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Corporate Disclosure

Atlas Pre-Seed Programme · Administered via SWC Field (KEYSTRA Ltd.)

Operator and Parties Disclosure

Effective Date: 26 August 2026

Responsibility Matrix

Role

Responsible Party

Operator / Administrator

KEYSTRA Ltd., C984038, Seychelles

Contracting Party / Seller

Atlas Overseas FZE, No. 4219, Licence L-4407, UAE

Payment Recipient (upon debit from the balance)

Atlas Overseas FZE

Processing of Funds Added / Holding of Balance

Engaged licensed payment service provider (PSP) — not identified

KYC/AML

KEYSTRA Ltd. using Veriff; final contractual decisions — Atlas Overseas FZE

Data Controller

KEYSTRA Ltd.

Complaints and Refunds

KEYSTRA Ltd. receives and coordinates; Atlas Overseas FZE implements contractual and payment decisions

What Atlas Is

Atlas is a technology project being developed to coordinate individual stages of real estate transactions in the UAE, including property searches, data verification, document management and payment support. The project is at an early stage of development; certain features and partnerships may not yet be available and may change. Atlas does not replace brokers, developers, banks, payment service providers, legal advisers or official government registries.

Who the Seller Is

The seller of the IP Shares is Atlas Overseas FZE (UAE). Applications and initial verification are handled by KEYSTRA Ltd. (Seychelles), trading as “SWC Field”. For the full particulars of the parties, see the Corporate Disclosure above.

General Terms for Purchasing IP Shares

The base price, payment mechanics, royalties and buyback are summarised below on this page; for the full terms, see the Programme Terms and the IP Shares Terms.

The base price of one IP Share at the Pre-Seed stage is USD 1.00.

An IP Share confers the right to a proportionate share of royalties and the right to participate in a buyback if and when offered by the Seller; it does not confer any equity interest, voting rights or guaranteed return.

Principal Risks

For the principal warning and a complete list of risks, see the Risk Disclosure. In summary:

a high risk of losing the entire amount paid;

royalties and any buyback are not guaranteed;

the IP Shares Register is maintained technically by the Seller alone, without independent third-party verification.

Who Conducts KYC/AML Checks

KEYSTRA Ltd. conducts the initial verification using Veriff; every purchase is subject to AML screening. For the full procedure, see the KYC/AML Policy.

Who Receives Payment

Payment is made by funding the balance in the Personal Account and debiting that balance in favour of Atlas Overseas FZE upon purchase; any unspent balance may be withdrawn at any time. For details, see §4 of the Programme Terms.

Who Handles Complaints and Refunds

The single point of contact is KEYSTRA Ltd., which refers matters to the Seller where necessary. For the procedure and time limits, see the Complaints Policy and the Cancellation and Refund Policy.

The Sole Action Available on the Page

[Submit an Application] — a contact details form. Submitting an application does not create any obligation to pay. Links to the complete document package (Programme Terms, IP Shares Terms, Risk Disclosure, Eligibility and Jurisdiction Restrictions, KYC/AML Policy, Privacy Notice, Complaints Policy and Cancellation and Refund Policy) are available on the same page before the application is submitted.

1. Platform Operator and Administrator

KEYSTRA Ltd., an International Business Company incorporated in the Republic of Seychelles on 17 March 2026 under the International Business Companies Act 2016, registration number C984038, registered office at Suite 9, Ansuya Estate, Revolution Ave, Victoria, Seychelles (“SWC Field”, the “Administrator”).

The Administrator operates the SWC Field platform, receives applications, conducts initial KYC checks, arranges AML screening using Veriff, acts as the controller of personal data processed through the platform, and handles enquiries and complaints.

2. Contracting Party and Seller

Atlas Overseas FZE, a free zone company incorporated in the DWTC Free Zone, Dubai, UAE, registration number 4219, licence L-4407, registered office at Sheikh Rashid Tower, Floor 04, Premises 407-FZF 252, Dubai World Trade Centre, Sheikh Zayed Road, Dubai, UAE; Manager: Aliaksei Kazarchuk (the “Seller”).

The Seller is the contracting party under the agreement for the sale and purchase of IP Shares, receives payment, transfers the IP Shares, maintains the Register and performs the obligations relating to royalties and any potential buyback.

3. Payment

The Buyer funds the balance in the SWC Personal Account through an engaged licensed payment service provider; the balance is debited in favour of the Seller when payment for the IP Shares is made. Any unspent balance constitutes a prepayment by the Buyer and may be withdrawn at any time upon request. The date of payment for the IP Shares is the date on which funds are debited from the balance in favour of the Seller. Payment system fees are borne by the Buyer.

4. KYC/AML

KYC is conducted by the Administrator once, before acceptance of the Offer. Every purchase is subject to mandatory AML screening using Veriff. The Seller may request additional documents and suspend performance where a risk of non-compliance is identified.

5. Personal Data

The Administrator is the controller of personal data collected through SWC Field. Veriff is engaged as a specialist identity verification provider; Veriff’s independent obligations in respect of data are governed by applicable law and its privacy notice.

6. Complaints and Refunds

The Administrator receives and handles complaints and refund requests through the SWC Personal Account or by email at compliance@swcfield.com. Decisions affecting the agreement, any payment or a refund are implemented by the Seller as the contracting party and recipient of payment.

Published programme document. If a later signed version is issued by the parties, that version prevails in case of conflict.