Equipher Desmarni Estates collaborates with its hundreds of partner institutions to fully comply with the Family Education Rights and Privacy Act, as amended ("FERPA").

• Any protected educational records created using the Equipher Desmarni Estates platform will be retained by the institution as required under federal law.

• No personally identifiable information ("PII") from educational records provided to Equipher Desmarni Estates will be redistributed to any third party.

• Any use of educational records for purposes of Equipher Desmarni Estates's data analytics or study will be aggregated and stripped of any personally identifiable information.

• Maintaining records created by the student through the Equipher Desmarni Estates platform for the student's continued access beyond graduation is subject to the student's direct acceptance of the Equipher Desmarni Estates's TOS.

• At the potential termination of an Agreement, at the reasonable request of the Client, Equipher Desmarni Estates agrees to make reasonable efforts to return or destroy any FERPA-protected educational records then in its possession.