omissions in the content of the Services, or any failures, delays, or interruptions in the provision of the Services. We disclaim and exclude any express or implied warranties or representations, including any warranties as to merchantability or fitness for a particular purpose of the Services to the broadest extent permitted by law. We make no warranties or representations, express or implied, as to the timeliness, accuracy, quality, completeness or existence of the content and information posted on the Services. We make no warranties or representations, express or implied, for technical accessibility, fitness or flawlessness of the Services. We make no warranties or representations that your use of content and information posted on the Services will not infringe rights of third parties.
4. You hereby wilfully and unconditionally waive any and all conditions, warranties and other terms which might otherwise be imposed or implied law or the law of equity.

17. YOUR WARRANTIES

1. By accessing our Services, you wilfully warrant that:
   1. Seedbox will not be liable for the effects, results, function, use, or reliability of any of our Services.
   2. You unconditionally undertake to defend in all kinds of proceedings, hold free and harmless, and fully indemnify Seedbox and the Related Parties from any and all claims, suits, actions, liabilities, losses, damages, fees, taxes, penalties, charges and expenses related to or arising from your relationship or engagement with Seedbox, including the use or access of the Services as well as these Terms and future revisions thereof.
   3. You firmly warrant that you have no current or future claim of whatever nature, expected, real or apparent, against the Released Parties. You unconditionally and irrevocably quitclaim, release, discharge and waive any and all claims and actions of whatever nature, expected, real or apparent, which you may now or in the future have directly or indirectly arising from or related to all legal relations, contracts and arrangements with the Released Parties, including the use or access of our products and these Terms and future revisions thereof.
   4. You warrant to not withhold, suspend, discontinue, alter or modify any of your payments, due amounts and obligations to Seedbox for any reason including the existence of any dispute, claim or allegation against Seedbox or its Related Parties.
   5. You authorize and instruct Seedbox to use, offset, apply and/or compensate any and all amounts in your various Wallets to pay any and all balances and obligations to Seedbox arising from or related to the Services and these Terms, including your unpaid dues, interests, fees losses and damages as reasonably determined by Seedbox.

18. DISCLAIMERS

1. Seedbox makes no warranties regarding the products and services of the Vendor accounts, or any other content provided by any user. Users shall enter into Transactions at their own risk.
2. User interactions with other users are solely between users. Seedbox will not be responsible for any loss or damage incurred between the users and is under no obligation to intervene.
3. The users hereby release Seedbox, including its affiliates, officers, employees, agents, successors, and assigns from, and hereby waive and release each and every past, present and future dispute, claim, controversy, demand, right, obligation, liability, action and cause of action of every kind and nature, that has arisen or arises directly or indirectly out of, or relates directly or indirectly to, any interactions or transactions of the user with, or act or omission of the user in relation to other users.

19. NO WAIVER

1. If we delay exercising or fail to exercise or enforce any right or interest available to us under these Terms, such delay or failure does not constitute a waiver of that right or any other rights under these Terms.

20. FORCE MAJEURE

1. We will not be liable to you for any lack of performance, or the unavailability or failure, of the Services, or for any failure or delay by us to comply with these Terms, where such lack, unavailability or failure arises from any cause beyond our reasonable control.

21. INTERPRETATION

1. In these Terms, unless the context requires otherwise: (i) any phrase introduced by the words "including", "include", "in particular", "for example" or any similar expression shall be construed as illustrative only and shall not be construed as limiting the generality of any preceding words; and (ii) references to the singular include the plural and to the masculine include the feminine, and in each case vice-versa.

22. ELECTRONIC COMMUNICATIONS

In consideration of us agreeing to accept documents, forms, contracts, certifications, waivers, instructions, and any other document in electronic or scanned form by electronic mail ("email"), through our website, other electronic means, or facsimile from you without requiring a physical written confirmation prior to acting thereon, the you acknowledge, confirm, and agree that:

1. Transmitting documents, forms, waivers, and instructions through our website, email, other electronic means, or facsimile are not secure means of communication and you are aware of the risk involved, and request the we to accept such documents, forms, contracts, certifications, waivers, instructions, and any other document in electronic or scanned form for your convenience.
2. You hereby authorize us to act on documents, forms, contracts, certifications, waivers, instructions, and any other document in electronic or scanned form sent by email, through our website, other electronic means, or facsimile which in its sole discretion believe emanate from you as if a physical written instrument was provided. You agree that any web signatures or digital representation of physical signatures captured in electronic files such as pdf documents, and agreement via tickboxes or checkboxes are the legal equivalent of actual or handwritten signatures, which are valid and binding against you as if such signatures were signed on a physical document. No certification authority or third-party verification is necessary to validate or enforce such signature/s.
3. We shall not be liable for acting in good faith on documents, forms, contracts, certifications, waivers, instructions, and any other document in electronic or scanned form sent through our website, by email, other electronic means, or facsimile which emanate from unauthorized persons. Any transaction made pursuant to documents, forms, contracts, certifications, waivers, instructions, and any other document in electronic or scanned form provided in our website, sent by email, other electronic means, or facsimile acted upon in good faith and in the absence of gross negligence or fraud by us shall be binding upon you whether made with or without your authority, knowledge, or consent.
4. You understand that we have absolute discretion to refuse to act upon such documents, forms, contracts, certifications, waivers, instructions, and any other document if it has any reason to doubt the authenticity thereof or the authority of the person giving such instructions.
5. In the absence of gross negligence or fraud by us, you shall indemnify and hold us (and each of its officers, directors, employees and shareholders) free and harmless at all times against all actions, proceedings, claims, losses, damages, costs and expenses which may be brought against us or suffered or incurred by us and which shall have arisen either directly or indirectly out of or in connection with our acceptance of documents, forms, contracts, certifications, waivers, instructions, and any other document in electronic or scanned form sent by email, through our website, other electronic means, or facsimile from you.

23. NOTICES

1. Unless otherwise specifically indicated, all notices given by you to us must be sent to support@seedbox.ph. We may give notice to you at the email address you provide to us when you register. Notice will be deemed received and properly served immediately when posted on the Services or when an email or other electronic communication is sent including SMS to the phone number you registered in the Form. In proving the service of any notice via email, it will be sufficient to prove that such email was sent to the specified e-mail address of the addressee.

24. EXCLUSIVE VENUE AND CHOICE OF LAW

1. You and Seedbox agree that all claims and disputes arising out of or relating to the Terms or the use of the Services will be exclusively brought before the courts of Makati City, Philippines.
2. These Terms shall be exclusively governed and interpreted under the laws of the Republic of the Philippines without regard to its conflict of laws provisions.

25. SEVERABILITY

1. If any of these Terms is declared or found to be unenforceable, illegal, void, or otherwise ineffectual, then that provision shall be deemed removed from these Terms without affecting the validity, efficacy, and enforceability of all the other provisions.

• Seedbox Terms and Conditions of Use v2.0
• Updated: 2021 January 08

Maintaining your privacy is an important part of the products and services that we provide. This Privacy Statement, hereafter referred to as "Statement", explains how we collect, protect, use, and share information when you access our websites and/or apply for and avail of our products and services.

Seedbox Technologies, Inc. ("Seedbox"), together with Technologies, Inc., ATR Asset Management, Inc., and ATRAM Trust Corporation, and any of their respective parent, subsidiaries, and affiliates (collectively, the "ATRAM Group") operates the Seedbox Philippines, an online investment platform provider. This Statement outlines the general practices of Seedbox Technologies, Inc. and the ATRAM Group in relation to our processes and content which are made available through our websites, our online and mobile applications, and social media pages (collectively referred to as "websites"). This Statement also covers the privacy practices for our customers who apply for and obtain products and services from or through us, such as, but not limited to, investments, insurance, and other such products and services that Seedbox may offer from time to time.

The privacy practices described in this Statement are primarily intended for individuals in the Philippines and are designed to comply with the Data Privacy Act of 2012 (R.A. 10173) and its implementing rules and regulations. When accessing our websites and/or availing of our services from outside the Philippines, you acknowledge and agree that your information may be transferred to and processed in the Philippines following legal and regulatory standards for data protection that may differ from your current or home jurisdictions.

I. Information We May Collect

When you apply for or avail of any product or service offers by or through us, or when you interact with our employees, authorized representatives, agents and service providers, we collect your personal information. This may include, among others:

1. your name and personal particulars such as contact details, address, gender, birthdate, education, nationality, family members and relationships;
2. specimen signatures;
3. government ID details including your TIN No., SSS No., or GSIS No.;
4. financial information (such as income, expenses, balances, investments, tax, insurance, financial and transaction history, investment experience, investment horizon, risk appetite, liquidity requirements, financial goals, etc.);
5. employment details;
6. business interests and assets;
7. images via CCTV and other similar recording devices and processes which may be observed when visiting our offices and/or using our other facilities;
8. voice recordings of our conversations with you; and
9. any other information that may be required by local and foreign regulatory agencies.

We may, as and when necessary, seek to verify or augment these information with third-party entities including government regulators, judicial, supervisory bodies, tax authorities or courts of competent jurisdiction and, in the process, gain additional information about you.

In the course of availing our products and services, we also collect information about your transactions and dealings which include your account activities, movements and interactions with third parties.

When you access our websites, we may provide information about us as well as information regarding products and services available from our through us. If you have enrolled your account as a condition of use, you may conveniently access your accounts through our website. In the course of using our network of websites and electronic platforms, we may collect non-personal information such as those provided by your device which may include the IP address, operating system, browser type and version, and other machine identifiers. We may likewise use web analytics tools, including those of third parties’, that use cookies to collect anonymous information and data generated in connection with your activities when you visit the pages and our network of websites.

We may also collect, use and keep your personal opinions or comments made known to us via feedback or responses to surveys or any other interaction that you had with our employees, authorized representatives, agents, and service providers.

II. Use of Information

We use the information collected to deliver and provide the products and services that you have availed to:

1. approve, facilitate, administer and process applications and transactions;
2. respond to queries, requests and complaints and improve how we interact with you;
3. send you statements, billings, notices and other such documents necessary for continued use of our products and services;
4. conduct studies and researches for the purpose of reviewing, developing and improving our products and services;
5. perform profile analysis, behavioral modeling and analytics to understand needs, preferences and market trends to be able to improve and recommend suitable products and services;
6. reach out to you regarding products and services information, including offers, promotions, discounts, rewards; and for personalizing your experience with our various touchpoints such as branches, call center, telemarketing, email, messaging and other channels;
7. determine the effectiveness of our marketing efforts and initiatives;
8. perform certain protective safeguards against improper use or abuse of our products and services including fraud prevention;
9. comply with our operational, audit, administrative, credit and risk management processes, policies and procedures, the terms and conditions governing our products, services, facilities and channels, legal and regulatory requirements of government regulators, judicial, supervisory bodies, tax authorities or courts of competent jurisdiction, as the same may be amended or supplemented from time to time.
10. comply with applicable laws of the Philippines and those of other jurisdictions including the United States Foreign Account Tax Compliance Act (FATCA), the laws on the prevention of money laundering including the provisions of Republic Act No. 9160 (Anti-Money Laundering Act of 2001, as amended (AMLA) and the implementation of know your customer and sanction screening checks
11. comply with legal and regulatory requirements such as submission of data to credit bureaus, credit information companies, the Credit Information Corporation (CIC) (pursuant to RA No. 9510 and its implementing rules and regulations) responding to court orders and other instructions and requests from any local or foreign authorities including regulatory, governmental, tax and law enforcement authorities or other similar authorities;
12. perform other such activities permitted by law or with your consent.

III. Sharing of Information

Many of the products and services available in our online investment platform are provided by ATR Asset Management, Inc., ATRAM Trust Corporation, and third-party financial product providers or distributors. A list of third-party financial product providers presently available on the platform can be accessed here: {Insert link to list} and on the product page of our website. The foregoing lists shall be updated continuously as additional third-party product providers are made available on the Seedbox platform.

When you avail of products and services provided by the other members of the ATRAM Group, or other third-party financial product providers and distributors, you also become their client. Accordingly, it is necessary for us to use, process, and share your personal data to such members of the ATRAM Group and third-party providers for the same purposes enumerated above, as well as the following:

1. To facilitate your account opening or application with the concerned subsidiary, affiliate, or third party financial product provider;
2. To validate, consolidate or update your customer information records;
3. To provide consolidated billings, investment summaries, or other reports as you may request;
4. To send you reminders, announcements, promotions, offers, invitations and other notifications;
5. To enroll you in loyalty or similar client-oriented programs of Seedbox;
6. For research purposes or to design, financial, securities and investment or other related products or services for your use;
7. For promotional and/or marketing activities of Seedbox or of the concerned subsidiary/ies, affiliate/s, or third-party fund providers; and
8. To comply with a legal obligation to which Seedbox or the concerned subsidiary, affiliate, or third party fund provider is subject.

And by availing of such products and services, you also agree to their respective privacy policies of the relevant entity.

Additionally:

1. We may share personal information with our parent, subsidiaries, affiliates and third parties in order to better understand the way you use our products and services. This will allow us to improve our services and offer you opportunities to obtain such other useful products and services that may deliver greater value to you.
2. We may share information with our parent, subsidiaries and affiliates to likewise offer you additional products and services that we believe you might find interesting.
3. We may share with third parties that we engaged to support us in delivering our services to you. These may involve anonymous or aggregated information to help improve our products, services, and content.
4. We may also share information with third parties we engage, including third-party data processors, to help us operate our business. These include support in:
• complying with legal requirements such as court orders;
• enforcing our terms of use and other applicable policies with respect to the services that we provide;
• addressing fraud, security or technical issues, to respond to an emergency or otherwise to protect the rights, property or security of our customers or third parties;
• to carry out all other purposes set out above.

We may transfer, store, and/or process your personal data outside the Philippines. In doing so, we will comply with the Data Privacy Act and its implementing rules and regulations.

We wish to assure you that we do not, and will not, sell personal data to any third parties. All our engagements with third parties shall be fully compliant with our obligation of confidentiality imposed on us under the applicable agreements and/or terms and conditions or any applicable laws that govern our relationship with you.

IV. Data Retention

Your personal information shall be retained for as long as the purpose for which it was collected, and such other purposes that you may have consented to from time to time, remains in effect and until such time as it is no longer required nor necessary to keep your information for any other legal, regulatory or business purposes.

Under present Anti Money Laundering Rules and Regulations, all records obtained through customer due diligence, account files and business correspondence, and the results of any analysis undertaken must be kept, for, at least, five (5) years following the closure of account, termination of the business or professional relationship or after the date of the occasional transaction.

V. Protection of Information

We fully recognize the value of your personal information particularly as it may include sensitive personal information such as your gender, government-issued IDs, etc. Appropriately, we strive to maintain the confidentiality, integrity and availability of your personal information by employing physical, technological and procedural safeguards. We train our employees to properly handle your information. Whenever we engage other companies to provide services for us, we require them to protect personal information aligned with our own security standards.

VI. Data Privacy Rights

In respecting your rights to privacy, you may opt to tell us:

1. not to send you marketing materials via email;
2. not to share your information with our subsidiaries and affiliates or with other companies that we have business with provided that such information is not critical nor required by applicable laws and regulations in maintaining the services that you have availed with us;
3. to provide you with information that we currently have about you subject to restrictions applied to us as a bank and a company operating in the Philippines by certain laws and regulations;
4. to update your information;
5. about your other concerns relating to how we collect, use, share, protect or dispose your information.

We may charge a fee for processing your request/s for access and/or update. Such a fee depends on the nature and complexity of your request. Information on the processing fee will be made available to you prior to making the request.

For any queries, clarifications or requests on any aspect of this Statement, the exercise of your rights pertaining to your personal information or to provide any feedback that you may have about our processing of personal information, please visit any of our office or call us at _____________. You may also email us at support@seedbox.com.ph which is manned during business hours.

You may also write our Data Privacy Officer at:

• Seedbox DPO
• (dpo@seedbox.ph)
• Seedbox Technologies, Inc.
• 8/F 8 Rockwell, Hidalgo St., Rockwell Center
• Makati City 1210
• Philippines

We may modify or amend this Statement from time to time to keep up with any changes in relevant laws and regulations applicable to us or how we collect, use, protect, store, share or dispose of your personal information. Any relevant updates will be posted on our website.

*Definitions:

Personal Information/ Data - refers to any information whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual.

Sensitive Personal Information/ Data - refers to personal information:

1. About an individual’s race, ethnic origin, marital status, age, color, and religious, philosophical or political affiliations;
2. About an individual's health, education, genetic or sexual life of a person, or to any proceeding for any offense committed or alleged to have been committed by such person, the disposal of such proceedings, or the sentence of any court in such proceedings;
3. Issued by government agencies peculiar to an individual which includes, but not limited to, social security numbers, previous or current health records, licenses or its denials, suspension or revocation, and tax returns; and
4. Specifically established by an executive order or an act of Congress to be kept classified.

• Seedbox Data Privacy Statement v2.0
• Updated: 2021 January 08