PAMMO — TERMS AND CONDITIONS OF SERVICE (MAIN)

Version 1 — Publication-Ready Pending Final Review Last Updated: 2026-05-18 Effective Date: 15 June 2026 (Beta start; full Service launch staged per Pammo-Program-Rules-V1 §1)

PREAMBLE — DUAL-ENTITY OPERATING STRUCTURE

These Terms and Conditions of Service (these "Terms", "T&C", or this "Agreement") constitute a legally binding agreement between you ("User", "you") and the Pammo operating entity that contracts with you under §0 below, governing your access to and use of the Pammo platform — including all websites, mobile applications, application programming interfaces (APIs), software, generative AI tools, listing tools, content, and services made available by Pammo (collectively, the "Service").

Pammo is operated jointly by two affiliated companies under a geo-routed dual-entity structure:

• AEDOWON CO., LTD — a company duly registered under the laws of the Kingdom of Thailand. Thailand-resident Users contract directly with AEDOWON CO., LTD. Payments are routed via Omise (Opn Payments Co., Ltd.) in THB, with Thai VAT and withholding-tax handling per the Thai Revenue Code and the Direct Sales and Direct Marketing Act B.E. 2545 (2002).

• AEDOWON SINGAPORE PTE. LTD. — a company incorporated under the laws of the Republic of Singapore (Unique Entity Number "UEN" 202612161D). International (non-Thailand) Users contract directly with AEDOWON SINGAPORE PTE. LTD. Payments are routed via Polar.sh (Polar Software, Inc., Merchant of Record) in USD or such other currencies as Polar supports, with Singapore Goods and Services Tax ("SG GST") and MoR-level tax compliance handled by Polar in supported jurisdictions.

"Pammo", "we", "us", and "our" refer collectively to AEDOWON CO., LTD and AEDOWON SINGAPORE PTE. LTD. in the joint operation of the Service. The specific entity that is your contractual counterparty under these Terms is determined at checkout per §0 below. Pammo's geo-routing decision is made on the basis of your declared country of residence validated against your billing instrument; you may not self-select your route to avoid tax or other regulatory obligations.

By accessing, registering for, or using the Service in any manner, you acknowledge that you have read, understood, and agree to be bound by these Terms, the Pammo Privacy Notice, the Pammo Cookie Notice, the Pammo Acceptable Use Policy, the Pammo Pricing Schedule, the Pammo Program Rules, the Pammo Sub-Processor List, the Pammo Data Processing Addendum, the Pammo Payment Processor Partners disclosure, and any program-specific terms incorporated by reference (the Affiliate Program Terms, the Creator Program Terms) (collectively, the "Pammo Policies"). If you do not agree to these Terms, you must not access or use the Service.

These Terms are designed to comply with the Personal Data Protection Act B.E. 2562 (2019) of the Kingdom of Thailand ("Thailand PDPA"), the Personal Data Protection Act 2012 of the Republic of Singapore ("Singapore PDPA"), and, where applicable, the General Data Protection Regulation (Regulation (EU) 2016/679) ("GDPR"), the United Kingdom Data Protection Act 2018 and UK GDPR, and other prevailing international standards for software-as-a-service ("SaaS") providers.

0. CONTRACTING-ENTITY ALLOCATION CLAUSE

0.1 Geo-routing. At signup, you declare your country of residence; the Service detects and validates this against your billing instrument (card BIN, PromptPay binding, banking app, or Polar-supported wallet). Based on the result:

0.2 Single source of truth. Notwithstanding the dual-entity structure, both entities accept these Terms as a single, unified contract framework. The contracting entity that issues your invoice, receives your payment, and is your counterparty for refund / dispute purposes is recorded on your invoice and in your account dashboard.

0.3 Joint controllership for account data. For data-protection purposes, AEDOWON CO., LTD and AEDOWON SINGAPORE PTE. LTD. act as joint data controllers for account, billing, security, and audit-log data; details and the primary contact (Data Protection Officer) channel are set out in the Pammo Privacy Notice §1.

0.4 Relocation. A User who relocates between Thailand and any other country may request a route review by emailing billing@pammo.co. Changes take effect at the next renewal Billing Cycle; no retroactive re-routing or refund is required.

0.5 No self-selection. You may not select the route in order to avoid tax or any other regulatory obligation. Pammo reserves the right to re-route at the next renewal where evidence of mis-stated residence appears.

1. ACCEPTANCE OF TERMS

1.1 Binding Agreement. By creating an account, clicking "I Agree" / "ยอมรับ" / "Sign Up" / "Subscribe", or by otherwise accessing or using any portion of the Service, you affirmatively accept these Terms in their entirety and enter into a binding contractual relationship with the Pammo contracting entity determined under §0.

1.2 Authority to Bind. If you access or use the Service on behalf of a company, partnership, real-estate brokerage, agency, developer, or other legal entity (each, an "Organization"), you represent and warrant that (a) you have the full legal authority to bind such Organization to these Terms; (b) you have read and understood these Terms; and (c) you agree to these Terms on behalf of such Organization. In such event, "User", "you", and "your" shall refer to such Organization.

1.3 Electronic Acceptance. Your electronic acceptance of these Terms (including by clicking, checking a box, or continuing to use the Service) carries the same legal weight and enforceability as a handwritten signature under the laws of the Kingdom of Thailand, the Republic of Singapore, the European Union, and the United Kingdom — including the Thai Electronic Transactions Act B.E. 2544 (2001) as amended, the Singapore Electronic Transactions Act 2010, the eIDAS Regulation 910/2014, and the UK Electronic Communications Act 2000.

1.4 Supplementary Agreements. Certain features of the Service may be subject to additional terms — including the Affiliate Program Terms, the Creator Program Terms, the Program Rules (including FGF), and any feature-specific terms posted within the Service, each as published and updated from time to time. Such supplementary agreements are incorporated by reference and form an integral part of these Terms. In the event of a conflict, supplementary program-specific terms control on program-specific matters, and these Terms control on all other matters.

1.5 Minimum Age. You must be at least eighteen (18) years of age to enter into these Terms. By accepting, you represent and warrant that you have reached the age of majority in your jurisdiction of residence.

2. SERVICE DESCRIPTION

2.1 Overview of Pammo. Pammo is an artificial-intelligence-powered software-as-a-service platform designed primarily for real estate professionals — including individual property agents, brokerages, sales teams, developers, investors, and affiliated stakeholders — operating in Thailand and adjacent markets. The Service combines proprietary AI engines, third-party data feeds, web-sourced supply / demand data ("Property Discovery"), and User-contributed information to deliver an integrated suite of tools for listing creation, inventory management, contract drafting, deal management, AI-assisted chat command, and PANNORA Co-Pilot for sales workflow assistance.

2.2 Core Modules. Without limitation, the Service includes the following modules:

(a) Chat-to-Listing — AI-assisted conversion of free-text or LINE / chat snippets into structured property listings.

(b) Listing Hub — listing inventory management, search, filter, inline-edit, and data-completeness indicators (Free tier capped at 10 listings; PRO / ULTRA unlimited per Pammo-Pricing-Schedule-V1).

(c) AI Chat Command — natural-language commands to create, edit, search, or summarize listings.

(d) AI Listing Description — generative copy for listings in Thai or English, optimized for downstream channels (e.g., DDproperty, Facebook, condominium-portal feeds).

(e) Document OCR + Parse — vision-model extraction of structured data from photographs of title deeds, contracts, and offer quotations.

(f) AI Property Matching — vector-search-based matching of customer requirements to inventory listings.

(g) Property Discovery — Pammo-operated web aggregation and parsing of public real-estate listings to enrich inventory.

(h) Contract Auto-gen — template-based and AI-assisted document generation for letters of intent, offers to purchase, lease agreements, and brokerage agreements (subject to §8.4 below — drafting aid only, not legal advice).

(i) PANNORA Co-Pilot — AI-driven sales-assistance suite including Sales Co-Pilot, Sentiment Analysis, Property Analytics Dashboard, and AI Sales Coaching (ULTRA-tier feature).

(j) Public Share Pages — shareable listing-detail pages for client outreach.

2.3 Continuous Evolution. The Service is provided on an evolving basis. Pammo reserves the right, in its sole discretion, to add, modify, suspend, or discontinue any feature, module, integration, or functional component at any time, subject to §6 (Dynamic Pricing) and applicable consumer-protection laws.

2.4 No Brokerage Services. Pammo is a software platform only. Pammo does not act as a real estate broker, agent, fiduciary, escrow agent, lender, valuer, or counterparty to any property transaction. Pammo does not represent buyers or sellers and does not earn commissions on property transactions executed through or with the assistance of the Service — except for the FGF / Affiliate / Creator program commissions governed by the supplementary terms in §11.

2.5 Third-Party Data. Property data presented in the Service may originate from public sources, partner integrations, web-scraped public listings (subject to source-side terms of service), or User submissions. Pammo does not guarantee the timeliness, accuracy, completeness, or legal status of any third-party data, and presents such data with the prominent "AI Output / Property Data Disclaimer" prescribed in §8.

3. ELIGIBILITY AND ACCOUNT REGISTRATION

3.1 Eligibility Requirements. To use the Service, you must:

(a) be a natural person of at least eighteen (18) years of age, or a duly organized legal entity; (b) have full legal capacity to enter into binding contracts; (c) not be barred from receiving services under the laws of Thailand, Singapore, or any other applicable jurisdiction; (d) not be located in, or a national of, any country subject to comprehensive economic sanctions imposed by the United Nations, the Kingdom of Thailand, the United States, the European Union, the United Kingdom, Switzerland, or Singapore; and (e) provide accurate, current, and complete information during the registration process.

3.2 Account Creation. You agree to:

(a) provide truthful and accurate registration information, including legal name, valid email address, mobile number, and (where required) tax identification or business registration number; (b) maintain and promptly update your account information to keep it accurate, current, and complete; (c) safeguard your account credentials and never share them with any third party; (d) accept responsibility for all activities that occur under your account.

3.3 Identity Verification (KYC). Pammo may, at its discretion, require you to complete identity verification ("KYC") procedures — including submission of government-issued identification, proof of address, or business-registration documents — particularly where you apply to the Creator Program or trigger an anti-fraud review under Pammo-Program-Rules-V1 §8. Failure to complete such verification may result in suspension or termination of your account, or rejection of your Creator / Affiliate application.

3.4 One Account per User. Unless explicitly authorized in writing by Pammo, each User may maintain only one (1) active personal account. Organizations may maintain seat-based or team-based accounts under enterprise arrangements per Pammo-Pricing-Schedule-V1 §9.

3.5 Account Security. You are solely responsible for maintaining the confidentiality of your username, password, API keys, and any other authentication credentials. You must immediately notify Pammo at support@pammo.co of any unauthorized access, security breach, or suspicious activity. Pammo shall not be liable for any loss or damage arising from your failure to comply with this §3.5.

4. SUBSCRIPTION PLANS AND BILLING

4.1 Subscription Tiers. The Service is offered on a subscription basis through a range of tiered plans (each, a "Plan"), including the Free, PRO, and ULTRA tiers (and the Beta / Early Access intro SKUs governed by Pammo-Program-Rules-V1 §1–§2). The features, quotas, and pricing of each Plan are described in the Pammo Pricing Schedule and may be updated from time to time in accordance with §6.

4.2 Billing Cycles. Subscription fees ("Subscription Fees") shall be charged in advance on a recurring basis according to the billing cycle selected by the User (monthly or yearly). Each billing cycle is referred to as a "Billing Cycle". Yearly Billing Cycles are billed in a single up-front payment and credit allowances drip month-by-month signup-anchored.

4.3 Authorized Payment Methods. Per the contracting entity allocation in §0:

(a) TH Route (via Omise): credit card (Visa, Mastercard, JCB), debit card, PromptPay (QR / instant transfer), TrueMoney Wallet, mobile banking, and such other payment methods as Omise enables from time to time.

(b) International Route (via Polar.sh as Merchant of Record): credit card (Visa, Mastercard, American Express, JCB where supported), and such other payment methods as Polar enables in your jurisdiction at checkout.

By providing a payment method, you authorize the contracting entity and its payment processor (Omise or Polar, as applicable) to charge that payment method for all applicable fees in accordance with these Terms.

4.4 Auto-Renewal.

(a) Clear Disclosure. At the point of subscription, Pammo will disclose in a clear and conspicuous manner: (i) the recurring fee, (ii) the billing frequency, (iii) the renewal date, (iv) any introductory rate that will revert to the standard rate (including Beta-Lock and EA-intro rate-lock expiries per Pammo-Program-Rules-V1 §2), and (v) a plain-language description of how to cancel.

(b) Separate Affirmative Consent. Subscriptions automatically renew at the end of each Billing Cycle for a successive Billing Cycle of equal duration only if you have separately and affirmatively consented to auto-renewal at the point of purchase, in compliance with applicable consumer-protection laws — including the U.S. FTC "Click-to-Cancel" Rule (16 CFR Part 425), the EU Consumer Rights Directive 2011/83/EU Art 8, the Thailand Direct Sales and Direct Marketing Act B.E. 2545 (2002), and analogous laws of your jurisdiction.

(c) Pre-Renewal Reminder. For yearly subscriptions, Pammo will send a renewal reminder email to your registered email address at least thirty (30) calendar days prior to each automatic renewal, identifying the renewal date, renewal amount, and providing a one-click cancellation link.

(d) Easy Cancellation. You may cancel auto-renewal at any time through your account settings using a single-click control, or by emailing billing@pammo.co. Cancellation methods are at least as simple as the methods used to subscribe.

4.5 Cancellation. You may cancel your subscription at any time. Cancellation takes effect at the end of the then-current Billing Cycle. Upon cancellation:

(a) you retain access to the Service through the end of the paid Billing Cycle; (b) your subscription does not renew for the next Billing Cycle; (c) no pro-rata refund is issued for unused portions of the current Billing Cycle except as required by mandatory consumer-protection law or as expressly provided in §7.

4.6 Failed Payments. If a payment fails, Pammo may (a) retry the charge over a reasonable period under the payment processor's standard dunning schedule; (b) downgrade your account to the Free tier; (c) suspend access to paid features; and (d) terminate your account if the failure is not remedied within a reasonable period. You remain liable for any unpaid Subscription Fees plus any reasonable collection costs to the extent permitted by mandatory law.

4.7 Taxes. All fees are exclusive of applicable taxes (VAT, GST, withholding tax, sales tax, or similar levy) unless explicitly stated otherwise.

(a) TH Route Users receive Thai-language tax invoices from AEDOWON CO., LTD compliant with Thai Revenue Code §86; Thai withholding-tax certificates (Phor Ngor Dor 50 / 50 ทวิ) are issued annually for Users to whom WHT applies (e.g., business-Users in Thailand making service-fee payments).

(b) International Route Users receive USD-denominated invoices from AEDOWON SINGAPORE PTE. LTD. or, where Polar acts as Merchant of Record, from Polar; SG GST or local VAT / sales-tax is collected by Polar in supported jurisdictions per the Polar MoR terms incorporated through Pammo-Payment-Processor-Partners-V1 §2.

(c) You are responsible for the payment of all taxes associated with your use of the Service that are not collected by Pammo or its payment processor at checkout.

4.8 Free Trials and Promotional Offers. Pammo may offer free trials, discount codes, or promotional pricing (including the Beta-Lock 345 ฿/mo carry-forward and EA ULTRA 895 ฿/mo intro per Pammo-Program-Rules-V1 §2). Such offers are subject to the specific terms posted at the time of offer, are non-transferable, and may be revoked at any time. Unless you cancel before the expiration of a free trial, you authorize Pammo to automatically charge the applicable Subscription Fee at the conclusion of the trial — subject to the §4.4 auto-renewal disclosure and consent rules.

5. EXTRA USAGE AND CREDIT-METER TERMS

5.1 Concept of Extra Usage. Each Plan includes a defined monthly quota of credits and Discovery credits ("Quota"). When you reach or exceed your Quota, you may continue to use the Service through one of two billing modes (collectively, "Extra Usage"):

(a) Auto-Charge Mode (credit card or other Authorized Payment Method on file); or (b) Prepaid Credit Mode (pre-purchased Prepaid balance).

Extra Usage is opt-in only. By default, Extra Usage is OFF, and metered features will throttle or block once Quota is exhausted (subject to the ULTRA Fair Use Policy in Pammo-Pricing-Schedule-V1 §6, under which ULTRA's general-credit allowance is throttled rather than hard-blocked).

5.2 Auto-Charge Mode.

(a) Activation. Maintain a valid Authorized Payment Method on file; explicitly toggle "Extra Usage" to ON in your account dashboard; and acknowledge the Per-Credit Fees and the Monthly Spending Limit.

(b) Per-Credit Billing. When Auto-Charge is ON and your Quota is exhausted, each subsequent metered action accrues a Per-Credit Fee at the then-current published rate (currently 0.30 ฿/general credit and 0.50 ฿/Discovery credit per Pammo-Pricing-Schedule-V1 §5.1; equivalent to 3 ฿ per legacy AI Action and 5 ฿ per legacy Discovery Action).

(c) Aggregated Charging. Per-Credit Fees accrued during a Billing Cycle are aggregated and charged to your Authorized Payment Method either (i) at the end of the Billing Cycle alongside your Subscription Fee, or (ii) when the accumulated balance exceeds a reasonable threshold defined by Pammo, whichever occurs first.

(d) Monthly Spending Limit. You must set a Monthly Spending Limit (default 200 ฿/month; range 50 ฿ to 2,000 ฿ per Pammo-Pricing-Schedule-V1 §5.4). When the limit is reached within a calendar month, the Service auto-blocks further chargeable actions until (i) the next monthly reset on the first (1st) of the following calendar month, (ii) you raise the limit, (iii) you upgrade your Plan, or (iv) you top up Prepaid Credits.

5.3 Prepaid Credit Mode.

(a) Purchase. Available denominations and minimum top-up per Pammo-Pricing-Schedule-V1 §5.3 (100 / 200 / 500 / 1,000 THB; min 100 THB).

(b) Consumption. Prepaid Credits are debited at the same Per-Credit Fees as Auto-Charge Mode. When Prepaid Credits are exhausted and Auto-Charge is not ON, the Service blocks further chargeable metered actions.

(c) No Expiry. Prepaid Credits do not expire and remain in your account until consumed, subject to §17 (Termination), provided that this provision does not apply where mandatory unclaimed-property or consumer-protection laws require otherwise.

(d) Non-Refundable. Prepaid Credits are non-refundable, non-transferable, and non-exchangeable for cash, except as required by mandatory law.

5.4 Order of Consumption. If a User has both Prepaid Credits and Auto-Charge enabled, Prepaid Credits are consumed first. Auto-Charge engages only when Prepaid Credits reach zero.

5.5 Credit Display Convention (D-01). All user-facing display uses credits: 1 legacy "AI Action" displays as 10 credits; 1 legacy "Property Discovery Action" displays as 10 Discovery credits. Internal accounting may continue legacy ai_actions_* columns, with credits_displayed = ai_actions × 10 as the published value.

5.6 Notifications and Transparency. Pammo will provide in-Service notifications when (a) Quota reaches 80% consumption; (b) Quota is exhausted; (c) Monthly Spending Limit is approached or reached; (d) Prepaid Credits are running low; and (e) you cross any ULTRA Fair Use throttle threshold (per Pricing Schedule §6). You are responsible for monitoring your consumption and managing your settings accordingly.

5.7 No Liability for User-Configured Spending. By enabling Auto-Charge and / or setting a Monthly Spending Limit, you accept full responsibility for the resulting charges. Pammo shall not be liable for charges incurred up to the Monthly Spending Limit, even if such charges arise from scripts, repeated queries, automated workflows, or unintended use — subject to the §15 carve-outs (gross negligence, willful misconduct, fraud, mandatory consumer-protection law).

6. DYNAMIC PRICING CLAUSE

6.1 Right to Adjust Pricing. Pammo reserves the right to modify, increase, decrease, restructure, or otherwise adjust:

(a) Subscription Fees for any Plan; (b) Per-Credit Fees for any class of credit action or Discovery credit action; (c) Prepaid Credit purchase pricing or denomination structures; (d) Add-on, integration, or premium feature pricing; (e) Bundling, packaging, quota allocations, and feature inclusions of any Plan; and (f) Discount, promotional, and trial structures —

subject to the protections in §6.4–§6.6 for already-paid Subscriptions and Prepaid Credits, and subject to the User's right to cancel under §4.5 prior to any new rate taking effect on renewal.

6.2 Method of Notification. Pammo will (i) publish updated pricing on the Pammo Pricing Schedule; (ii) send email notification to active paid subscribers at least fourteen (14) calendar days prior to any pricing change taking effect at the User's next renewal; and (iii) where reasonably practicable, display an in-Service banner. The published Pricing Schedule is the authoritative source.

6.3 No Vested Right. Except as expressly provided in §6.4, you have no vested right in any particular pricing level, no entitlement to grandfathered pricing, and no claim for damages arising from a pricing change.

6.4 Honoring of Existing Subscriptions and Prepaid Credits. Notwithstanding the foregoing:

(a) Active Paid Subscriptions at the time of a pricing change shall continue at the originally-paid rate until the conclusion of the then-current Billing Cycle. Upon renewal, the new published rate shall apply, subject to your right to cancel under §4.5 before the renewal date.

(b) Unused Prepaid Credits purchased prior to a pricing change shall continue to be consumed at the Per-Credit Fee in effect at the time of the credit purchase, until such Prepaid Credits are fully depleted. New top-ups after the pricing change are subject to the new Per-Credit Fees.

(c) Rate-Locks (Beta-Lock and EA-intro) are honored to their individual expiry dates per Pammo-Program-Rules-V1 §2; this §6 does not shorten any rate-lock window.

6.5 Yearly Plans. For yearly subscriptions, the originally-paid rate is honored for the entire twelve (12) month paid period. Renewal occurs at the new published yearly rate unless cancelled before renewal.

6.6 Material Adverse Changes — Right to Cancel. If Pammo introduces a pricing change that would result in a material adverse impact on your subscription (e.g., a substantial fee increase at renewal), you may exercise your right to cancel under §4.5 prior to the effective date of such change. Cancellation under this §6.6 is not a waiver of your obligation to pay accrued fees through the end of the current Billing Cycle.

6.7 No Retroactive Charging. Pammo shall not retroactively charge Users for credits consumed prior to a pricing change. All Per-Credit Fees and Subscription Fees are calculated based on the rate in effect at the time of the action or the start of the Billing Cycle, respectively.

7. REFUND POLICY

7.1 General Policy — No Refund After Activation. Consistent with Pammo's general commercial policy and anti-fraud framework, all Subscription Fees, Per-Credit Fees, Prepaid Credits, add-on purchases, and other amounts paid to Pammo are non-refundable once the Service has been activated, accessed, or used, except as expressly provided in this §7 or as required by mandatory law.

7.2 Yearly Subscription Refund Window (7 Days / 10% Quota). For yearly subscriptions, a User may request a full refund of the Subscription Fee within seven (7) calendar days of the initial purchase, provided that the User has not consumed more than ten percent (10%) of the included annual general-credit Quota and has not received any FGF, Affiliate, or Creator-Program benefits associated with the purchase. After the seven-day window or upon exceeding 10% Quota consumption, the Yearly Subscription Fee becomes fully non-refundable.

7.3 Pro-Rata Refunds. Pammo does not generally provide pro-rata refunds for partial-period cancellations, downgrades, or non-use of paid features.

7.4 Service Outage Compensation. In the event of a continuous, Pammo-attributable Service outage exceeding twenty-four (24) consecutive hours, affected Users may request, in lieu of a cash refund, an extension of their Subscription Cycle or an issuance of Prepaid Credits equivalent to the pro-rata value of the outage.

7.5 Chargebacks. Filing a chargeback or payment dispute with your bank or card issuer without first attempting to resolve the matter with Pammo support (via support@pammo.co, response SLA 7 calendar days) constitutes a material breach of these Terms. Consequences may include:

(a) immediate suspension or termination of your account; (b) forfeiture of all Prepaid Credits and FGF / Affiliate / Creator earnings; (c) recovery of disputed amounts plus chargeback fees and reasonable collection costs; (d) referral of the dispute to a regulated credit-reporting agency or licensed collection agency, in compliance with applicable credit-reporting laws and only after a final adverse determination of the dispute and reasonable opportunity for the User to cure; (e) permanent ban from re-registering for the Service.

A successful chargeback after Pammo's good-faith dispute response constitutes presumptive fraud per Pammo-Acceptable-Use-Policy-V1 §4.3(f).

7.6 Mistaken or Duplicate Charges. If you reasonably believe you have been charged in error or twice for the same item, contact billing@pammo.co within thirty (30) calendar days of the charge. Verified erroneous or duplicate charges will be refunded in full to the original payment method.

7.7 Statutory Rights. Nothing in this §7 limits or excludes any non-waivable statutory rights you may have under:

(a) the Consumer Protection Act B.E. 2522 (1979) of the Kingdom of Thailand; (b) the Direct Sales and Direct Marketing Act B.E. 2545 (2002); (c) the Consumer Case Procedure Act B.E. 2551 (2008); (d) the Singapore Consumer Protection (Fair Trading) Act 2003; (e) the EU Consumer Rights Directive 2011/83/EU; (f) the U.S. FTC Click-to-Cancel Rule (16 CFR Part 425); (g) any other consumer-protection law of your jurisdiction of residence.

7.8 EU / EEA / UK Consumer Cooling-Off (CRD Art 9 / 16(m)). If you are a consumer resident in the European Economic Area or the United Kingdom, you ordinarily have a right under EU CRD 2011/83/EU Article 9 (and analogous UK regulations) to withdraw from a distance contract for digital content within fourteen (14) calendar days of conclusion.

Pursuant to Article 16(m), you expressly consent to the supply of digital content beginning during the 14-day cooling-off period and acknowledge that you thereby lose your right of withdrawal once supply has begun — except for the limited rights in §7.2 (Yearly Subscription within 7 days, < 10% Quota consumed). Pammo will provide written confirmation of this consent and acknowledgement on a durable medium (email and account-dashboard record) following purchase.

8. AI-GENERATED CONTENT AND PROPERTY DATA DISCLAIMER

8.1 Nature of AI Output. The Service utilizes generative AI, large language models, computer-vision models, and predictive analytics. AI-generated outputs include, without limitation, property descriptions, market commentary, valuation suggestions, document drafts, image enhancements, translations, OCR-extracted document data, vector-search matching results, and conversational responses ("AI Output").

8.2 No Warranty of Accuracy. AI OUTPUT IS PROVIDED ON AN "AS-IS" AND "AS-AVAILABLE" BASIS WITHOUT ANY WARRANTY OF ACCURACY, COMPLETENESS, CURRENCY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT, OR MERCHANTABILITY. AI Output may contain errors, omissions, hallucinations, factual inaccuracies, biases, or out-of-date information. Pammo makes no representation or warranty regarding any AI Output.

8.3 No Warranty Regarding Property Data. Property data displayed in the Service — including listings, prices, addresses, square footage, ownership records, zoning information, condominium foreign-quota status, foreign-ownership restrictions, market estimates, comparable sales, and rental yields ("Property Data") — is aggregated from public sources, partner integrations, scraped public listings, and User submissions. Pammo does not guarantee the accuracy, currency, completeness, legality, or availability of any Property Data. Property listings may be outdated, withdrawn, mispriced, or fraudulent.

8.4 No Legal, Financial, Tax, or Investment Advice. AI Output and Property Data do not constitute legal advice, financial advice, tax advice, investment advice, real-estate brokerage advice, valuation reports, appraisals, title reports, or professional opinions of any kind. Documents drafted with the assistance of the Service (including contracts) are template aids only, are not reviewed by licensed attorneys, and must not be relied upon as final legal instruments without independent legal review.

8.5 User Responsibility for Due Diligence. You are solely and exclusively responsible for conducting your own independent due diligence prior to making any decision based on the Service, including:

(a) verifying property ownership, title, encumbrances, and legal status with the Land Department or qualified counsel; (b) confirming pricing, condition, square footage, and physical attributes through site inspections and licensed appraisers; (c) consulting licensed real estate brokers, attorneys, accountants, or financial advisors for transactional advice; (d) verifying foreign-ownership eligibility, condominium foreign-quota status, lease structures, and visa / tax implications; (e) confirming the identity, capacity, and authority of any counterparty; and (f) reviewing all documents with qualified counsel before execution.

8.6 No Liability for Decisions. Pammo shall bear no liability whatsoever for any decision, action, omission, transaction, loss, damage, or harm arising from or related to your reliance on AI Output or Property Data, including lost profits, lost opportunities, transactional losses, fraud losses, foreign-ownership disqualification, contract disputes, or any other direct, indirect, incidental, consequential, or punitive damages — subject to the §15 carve-outs.

8.7 Reporting Inaccuracies. Pammo welcomes reports of inaccurate or fraudulent listings via the in-Service reporting tools or to support@pammo.co. Pammo will use reasonable efforts to investigate verified reports.

8.8 AI-Specific Rules. AI use is governed in addition by Pammo-Acceptable-Use-Policy-V1 §5 — including no deepfakes of real persons without consent; AI disclosure requirements where mandated by law (FTC AI Endorsement Guides, China Deep Synthesis Regulations, EU AI Act provisions applicable to generated content); no representation of AI Output as legal / financial / medical / tax / psychological advice; mandatory human review before commercial deployment; and the prohibition on training competing AI models with Pammo Output.

9. INTELLECTUAL PROPERTY OWNERSHIP

9.1 Pammo Intellectual Property. All right, title, and interest in and to the Service — including all software, source code, object code, AI models, model weights, fine-tunes, training data, algorithms, designs, user interfaces, trademarks, service marks, trade names, logos, documentation, and all related intellectual-property rights (collectively, "Pammo IP") — are and shall remain the exclusive property of Pammo and its licensors. No license is granted to you except as expressly set forth in these Terms.

9.2 Limited License to Users. Subject to your continued compliance with these Terms, Pammo grants you a limited, non-exclusive, non-transferable, non-sublicensable, revocable license to access and use the Service for your internal business or personal use during the term of your active subscription.

9.3 User Input. You retain all ownership rights in any data, text, images, documents, listings, contact information, or other content that you upload, submit, or input into the Service ("User Input"). By submitting User Input, you grant Pammo a worldwide, royalty-free, sublicensable, transferable license to host, store, reproduce, modify, create derivative works of, transmit, display, and distribute User Input solely to the extent necessary to (a) provide and improve the Service to you and other Users; (b) train, fine-tune, evaluate, and benchmark Pammo's AI models and analytics (subject to applicable data-protection laws and your consent under §13–§13B where required); (c) generate aggregated, de-identified analytics; and (d) comply with legal obligations.

9.4 AI-Generated Output — Allocation of Rights.

(a) Ownership. To the maximum extent permitted by law, you may use AI Output generated through your use of the Service for any lawful business or personal purpose, including commercial purposes.

(b) Non-Exclusivity. AI Output is generated probabilistically; other Users may receive identical or substantially similar Output in response to similar prompts. You do not have exclusive rights in AI Output.

(c) Reservation. Pammo and its licensors retain all rights in the underlying AI models, generation methodology, prompts, system instructions, and any technical components used to produce AI Output.

(d) No Warranty of Copyrightability. AI Output may not be eligible for copyright protection in some jurisdictions (including the United States, where purely AI-generated works lacking sufficient human authorship are not registrable per US Copyright Office guidance and Thaler v. Perlmutter). Pammo makes no representation or warranty regarding the copyrightability of any AI Output.

9.5 Restrictions on AI Output. You shall not:

(a) use AI Output to develop, train, or improve any AI model that competes with Pammo; (b) misrepresent AI Output as having been verified, audited, or endorsed by Pammo or any licensed professional; (c) use AI Output in any manner that violates applicable law or third-party rights.

9.6 Listing Data. Property listings created through the Service that incorporate User Input remain owned by the respective Users; Pammo retains a license to display, distribute, and syndicate such listings as part of the Service. Aggregated, de-identified market data derived from the Service is owned by Pammo.

9.7 Feedback. If you provide Pammo with suggestions, feature requests, ideas, comments, or feedback regarding the Service ("Feedback"), you assign to Pammo all right, title, and interest in such Feedback. Pammo may use Feedback freely without obligation or compensation.

10. USER OBLIGATIONS AND PROHIBITED USE

10.1 General Obligations. You agree to use the Service only for lawful purposes and in compliance with these Terms, the Pammo Acceptable Use Policy, all applicable laws and regulations, and the rules of any relevant professional, governmental, or industry body (including the Real Estate Brokers Act B.E. 2557 (2014) and the regulations of the Real Estate Brokers Association of Thailand where applicable to you).

10.2 Prohibited Conduct. You shall not, and shall not permit any third party to:

(a) Scraping & Automation. Scrape, crawl, harvest, index, or otherwise extract data from the Service through automated means, except via documented APIs and within published rate limits.

(b) Fake or Fraudulent Listings. Post, upload, or generate any property listing that is false, deceptive, misleading, fictitious, fraudulent, or that you do not have legitimate right to list.

(c) MLS / Property-Portal Violations. Violate the rules of any Multiple Listing Service ("MLS"), property portal (e.g., DDproperty, Hipflat, Baania, Estopolis), real-estate board, condominium-juristic-person data source, or similar industry source.

(d) IP Infringement. Upload, post, distribute, or use content that infringes any patent, trademark, trade secret, copyright, right of publicity, moral right, or other intellectual-property right of any third party.

(e) Spam & Unsolicited Communications. Use the Service to send spam, unsolicited messages, mass marketing, phishing, or any communication in violation of anti-spam laws (including Thailand PDPA marketing provisions, Singapore Spam Control Act 2007, EU Directive 2002/58/EC, and analogous laws).

(f) Competitor Scraping. Use the Service to scrape, harvest, or extract data from competitors of Pammo, third-party property portals, or any source where such extraction would violate the source's terms of service or applicable law (including the Thai Computer-Related Crime Act B.E. 2550 (2007)).

(g) Reverse Engineering. Reverse-engineer, decompile, disassemble, or attempt to derive the source code, models, weights, or training data of the Service, except to the extent expressly permitted by mandatory law.

(h) Security Bypass. Bypass, disable, or interfere with any security, rate-limit, watermark, or access-control feature of the Service.

(i) Misuse of AI. Use the Service to generate content that is unlawful, defamatory, obscene, hateful, violent, sexually explicit (involving minors or non-consensual subjects), or otherwise harmful (per Pammo-Acceptable-Use-Policy-V1 §3).

(j) Account Abuse. Create multiple accounts to circumvent quotas, evade bans, or manipulate FGF / Affiliate / Creator referral programs.

(k) Resale. Resell, sublicense, lease, rent, or otherwise commercially exploit the Service or AI Output without Pammo's prior written authorization.

(l) Malicious Code. Upload or transmit any virus, worm, Trojan horse, ransomware, or other malicious code.

(m) Impersonation. Impersonate any person, entity, or licensed professional, or misrepresent your affiliation with any person or entity.

(n) Fair Housing & Anti-Discrimination. Use the Service to engage in or facilitate housing discrimination in violation of the Thai Constitution §27, the EU Race Equality Directive 2000/43/EC, the U.S. Fair Housing Act (42 USC §3601 et seq.), or analogous fair-housing laws of your jurisdiction, on the basis of race, color, religion, national origin, gender, sexual orientation, gender identity, disability, family status, source of income, age (where protected), or any other protected characteristic. You are responsible for ensuring that prompts, listings, audience targeting, and AI Output do not encode discriminatory preferences (e.g., "no children", "Thai-buyers-only" without the lawful foreign-quota basis, etc.).

(o) Money Laundering / Sanctions. Use the Service to facilitate money laundering, terrorist financing, sanctions evasion, or any other financial crime — in compliance with the Thai Anti-Money Laundering Act B.E. 2542, Singapore Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act, and applicable sanctions regimes (UN, US OFAC, EU, UK OFSI, Thailand AMLO, MAS Singapore).

(p) Interference. Interfere with or disrupt the integrity, performance, or availability of the Service or any User's enjoyment of the Service.

10.3 Compliance with Real Estate Laws. Users who are licensed real estate professionals undertake to comply with all licensing requirements, ethical codes, and disclosure obligations applicable to their profession in their jurisdiction, including the Thai Real Estate Brokers Act, the Condominium Act B.E. 2522, the Land Code, and applicable foreign-ownership rules.

10.4 Right to Investigate and Enforce. Pammo reserves the right (but assumes no obligation) to investigate any suspected violation of this §10 or the AUP, to remove or modify offending content, to suspend or terminate offending accounts, and to cooperate with law-enforcement authorities. Pammo may freeze and forfeit accrued FGF, Affiliate, or Creator earnings of any User found to be in material breach.

11. AFFILIATE, FGF, AND CREATOR PROGRAM REFERENCES

11.1 FGF Program. Pammo operates a "Friend-Get-Friend" program ("FGF Program") open to every User from the day of account creation. FGF rewards are issued as Product Credit (credit / Discovery credit bonus) per the D-07 V1 Lock canonical mechanism — not as THB voucher defer. The full FGF rules are set out in the Program Rules §3 and the underlying FGF + Affiliate Business Rules V3 §2.

11.2 Affiliate Program. Pammo operates an Affiliate Program governed by the Pammo Affiliate Program Terms. Commission tiers are Starter 15% / Growth 17% / Elite 20% (recurring × 12 months on actual paid revenue). Affiliate cookie duration: 60 calendar days, first-click wins. See Pammo-Program-Rules-V1 §4.

11.3 Creator Program. Pammo operates a Pammo Creator Program governed by the Pammo Creator Program Terms. Creator tiers override Affiliate tiers: Pro Creator 13% (followers ≥ 5K, 4 content units / month including ≥ 1 long-form) and Elite Creator 15% (followers ≥ 20K, 7 content units / month including ≥ 2 long-form). Creator Commission is CASH PAYOUT ONLY. Cookie duration: 60 days. Three-strike removal with 3-month wind-down. Annual recognition is non-cash (Top 1 / Top 3 / Top 10 prestige tiers). See Pammo-Program-Rules-V1 §5 and Pammo-Creator-Program-V1 §3 + §5 + §6.

11.4 Earnings, Hold Periods, and Forfeiture. Hold period: 14 calendar days post-activation. Minimum payout: THB 500 (or USD-equivalent). Payout frequency: monthly on the 15th. Earnings, anti-fraud forfeiture rules, refund clawback, chargeback recovery, and dispute mechanisms are set forth in the Affiliate Terms, the Creator Terms, and the Program Rules §8.

11.5 Independent Contractor. Participation in any Pammo program does not create any employment, agency, partnership, or joint-venture relationship between you and Pammo. You participate strictly as an independent contractor.

11.6 Tax Responsibility for Earnings. You are solely responsible for declaring and paying all taxes applicable to earnings received under any Pammo program in your jurisdiction of residence. Pammo issues withholding-tax certificates (TH WHT Phor Ngor Dor 50 / 50 ทวิ) and collects W-9 / W-8BEN / W-8BEN-E for non-SG-resident international counterparties as required.

11.7 Conflict. In the event of a conflict between these Terms and any program-specific terms (FGF / Affiliate / Creator), the program-specific terms control on program-specific matters; these Terms control on all other matters.

12. DATA PRIVACY AND PDPA / GDPR COMPLIANCE

12.1 Privacy Notice. Pammo's collection, use, storage, disclosure, and processing of personal data is described in detail in the Pammo Privacy Notice, which is incorporated by reference into these Terms.

12.2 Roles under PDPA / GDPR. For personal data of Users (registration, billing, account, audit, security telemetry), the Pammo entities act jointly as Data Controllers within the meaning of Thailand PDPA, Singapore PDPA, and GDPR, with primary-controller-and-DPO contact through the Singapore-incorporated entity (AEDOWON SINGAPORE PTE. LTD., DPO: dpo@pammo.co) and local-controller-co-responsibility at AEDOWON CO., LTD for Thai-resident Users. The joint-controller arrangement is described in Pammo-Privacy-Notice-V1 §1.

For personal data of third parties uploaded by Users into the Service (e.g., contact information of leads, prospective buyers / tenants, customer audience data), Pammo acts primarily as a Data Processor acting on the User's instructions, and the User is the Data Controller of such data. See §12.2A below and Data Processing Addendum.

12.2A Pammo's Processor Obligations for User-Uploaded Third-Party Data. Where Pammo acts as a Processor on the User's behalf for User-uploaded third-party personal data (the "Processed Data"), Pammo undertakes to:

(a) process Processed Data only on the User's documented instructions — including with regard to cross-border transfers — except where required by EU / Thai / Singapore / UK law, in which case Pammo will inform the User of that legal requirement before processing (unless prohibited);

(b) ensure that personnel authorized to process Processed Data have committed themselves to confidentiality;

(c) implement appropriate technical and organizational security measures consistent with Thailand PDPA §37, Singapore PDPA §24, and GDPR Art 32;

(d) not engage another processor (sub-processor) without the User's prior general written authorization, and notify the User of any intended changes per the 30-day prior-notice mechanism in Pammo-Sub-Processor-List-V1 §1 + Pammo-Data-Processing-Addendum-V1 §7;

(e) assist the User in responding to data-subject-rights requests under Thailand PDPA §§30–37 / GDPR Arts 15–22 / Singapore PDPA §§21–22;

(f) assist the User with breach notification, DPIA, and consultation obligations under GDPR Arts 32–36 / Thailand PDPA §§37, 39 / Singapore PDPA §§26B–26D;

(g) at the User's choice, delete or return Processed Data after the end of the provision of services and delete copies, unless retention is required by law;

(h) make available to the User all information necessary to demonstrate compliance with this §12.2A and allow audits, including inspections, conducted by the User or a mandated auditor on reasonable advance notice and subject to confidentiality (per Pammo-Data-Processing-Addendum-V1 §9).

The Processed Data, retention period, processing purposes, categories of data subjects, and approved sub-processors are set out in Schedule A — Data Processing Particulars to these Terms (drafted in full in the Data Processing Addendum §4–§6 and Annex II).

12.3 Lawful Bases for Processing. Pammo processes personal data on the following lawful bases under PDPA / GDPR:

(a) performance of these Terms (contract — GDPR Art 6(1)(b); Thailand PDPA §24(3); Singapore PDPA §13); (b) compliance with legal obligations (GDPR Art 6(1)(c); Thailand PDPA §24(1)); (c) legitimate interests, including service improvement, security, fraud prevention, and program-attribution (GDPR Art 6(1)(f); Thailand PDPA §24(5)); (d) explicit consent (for marketing and certain optional processing — §13A and §13B); (e) protection of vital interests, where applicable.

12.4 Data Subject Rights. Subject to applicable PDPA / GDPR / SG PDPA, you have the right to:

(a) be informed of the categories of personal data collected, the purposes of processing, retention periods, recipients, and the source where data is collected from third parties (Thailand PDPA §23 / GDPR Art 13–14 / Singapore PDPA §20); (b) access your personal data and obtain a copy (Thailand PDPA §30 / GDPR Art 15 / Singapore PDPA §21); (c) request data portability in a commonly used, machine-readable format (Thailand PDPA §31 / GDPR Art 20); (d) object to processing on grounds set out in Thailand PDPA §32, including direct marketing, profiling, and processing based on legitimate interest; (e) request erasure ("right to be forgotten") where the conditions in Thailand PDPA §33 / GDPR Art 17 apply, subject to lawful retention obligations; (f) request restriction of processing (Thailand PDPA §34 / GDPR Art 18); (g) request rectification or completion of inaccurate or incomplete personal data (Thailand PDPA §§35–36 / GDPR Art 16); (h) withdraw consent at any time, without retroactive effect (Thailand PDPA §19 / GDPR Art 7(3) / Singapore PDPA §16); (i) lodge a complaint with the Personal Data Protection Committee (PDPC) of Thailand, the Personal Data Protection Commission of Singapore, your local supervisory authority under GDPR, the UK Information Commissioner's Office (ICO), or the U.S. state attorney general (for CCPA / CPRA / VCDPA / CPA / CTDPA / UCPA), as applicable.

To exercise these rights, contact dpo@pammo.co. Response timeline: 30 calendar days of receipt (extendable by a further 60 days for complex requests with notice and reasons within the original 30 days), in accordance with Thailand PDPA §32, Singapore PDPA §21(2), and GDPR Art 12(3). Withdrawal of consent processed within 7 calendar days of valid request.

12.5 Cross-Border Data Transfers. Pammo may transfer personal data to servers, sub-processors, or affiliates located outside Thailand, Singapore, or the EU/EEA, including to the United States, the European Union, the United Kingdom, Singapore, Hong Kong, Japan, and other jurisdictions. Such transfers are made under one or more of the following safeguards:

(a) adequacy decision (Thailand PDPA §28(2) / GDPR Art 45); (b) Standard Contractual Clauses approved by the European Commission (Decision 2021/914) or by the Thailand PDPC, or Binding Corporate Rules approved by the competent supervisory authority (Thailand PDPA §28(3) / GDPR Art 46); (c) User's explicit consent after being informed of the absence of adequate safeguards and the resulting risks (Thailand PDPA §28 ¶2(2) / GDPR Art 49(1)(a)); (d) necessity for performance of the contract with the User or pre-contractual measures (Thailand PDPA §28 ¶2(3) / GDPR Art 49(1)(b)); (e) other lawful mechanisms recognized by the PDPC or under GDPR.

A current list of recipient jurisdictions and safeguards by sub-processor is published in the Pammo Sub-Processor List.

12.6 Property Listing Data vs Personal Data. Property Listing Data (property attributes, addresses, prices, photographs, descriptions) is treated as business data and content data, not personal data, except to the extent it embeds identifiable information about a natural person (e.g., owner names, agent contacts). Where Property Listing Data contains personal data, you warrant that you have obtained all necessary consents, lawful bases, and authorizations from the relevant data subjects under PDPA, Singapore PDPA, and GDPR.

12.7 Data Retention. Pammo retains personal data only for as long as necessary to (i) provide the Service; (ii) comply with legal obligations — including a minimum five (5) year retention of accounting and tax records under Thai Revenue Code §87/3, the Thai Accounting Act B.E. 2543 §14, the Singapore Companies Act §199, and the Singapore Income Tax Act §67; (iii) resolve disputes; and (iv) enforce these Terms. After the applicable retention period, personal data is securely deleted or irreversibly anonymized. See Pammo-Privacy-Notice-V1 §6 for the detailed schedule.

12.8 Data Security. Pammo implements administrative, technical, and physical safeguards — including encryption at rest (AES-256 or equivalent) and in transit (TLS 1.2+, TLS 1.3 preferred), role-based access control, multi-factor authentication, audit logging, and incident-response procedures — to protect personal data against unauthorized access, alteration, disclosure, or destruction. Full Technical and Organizational Measures (TOMs) are documented in Pammo-Data-Processing-Addendum-V1 §11 (Annex II).

12.9 Breach Notification. In the event of a personal data breach that poses a risk to the rights and freedoms of data subjects, Pammo will notify:

(a) the Thailand PDPC within seventy-two (72) hours of becoming aware of the breach where required by Thailand PDPA §39; (b) the Singapore PDPC within three (3) calendar days of a credible assessment per Singapore PDPA §26B-26D and the Notifiable Data Breaches Regulations 2021; (c) the lead EU/EEA supervisory authority within seventy-two (72) hours under GDPR Art 33–34; (d) the affected Users without undue delay where high risk to rights and freedoms is involved.

13. ACCEPTANCE OF TERMS & SERVICE-NECESSARY PROCESSING (REQUIRED — SINGLE CHECKBOX)

13.1 Required Consent — Single Checkbox. By checking the "I Agree" checkbox, you confirm that you:

(a) have read, understood, and agree to be bound by these Terms and the Pammo Privacy Notice;

(b) consent to Pammo's processing of your personal data as strictly necessary for the registration, provision, billing, security, support, audit, and lawful operation of the Service; and

(c) consent to the cross-border transfer of your personal data to Pammo's affiliates and sub-processors located outside Thailand for the sole purposes set out in (b), under the safeguards in §12.5.

13.2 Why This Consent Is Required. Refusal of this consent means we cannot provide you with the Service because the listed processing is essential to performance of the contract under Thailand PDPA §24(3), Singapore PDPA §13, and GDPR Art 6(1)(b).

13.3 Consent Record. Pammo maintains a record of date, time, IP address, T&C version, and Privacy Notice version associated with each consent capture, retained per Pammo-Privacy-Notice-V1 §6.

13.4 Consequences of Refusal. If you refuse the required consent in §13.1, you cannot register for or use the Service because the listed processing is necessary to perform this Agreement. Refusal of the optional marketing consent in §13A or the optional extra-territorial marketing transfer consent in §13B has no effect whatsoever on your access to or use of the Service, your subscription, or your participation in any Pammo program.

13A. MARKETING CONSENT (OPTIONAL — SEPARATE CHECKBOX)

13A.1 Optional Marketing Consent. Separately and optionally, you may opt in to receive marketing communications from Pammo by checking a distinct, pre-unchecked checkbox. Marketing includes promotional emails, SMS, push notifications, in-app messaging, LINE OA broadcasts, and personalized advertising. Refusal has no effect on your access to the Service.

13A.2 Verbatim Checkbox Text.

☐ I would like to receive marketing communications from Pammo (product updates, promotions, recommendations, and event invitations) by email, SMS, in-app notification, push notification, and LINE. I can withdraw consent at any time.

13A.3 Withdrawal. You may withdraw marketing consent at any time without effect on Service access, by adjusting privacy settings or emailing dpo@pammo.co. Withdrawal is processed within 7 calendar days.

13B. EXTRA-TERRITORIAL MARKETING TRANSFER (OPTIONAL — SEPARATE CHECKBOX, ONLY IF MARKETING CONSENT GIVEN)

13B.1 Optional Extra-Territorial Marketing Transfer. If you opt in to marketing under §13A, you may further opt in (via a distinct, pre-unchecked checkbox) to the disclosure of your data to Pammo's marketing service providers and advertising-platform sub-processors located outside Thailand (e.g., Meta, Google, TikTok, LINE) under the safeguards in §12.5. Per-network granularity applies — you may consent to specific networks individually.

13B.2 Refusal of §13B has no effect on your access to or use of the Service or on the validity of §13A consent.

13B.3 Withdrawal. You may withdraw per-network sub-consents at any time via Account → Privacy → Ad-Network Sharing or by emailing dpo@pammo.co.

14. NEWSLETTER SUBSCRIPTION CONSENT — SEPARATE OPT-IN

14.1 Optional, Separate Consent. In addition to §§13–13B, Users may separately and optionally opt in to receive Pammo's periodic newsletter by checking a distinct checkbox labeled, e.g., "Subscribe me to the Pammo newsletter". The newsletter checkbox is unticked by default and not bundled with any other consent.

14.2 Content. The newsletter may include real-estate market insights, product updates, educational content, success stories, industry research, and occasional partner offers.

14.3 Independent Withdrawal. Unsubscribe via the link in any newsletter email, your account dashboard, or newsletter@pammo.co. Unsubscribing from the newsletter does not affect any other consent.

14.4 No Penalty. Refusal or unsubscription has no effect on Service access.

15. LIMITATION OF LIABILITY

15.1 Disclaimer of Warranties. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE SERVICE, AI OUTPUT, AND PROPERTY DATA ARE PROVIDED "AS IS" AND "AS AVAILABLE", WITHOUT WARRANTY OF ANY KIND, EXPRESS, IMPLIED, OR STATUTORY — including without limitation any implied warranty of merchantability, fitness for a particular purpose, accuracy, completeness, non-infringement, quiet enjoyment, system integration, or freedom from computer viruses or other harmful components. Pammo does not warrant that the Service will be uninterrupted, timely, secure, or error-free.

15.2 Decisions Made From AI = User's Responsibility. ANY DECISION YOU MAKE OR ACTION YOU TAKE BASED ON AI OUTPUT, PROPERTY DATA, PANNORA CO-PILOT RECOMMENDATIONS, GENERATED CONTRACTS, OR ANY OTHER OUTPUT OF THE SERVICE IS UNDERTAKEN AT YOUR OWN AND SOLE RISK AND RESPONSIBILITY. Pammo is not your real estate broker, lawyer, accountant, financial advisor, valuer, or fiduciary, and shall bear no liability for any decision, transaction, loss, or damage arising therefrom.

15.3 Cap on Direct Damages. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, PAMMO'S TOTAL AGGREGATE LIABILITY ARISING OUT OF OR RELATED TO THESE TERMS OR THE SERVICE, REGARDLESS OF THE FORM OF ACTION, SHALL NOT EXCEED THE GREATER OF:

(a) the total fees actually paid by you to Pammo in the twelve (12) months immediately preceding the event giving rise to the claim, OR (b) FIVE THOUSAND THAI BAHT (THB 5,000) or ONE HUNDRED U.S. DOLLARS (US$100), WHICHEVER IS GREATER.

The cap in this §15.3 does not apply to (i) liability that cannot be excluded or limited under mandatory applicable law (including non-waivable statutory data-protection damages under Thailand PDPA §77, Singapore PDPA §32, GDPR Art 82); (ii) Pammo's gross negligence or willful misconduct; (iii) fraud or fraudulent misrepresentation; (iv) death or personal injury caused by Pammo's negligence; or (v) Pammo's express indemnification obligations under these Terms.

15.4 Exclusion of Indirect Damages. IN NO EVENT SHALL PAMMO, ITS AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES, OR LICENSORS BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, including lost profits, lost savings, lost business opportunity, loss of goodwill, loss of data, loss of property transactions, fraud losses, or substitute service costs, even if Pammo has been advised of the possibility of such damages — subject to the §15.5 carve-outs.

15.5 Carve-Outs. The limitations in this §15 shall not apply to: (a) liability that cannot be excluded or limited under mandatory applicable law; (b) Pammo's gross negligence or willful misconduct; (c) fraud or fraudulent misrepresentation; (d) death or personal injury caused by Pammo's negligence; (e) breaches of intellectual-property rights by either party; or (f) Pammo's express indemnification obligations.

15.6 Essential Basis of Bargain. You acknowledge that the limitations of liability in this §15 are an essential basis of the bargain between you and Pammo, and that the Service would not be provided to you absent such limitations.

16. INDEMNIFICATION

16.1 Your Indemnification. You agree to defend, indemnify, and hold harmless Pammo, its affiliates (including both AEDOWON CO., LTD and AEDOWON SINGAPORE PTE. LTD.), officers, directors, employees, contractors, agents, and licensors (the "Indemnified Parties") from and against any and all claims, demands, suits, proceedings, liabilities, damages, losses, judgments, fines, penalties, costs, and expenses (including reasonable attorneys' fees) arising out of or related to:

(a) your access to or use of the Service; (b) your User Input, including any allegation that User Input infringes any third-party right or violates any law; (c) any property listing or document you create, publish, or transmit through the Service; (d) any decision or transaction you undertake in reliance on AI Output, Property Data, or generated documents; (e) your violation of these Terms, the AUP, the Privacy Notice, the Program Rules, the Affiliate or Creator Program Terms, or any applicable law; (f) your violation of any third-party right (including intellectual-property, privacy, or contractual rights); (g) any dispute between you and another User, counterparty, or third party arising in connection with the Service; (h) your participation in the FGF, Affiliate, or Creator Programs; (i) any tax liability arising from your earnings under the FGF, Affiliate, or Creator Programs.

16.2 Procedure. Pammo will (a) promptly notify you in writing of any claim subject to indemnification (failure to give prompt notice does not relieve you of obligations except to the extent you are materially prejudiced); (b) permit you, at your expense, to assume sole control of the defense and settlement; and (c) provide reasonable cooperation at your expense. Pammo reserves the right, at its own expense, to assume the exclusive defense and control of any matter otherwise subject to indemnification by you, in which event you shall cooperate with Pammo. You may not settle any claim without Pammo's prior written consent where the settlement (i) admits any liability or wrongdoing by Pammo, (ii) imposes any non-monetary obligation on Pammo, or (iii) does not include a full release of Pammo.

17. TERMINATION

17.1 Termination by User. You may terminate these Terms at any time by cancelling all subscriptions and requesting account deletion through your account settings or by writing to support@pammo.co. Cancellation under §4.5 takes effect at the end of the current Billing Cycle; account deletion takes effect promptly thereafter, subject to lawful retention obligations under §12.7.

17.2 Termination by Pammo Without Cause. Pammo may terminate these Terms or suspend or close your account, for convenience and without cause, upon thirty (30) calendar days' prior written notice (sent via email to your registered address). In such event, Pammo refunds the pro-rata unused portion of any prepaid Subscription Fees and the unused balance of Prepaid Credits, provided you are not in material breach of these Terms.

17.3 Termination by Pammo With Cause. Pammo may immediately suspend or terminate your account, without prior notice and without refund, if you:

(a) materially breach these Terms, the AUP, the Program Rules, the Affiliate or Creator Terms, or applicable law; (b) engage in fraud, abuse, manipulation of programs, or chargeback abuse; (c) become subject to insolvency, bankruptcy, or liquidation proceedings; (d) fail to pay amounts due after a reasonable grace period; (e) become a sanctioned person or entity, or operate from a sanctioned jurisdiction; (f) pose a security risk to the Service or other Users.

17.4 Effect of Termination. Upon termination:

(a) your license to use the Service immediately ceases; (b) Pammo may delete your User Input following a reasonable grace period (typically 30 days), subject to lawful retention obligations; (c) you remain liable for all fees and charges accrued prior to termination; (d) sections that by their nature should survive (including §§7, 8, 9, 12, 15, 16, 17.4, 18, 19, and 20) shall survive termination; (e) where you are terminated for cause under §17.3, accrued FGF, Affiliate, and Creator earnings may be forfeited per the Program Rules §8 and the Affiliate / Creator Terms.

17.5 Data Export. For a period of thirty (30) calendar days following termination (other than for-cause termination under §17.3), Pammo provides reasonable mechanisms for you to export your User Input in a commonly-used format. Thereafter, User Input may be irretrievably deleted, subject to lawful retention.

18. DISPUTE RESOLUTION AND GOVERNING LAW

18.1 Dual Governing Law (per Route).

(a) TH Route (User contracts with AEDOWON CO., LTD): governed by the laws of the Kingdom of Thailand, without regard to its conflict-of-laws principles.

(b) International Route (User contracts with AEDOWON SINGAPORE PTE. LTD.): governed by the laws of the Republic of Singapore, without regard to its conflict-of-laws principles.

In each case, the United Nations Convention on Contracts for the International Sale of Goods (CISG) is expressly excluded.

18.2 Good-Faith Negotiation. The parties shall use good-faith efforts to resolve any dispute amicably through written notice and direct negotiation between authorized representatives for a period of thirty (30) calendar days before initiating any formal proceedings.

18.3 Mediation. If the dispute is not resolved through negotiation, the parties may, by mutual agreement, refer the dispute to mediation:

• TH Route: Thailand Arbitration Center (THAC) or another mediation body mutually agreed.
• International Route: Singapore International Mediation Centre (SIMC) or another mediation body mutually agreed.

18.4 Arbitration.

(a) Consumer Carve-Out — Thailand. This §18.4 does not apply to claims brought by a User who is a "consumer" under the Thailand Consumer Protection Act B.E. 2522. A Thai consumer-User retains the unwaivable right to bring claims before the consumer courts of competent jurisdiction in Thailand pursuant to the Consumer Case Procedure Act B.E. 2551 (2008), and Pammo agrees to be bound by such consumer-court jurisdiction.

(b) Consumer Carve-Out — Other Jurisdictions. Where mandatory consumer-protection law of your jurisdiction grants you non-waivable access to local consumer courts or to a small-claims procedure, you retain that right notwithstanding this §18.4.

(c) Non-Consumer Disputes — TH Route. Disputes not subject to (a) shall be finally settled by arbitration administered by the Thai Arbitration Institute (TAI) under its Arbitration Rules in effect at the time of filing. Seat: Bangkok. Language: Thai or English at claimant's election. Award final and binding.

(d) Non-Consumer Disputes — International Route. Disputes not subject to (b) shall be finally settled by arbitration administered by the Singapore International Arbitration Centre (SIAC) under its Arbitration Rules in effect at the time of filing. Seat: Singapore. Language: English. Award final and binding.

18.5 Court Jurisdiction (Carve-Outs). Notwithstanding §18.4, either party may bring proceedings in the courts of the applicable governing-law jurisdiction (Thai courts in Bangkok for TH Route; Singapore courts for International Route) for (a) injunctive or equitable relief to prevent imminent or continuing infringement of intellectual-property rights or breach of confidentiality, or (b) collection of undisputed amounts owed.

18.6 Class Action Waiver. To the maximum extent permitted by applicable law, you and Pammo agree that any dispute shall be resolved on an individual basis and not as part of any class, consolidated, or representative action. This waiver does not apply where prohibited by mandatory consumer-protection law (including the Thai Consumer Case Procedure Act §41 class-action mechanism, where applicable).

18.7 Time Limit for Claims. Any claim arising out of or related to these Terms or the Service must be commenced within one (1) year after the cause of action accrues, or within such longer period as required by mandatory law. After such period, the claim is permanently barred.

18.8 Equitable Relief. You acknowledge that breaches of §9 (IP) and §10 (Prohibited Use) may cause irreparable harm to Pammo for which monetary damages are inadequate, and that Pammo shall be entitled to seek injunctive and equitable relief without the need to post a bond.

19. CHANGES TO TERMS

19.1 Right to Amend. Pammo reserves the right to modify, amend, supplement, or replace these Terms at any time, in its sole discretion, to reflect changes in the Service, business practices, legal or regulatory requirements, or industry standards.

19.2 Notification Mechanism. Pammo notifies Users of material changes by:

(a) posting the updated Terms with an updated "Last Updated" date and version number; (b) displaying an in-Service notification, banner, or modal upon the User's next login following the change; (c) where the change is material and adverse, sending an email at least fourteen (14) calendar days prior to the effective date.

19.3 Acceptance of Amended Terms. Your continued access or use of the Service after the effective date constitutes acceptance of the amended Terms. If you do not agree, you may stop using the Service and cancel per §4.5.

19.4 Material Adverse Changes — Right to Cancel. For any material amendment that adversely affects your rights, you may cancel your subscription at any time prior to the effective date and receive a pro-rata refund of any prepaid Subscription Fees for the unused portion of the then-current Billing Cycle. This right does not extend to consumed Per-Credit Fees or used Prepaid Credits.

19.5 Versioning. A historical archive of prior versions of these Terms is maintained and available upon request at legal@pammo.co.

20. CONTACT INFORMATION

20.1 Pammo Operating Entities.

Thailand operations: AEDOWON CO., LTD Thai Tax ID / Company Registration No.: 0105568220777 250/207 SOI BUDDHAMONDON SAI 2 SOI 32, SALATHAMMASOP, TAWEWATTANA, BANGKOK 10170, THAILAND

International operations: AEDOWON SINGAPORE PTE. LTD. UEN: 202612161D 8 TEMASEK BOULEVARD, #17-02A, SUNTEC TOWER THREE, SINGAPORE 038988

20.2 Contact Channels.

20.3 Postal Notices. Postal notices to Pammo shall be sent to the registered office of the contracting entity (TH or SG), marked for the attention of the Legal Department.

20.4 Notices to Users. Notices shall be sent to the email address on the User's account or via in-Service notification and are deemed received upon transmission.

20.5 Language. These Terms are drafted in the English language; a Thai-language translation may be made available for convenience. In the event of inconsistency between the English and Thai versions, the English version prevails for legal interpretation, except where Thai law mandates that the Thai version govern in dealings with Thai consumers — in which case the Thai version prevails to the extent of such mandate.

ANNEX A — DEFINITIONS QUICK REFERENCE

SCHEDULE A — DATA PROCESSING PARTICULARS (REFERENCE TO DPA)

Schedule A, required by §12.2A and by Thailand PDPA §40 / GDPR Art 28(3), is set out in full in the Pammo Data Processing Addendum:

• §4 — Nature and Purpose of Processing
• §5 — Categories of Data Subjects and Personal Data
• §6 — Processor Obligations (PDPA §40 / GDPR Art 28(3)(a)–(h))
• §7 — Sub-Processors (with reference to Pammo-Sub-Processor-List-V1)
• §8 — International Transfers
• §9 — Audit
• §10 — Retention and Deletion
• §11 (Annex II) — Technical and Organizational Measures (TOMs)
• §12 — Breach Notification
• §13 — Data Subject Requests

This Schedule A is fully drafted as of the V1 publication and is not subject to a [TBD] placeholder.

ACKNOWLEDGMENT

BY CLICKING "I AGREE" / "ยอมรับ" OR BY ACCESSING OR USING THE SERVICE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS AND CONDITIONS, INCLUDING THE DUAL-ENTITY ALLOCATION (SECTION 0), THE EXTRA USAGE TERMS (SECTION 5), THE DYNAMIC PRICING CLAUSE (SECTION 6), THE REFUND POLICY (SECTION 7), THE LIMITATIONS OF LIABILITY (SECTION 15), THE DISPUTE RESOLUTION PROVISIONS (SECTION 18), AND THE REQUIRED CONSENT (SECTION 13). MARKETING CONSENT (SECTION 13A), EXTRA-TERRITORIAL MARKETING TRANSFER CONSENT (SECTION 13B), AND NEWSLETTER CONSENT (SECTION 14) ARE OPTIONAL AND PRESENTED AS SEPARATE CHECKBOXES; REFUSAL OF ANY OF THESE HAS NO EFFECT ON YOUR ACCESS TO THE SERVICE.

CHANGE LOG — V1

V1 (2026-05-18) — initial publication-ready draft. Built from the V1.1 baseline (2026-04-29 Pammo-Terms-Conditions-V1) with the following major redlines applied:

• Dual-entity Operating Structure (Preamble + §0): replaced the single-entity preamble with dual-entity geo-routing AEDOWON CO., LTD via Omise + AEDOWON SINGAPORE PTE. LTD. (UEN 202612161D) via Polar.sh, plus a contracting-entity allocation clause (§0) and joint-controllership framing for account data.
• Credit Display Rebase (D-01) applied throughout (§5.5 and elsewhere): 10 credits = 1 legacy AI Action.
• Auto-renewal disclosure (§4.4): expanded with clear-and-conspicuous disclosure, separate affirmative consent, 30-day pre-renewal reminder, and easy one-click cancellation per FTC ROSCA Click-to-Cancel + EU CRD Art 8 + Thai Direct Sales Act.
• EU / EEA / UK CRD Art 9 / 16(m) cooling-off carried forward (§7.8) with durable-medium consent and acknowledgement record.
• Liability cap floor carried forward (§15.3): greater of (a) 12-month fees paid or (b) THB 5,000 / USD 100. Carve-outs preserved for gross negligence / willful misconduct / fraud / death-PI / mandatory law / indemnification.
• Three-checkbox consent architecture carried forward (§13 Required + §13A Marketing + §13B Extra-Territorial Transfer + §14 Newsletter) — refusal of optional consents has no effect on Service access.
• §12.2A Processor Obligations carried forward and Schedule A fully drafted in Pammo-Data-Processing-Addendum-V1 §4–§13 (no [TBD] placeholder remaining; registered-office addresses + Thai Tax ID in §20.1 have been inserted from Joe-provided business details and are tracked in the Compliance Summary §7 Launch Checklist).
• Real-estate-specific AUP nods (§10.2(b) fake listings, (c) MLS/portal violations, (f) competitor scraping, (n) fair-housing + Thai-foreign-quota), with detailed AUP rules in Pammo-Acceptable-Use-Policy-V1.
• Singapore PDPA added as a primary compliance regime (Preamble, §12.2, §12.4, §12.9, §15.3 carve-out).
• Dual governing law and arbitration (§18) reflecting the dual-entity structure: Thai law + TAI for TH Route; Singapore law + SIAC for International Route; Thai consumer carve-out preserved.

END OF PAMMO TERMS AND CONDITIONS — MAIN — V1 (PUBLICATION-READY PENDING FINAL REVIEW) Last Updated: 2026-05-18