No, the 66.15% is based off 25m shares being accessible to trade out of 37.793m.
The provision you posted mentions seed shares are excluded from the calculation. So of the 11.993m existing seed shares, a portion, an amount of which we don't know, will not be locked up, and are in addition to the 25m shares in free float.
RFR
rafaella resources ltd.
IPO - Rafaella Resources Ltd, page-8
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