Is the seeding based on record rather than place?
If I understand correctly in a country with 3 divisions, 336 teams, the draw would be 256 teams, 80 in D.I and D.II and 176 in D.III, or 11 per each league in D.III. This would be the 5th place teams and 1/2 the 6th. But the OP's team was 9-13 last season as a bot, which is probably a worse record than most 5th place teams.