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Codes & Policies The Ikoku Group derives its codes and policies from its Founding Agreement and Code of Ethics — which collectively govern all activities conducted with, within, for, on behalf of, in reference to and otherwise pertaining to the company, its divisions, subsidiaries, and affiliates, as well as its products and services. Learn More

The User Agreement and Code of Conduct

Overview

Welcome to the main page for the Codes and Policies of The Alvan Ikoku Group LLC and of its divisions, series, subsidiaries, and affiliates (collectively, the “Policies” or “Codes and Policies”). Here, important information will be provided to you regarding the Codes and Policies that constitute The Ikoku Group User Agreement and Code of Conduct.

Please, therefore, take the time to read, understand and revisit the Codes and Policies carefully and regularly.

What is ‘Respect for Persons’

The Ikoku Group holds the fullest and most humane understanding of respect for persons to be essential to its formation, development, management and operations. These Codes and Policies are to constitute a core approach to characterizing, obtaining, safeguarding and ultimately having persons enjoy such respect. Therefore, it should be understood that The Ikoku Group takes as the basis for the Codes and Policies the following:

Human Beings Should Enjoy Dignity and Integrity
human beings should be treated as individual persons fully enjoying dignity, integrity, reciprocity and respect.
Human Beings Should Enjoy Basic, Civil and Fundamental Rights
human beings should be treated as individual persons fully enjoying basic, civil and fundamentals rights.
Human Beings Should be Treated as Individual, Freely Deciding Persons
human beings should be treated as individual persons with the ability to freely make decisions.
Human Beings with Diminished Freedom to Decide Should be Protected
human beings with diminished ability to freely make decisions should still be treated as individual decision-making persons but also be protected.
Policies Should Endeavor to Enable and Safeguard the Above
to the extent that is reasonable, the Codes and Polices — especially their interpretation and application — should endeavor to enable, safeguard and avoid diminishing individual persons’ dignity and integrity, enjoyment of basic, civil and fundamental rights, the ability to freely make decisions for themselves, and commensurate protections.
Communities Should Emanate From the Above
the communities of The Ikoku Group — particularly those it helps create, develop, foster and support — should emanate from, and be informed by, all of the aforementioned.

And furthermore, by using or visiting, in any way, The Ikoku Group, any area, part, section or properties of The Ikoku Group, any area, part, section or properties of its divisions, series, subsidiaries or affiliates, as well as any of its Products or Services, including the Sites, you accept and agree to the terms, conditions and requirements described above, and in these Codes and Policies, in their entirety without modification.

Who are ‘The Ikoku Group’

— In these Codes and Policies, and in all official documents, materials and statements, including as presented on the Products and Services, the Sites, and elsewhere, “The Ikoku Group” refers to The Alvan Ikoku Group LLC — also officially doing business as The Alvan Azinna Chibuzo Ikoku Group and The Ikoku Group — as well as any and all of its divisions, series, subsidiaries, affiliates, and its areas, offices, parts and sections, including but not limited to the following:

Alvan Ikoku Corporation
— The Alvan Ikoku Corporation (“The Ikoku Corporation” and “The Alvan Azinna Chibuzo Ikoku Corporation”) which constitutes a division, series and subsidiary wholly owned and managed by The Ikoku Group and its Founder, Alvan Azinna Chibuzo Ikoku.
Alvan Ikoku Group Holdings
— The Alvan Ikoku Group Holdings (“The Ikoku Holdings” and “The Alvan Azinna Chibuzo Ikoku Group Holdings”) which constitutes a division, series and subsidiary wholly owned and managed by The Ikoku Group and its Founder, Alvan Azinna Chibuzo Ikoku.
Alvan Ikoku Group Services
— The Alvan Ikoku Group Services (“The Ikoku Services” and “The Alvan Azinna Chibuzo Ikoku Group Services”) which constitutes a division, series and subsidiary wholly owned and managed by The Ikoku Group and its Founder, Alvan Azinna Chibuzo Ikoku.
Alvan Ikoku Philanthropies
— The Alvan Ikoku Philanthropies (“The Ikoku Philanthropies” and “The Alvan Azinna Chibuzo Ikoku Philanthropies”) which constitute a division, series and subsidiary wholly owned and managed by The Ikoku Group and its Founder, Alvan Azinna Chibuzo Ikoku.
Publiks Group
— The Publiks Group (including “Publiks Inc”) which constitutes a division, series and subsidiary wholly owned and managed by The Ikoku Group and its Founder, Alvan Azinna Chibuzo Ikoku.
The Ikoku Group Administration
also constituting part of The Ikoku Group is The Ikoku Group Administration as defined and described in these Codes and Policies and specifically the Policy on Company Integrity.
The Ikoku Group Offices and Properties
also constituting part of The Ikoku Group are the assets and properties of the aforementioned, and the offices and official addresses of The Ikoku Group and Publiks Inc, as determined by express written instrument signed and sealed of the Founder, Alvan Azinna Chibuzo Ikoku.
No Government or Public Entity, Office or Service
and the above with the understanding that The Ikoku Group, its divisions, series, subsidiaries and affiliates, as well as its Products and Services, and the Sites, shall not include (nor be construed or represented as including) any governments or government or public authorities, branches, entities, institutions, offices, parks, programs, services, utilities or other equivalent, nor their employees, officials, representatives or other agents.

And furthermore, by using or visiting, in any way, The Ikoku Group, any area, part, section or properties of The Ikoku Group, any area, part, section or properties of its divisions, series, subsidiaries or affiliates, as well as any of its Products or Services, including the Sites, you accept and agree to the terms, conditions and requirements described above, and in these Codes and Policies, in their entirety without modification.

What are ‘Products,’ ‘Services’ and ‘Sites’

— And in these Codes and Policies, as well as in all of the official documents, materials and statements of The Ikoku Group, including as they present on the Products and Services of The Ikoku Group and elsewhere, “Products” and “Services” refer to — but are not limited to the following:

Products and Services Themselves
any and all of the applications, goods, products, programs, services, sites and their equivalent of The Ikoku Group and of its divisions, series, subsidiaries, and affiliates.
That Contained and Involved in the Products and Services
any and all of the activities, computers, content, data and information, devices, domains, equipment, feedback, materials, marks, names, operations, properties and technologies involved in accessing, browsing, creating, continuing, developing, distributing, making available, maintaining, operating, processing, reproducing, sharing and otherwise using and visiting the applications, goods, products, programs, services, sites and their equivalent of The Ikoku Group and of its divisions, series, subsidiaries and affiliates.
Above as Applies to Sites
any and all of the above as it applies to the Sites of The Ikoku Group and to the Sites of its divisions, series, subsidiaries and affiliates (collectively the “Sites”) are included within the Products and Services.
No Government or Public Entity, Office or Service
and the above with the understanding that the Products and Services, including the Sites, of The Ikoku Group and of its divisions, series, subsidiaries and affiliates shall not include (nor be construed or represented as including) any governments or government or public authorities, branches, entities, institutions, offices, parks, programs, services, utilities or other equivalent, nor their employees, officials, representatives or other agents.

And furthermore, by using or visiting, in any way, The Ikoku Group, any area, part, section or properties of The Ikoku Group, any area, part, section or properties of its divisions, series, subsidiaries or affiliates, as well as any of its Products or Services, including the Sites, you accept and agree to the terms, conditions and requirements described above, and in these Codes and Policies, in their entirety without modification.

Who Is ‘The Founder’ and ‘The Owner’

— For the purposes of these Codes and Policies — as well as any other official communications, documents, statements and other materials of The Ikoku Group — “the Founder” and “the Owner” are understood to entail agreement and adherence to the following:

Sole Founder of The Ikoku Group
that references to “the Founder” mean and include only Alvan Azinna Chibuzo Ikoku as the sole Founder of The Alvan Ikoku Group LLC, its divisions, series, subsidiaries and affiliates, and the Products and Services, including the Sites.
Sole Owner of The Ikoku Group
that references to “the Owner” mean and include only Alvan Azinna Chibuzo Ikoku as the sole Owner of The Alvan Ikoku Group LLC, its divisions, series, subsidiaries and affiliates, and the Products and Services, including the Sites.

And furthermore, by using or visiting, in any way, The Ikoku Group, any area, part, section or properties of The Ikoku Group, any area, part, section or properties of its divisions, series, subsidiaries or affiliates, as well as any of the Products or Services, including the Sites, you accept and agree to the terms, conditions and requirements described above, and in these Codes and Policies, in their entirety without modification.

Who Are ‘We,’ ‘Our’ and ‘Us’

— For the purposes of these Codes and Policies, “we,” “our” and “us” are understood to entail agreement and adherence to the following:

The Ikoku Group and Associated Entities
references to “we,” “our”  and “us” mean and include The Alvan Ikoku Group LLC as well as its divisions, series, subsidiaries and affiliates, wholly owned and managed by Alvan Azinna Chibuzo Ikoku, the sole Founder and Owner.
Founder and Owner of The Ikoku Group
references to “we,” “our”  and “us” also mean and include Alvan Azinna Chibuzo Ikoku, as sole Founder and Owner of The Ikoku Group, its divisions, series, subsidiaries and affiliates, and the Products and Services, including the Sites.
Any Person Approved, Authorized and Employed by Founder
finally, references to “we,” “our”  and “us” also mean and include a natural person appointed or employed by Alvan Azinna Chibuzo Ikoku, sole Founder and Owner of The Ikoku Group, via expressly written instrument signed and sealed, and conducting approved and authorized activities and operations within, for, on behalf of, in reference to or otherwise pertaining to The Ikoku Group in a manner in accordance with the Codes and Policies.

And furthermore, by using or visiting, in any way, The Ikoku Group, any area, part, section or properties of The Ikoku Group, any area, part, section or properties of its divisions, series, subsidiaries or affiliates, as well as any of the Products or Services, including the Sites, you accept and agree to the terms, conditions and requirements described above, and in these Codes and Policies, in their entirety without modification.

Who Are ‘You,’ ‘User’ and ‘Visitor’

— For the purposes of these Codes and Policies, “you” is understood to entail agreement and adherence to the following:

Any Person Engaging in Activity, Especially User and Visitor
that, with the exception of the sole Founder and Owner, Alvan Azinna Chibuzo Ikoku, references to “you” and “your” mean and include any person engaging in any activity — especially as a visitor or user — in any way pertaining to The Ikoku Group, its divisions, series, subsidiaries and affiliates, and the Products and Services, including the Sites.
Any Person Thus Entering into Agreement
that the Codes and Policies are a legally binding agreement between The Ikoku Group and “you,” and they govern any and all of “your” activity in any way pertaining to The Ikoku Group, its divisions, series, subsidiaries and affiliates, and the Products and Services, including the Sites.
An Individual or an Organization
that most visitors and users of the Products and Services, or other areas, parts, sections and properties of The Ikoku Group, are independent individuals, though many are employees or other agents of entities, so the meaning of and references to “you” include both: (1) the “user” or “visitor” individually and (2) any entity or individual that is your employer or for whom you act as agent, unless otherwise stated in these Codes and Policies.
Age-Related Restrictions
that persons under thirteen (13) years of age are not authorized to — on their own — use any of the Products or Services, including any of the Sites.

And furthermore, by using or visiting, in any way, The Ikoku Group, any area, part, section or properties of The Ikoku Group, any area, part, section or properties of its divisions, series, subsidiaries or affiliates, as well as any of the Products or Services, including the Sites, you accept and agree to the terms, conditions and requirements described above, and in these Codes and Policies, in their entirety without modification.

Your Agreement

— With respect to the Agreement you enter into with The Ikoku Group via the Codes and Policies, and especially The Ikoku Group User Agreement and Code of Conduct, you understand and adhere to the following:

Persons Adhering to Agreement
that, with the exception of the Founder and Owner, the Codes and Policies are to be adhered to by a wide range of associated individuals and communities ― including but not limited to board and committee members, leadership, management, officers, staff, employees, volunteers, representatives, agents, collaborators, partners, and visitors and users ― as they work in their capacity to establish, further develop, operate, collaborate with, carry out the mission and purposes of, and also visit, use and participate in the offerings of The Ikoku Group.
Applicability and Governance of Agreement
that the Codes and Policies govern any and all of your activity, communication, operation, participation, visit and other use, in any way, pertaining to The Ikoku Group, its divisions, series, subsidiaries and affiliates, and the Products and Services, including the Sites, and that you agree to abide by, assist, fully cooperate with and not interfere with The Ikoku Group and its sole Founder and Owner, Alvan Azinna Chibuzo Ikoku in ensuring the compliance with and fulfillment of any and all terms, conditions, duties, principles, protections, rights and other requirements of the Codes and Policies.
Entry and Continuation of Agreement
that whenever you engage in any action, activity, communication, operation, participation, visit or other use of, in, within, for, on behalf of, in reference to or otherwise pertaining to The Ikoku Group, its divisions, series, subsidiaries or affiliates, and the Products and Services, including the Sites — directly or indirectly as further described below — you are agreeing to the Codes and Policies that collectively constitute The Ikoku Group User Agreement and Code of Conduct, as they are amended from time to time.
Direct and Indirect Entry and Continuation of Agreement
that whenever you engage in the above described activities directly or indirectly — whether engaged in through The Ikoku Group, its divisions, series, subsidiaries or affiliates, and the Products and Services, including the Sites; or through persons and entities working with The Ikoku Group, its divisions, series, subsidiaries or affiliates, and the Products and Services, including the Sites; or working with such engaged activities and resulting media, materials or otherwise — you are also agreeing to the Codes and Policies that collectively constitute The Ikoku Group User Agreement and Code of Conduct, as they are amended from time to time.
Binding Nature and Validity of Agreement
that you are also thus indicating that you understand the Codes and Policies, that you intend them to be the legal equivalent of a signed, written contract, equally binding, and that you accept such Codes and Policies and agree to be legally bound by them (your “Agreement”).
Agreement On Behalf of Organization
that if you are engaging in any of the above described activities, communication or uses for or on behalf of an organization, you are agreeing to this Agreement on behalf of that organization, and represent and warrant that you can do so.
In Case of Non-Agreement or Inability to Honor
that you will not engage in any of the above described activities, communication or uses if you do not agree to all of the Codes and Policies or if your jurisdiction will not honor them.

And furthermore, by using or visiting, in any way, The Ikoku Group, any area, part, section or properties of The Ikoku Group, any area, part, section or properties of its divisions, series, subsidiaries or affiliates, as well as any of the Products or Services, including the Sites, you accept and agree to the terms, conditions and requirements described above, and in these Codes and Policies, in their entirety without modification.

Your Consent to The Policies

— With respect to your ability to agree and consent to the Codes and Policies, and especially to The Ikoku Group User Agreement and Code of Conduct, you represent and warrant the following:

Your Power and Authority
that you have the power and authority to enter into the agreement entailed in the Codes and Policies, and especially The Ikoku Group User Agreement and Code of Conduct, including, where applicable, the power and authority to enter into the agreement on behalf of an organization.
Required Age or Permission and Supervision
that you are at least eighteen (18) years old or if younger at least thirteen (13) years old and engage in activity, communication, operation, participation, visit or other use in relation to The Ikoku Group, its divisions, series, subsidiaries and affiliates, or the Products and Services, including the Sites with the permission and supervision of an adult parent or guardian.
Reading and Understanding
that you have read and understood the Codes and Policies, and especially The Ikoku Group User Agreement and Code of Conduct.
Voluntary Nature of Consent
that you understand your consent to by voluntary in nature.
Agreement and Consent
that you consented to and agreed to be legally bound by the Codes and Policies, and especially The Ikoku Group User Agreement and Code of Conduct.

And furthermore, by using or visiting, in any way, The Ikoku Group, any area, part, section or properties of The Ikoku Group, any area, part, section or properties of its divisions, series, subsidiaries or affiliates, as well as any of the Products and Services, including the Sites, you accept and agree that your consent meets the conditions, principles and requirements for consent, as delineated and described in a these Codes and Policies — for the specific purpose of consenting to this Policy, the Agreement and the Codes and Policies.

Your Abiding by The Policies

— You represent, warrant and covenant that, given the above attestation about your consent to the Codes and Policies, and The Ikoku Group User Agreement and Code of Conduct, you have read, understood, consented to and agreed to be legally bound by and abide by The Ikoku Group User Agreement and Code of Conduct, and the Codes and Policies, as they are amended from time to time, and in their entirety without modification.

Your Accordance with Ethics

— You represent, warrant and covenant that, given the above attestation about your consent to the Codes and Policies, and The Ikoku Group User Agreement and Code of Conduct, you ensure following the aforementioned principles further remains in accordance with the Founding and Governing Code of Ethics.

Your Attention to Changes

— With respect to any changes to the aforementioned and below, you understand, agree to and adhere to the following::

Changes to Products and Services
that The Ikoku Group reserves to right to, at any time, without notice or liability, change, temporarily suspend or discontinue any aspect of the Products and Services, including the Sites; the right also do the same for the availability of any feature, database or content of the Products and Services, including the Sites; and the right also to impose limits on certain features and services or restrict your access to parts or all of the Products and Services, including the Sites, again without notice or liability.
Changes to Codes and Policies
that The Ikoku Group reserves the right to change and update these Codes and Policies, from time to time and at any time and without liability; that The Ikoku Group strongly encourages you to check back periodically to review the most current, updated version of these Codes and Policies; and that as a person or entity engaging in any activity in, within, with, for, on behalf of, in reference to or otherwise pertaining to The Ikoku Group, or a visitor or user of the Products or Services, including the Sites, it remains your responsibility to keep informed about such posted changes.
Reasonable Notice and Notification
that if The Ikoku Group makes significant material changes, it will attempt to notify you through the Sites or other Products and Services; but that you also agree that notices The Ikoku Group may provide on the Sites or other Products and Services themselves shall be deemed reasonable notice for this purpose.
Indication of Acceptance
that if you object to any changes, you may close any account or cease any activity, arrangement, communication, operation, services or equivalent you maintain with The Ikoku Group; and that your continued use of the Sites or any other Products or Services after publishing any changes to these Codes and Policies, or sending a notice about such changes, will constitute your acceptance of such modifications.

And furthermore, by using or visiting, in any way, The Ikoku Group, any area, part, section or properties of The Ikoku Group, any area, part, section or properties of its divisions, series, subsidiaries or affiliates, as well as any of the Products and Services, including the Sites, you accept and agree that your consent meets the conditions, principles and requirements for consent as delineated and described in these Codes and Policies.

Your Duty to Company Integrity

To protect the company and organizational integrity of The Ikoku Group — as well as the properties, rights and protections of the company and its official persons — The Ikoku Group requires all natural and legal persons concerned to read, understand, abide by and, where applicable, sign contracts and agreements delineated and described in the Policy on Company Integrity.

The Ikoku Group reminds you that the Policy on Company Integrity forms part of The Ikoku Group User Agreement and Code of Conduct. Thus, The Ikoku Group takes your continued visiting and use of its Products and Services, including its Sites, as active indication of your legally binding acceptance of this Policy as well as the Codes and Policies.

Your Questions and Feedback

Your questions regarding the Codes and Policies will help tremendously to make The Ikoku Group and its divisions, series, subsidiaries, partners and affiliates, as well as its Sites, Products and Services active, collaborative, safe and secure places and tools for doing work.

So if you have any questions, or thoughts, suggestions and feedback, please email them to policies@ikokugroup.com.

How to Report

And the reporting of any violations of these Codes and Policies will also help to make The Ikoku Group, its divisions, series, subsidiaries, partners and affiliates, as well as its Sites, Products and Services active, collaborative, safe and secure places and tools for doing work. The Duty to Report is also one of the principles of the Founding and Governing Code of Ethics.

So if you see, think or worry that a violation of code or policy may have occurred or may be occurring, please email policies@ikokugroup.com.

Do Read All Policies Before Continuing

Please, therefore, take the time to read and understand all of the Codes and Policies, and to revisit them whenever they are updated, before continuing to visit or use the Sites and any of the other Products or Services, and especially if you intend to be or are among the leadership staff, employees, volunteers, educators, researchers, donors, funding recipients, and partners, collaborators, agents or third-parties in any capacity formally approved by The Ikoku Group and its Founder and Owner, Alvan Azinna Chibuzo Ikoku.

The Codes and Policies, as well as some further clarifying definitions, are made available to you below.

Further Definitions

Provision

Provided below are definitions of terms to be used for purposes of these Codes and Policies, all official documents, policies and statements, and for any action, activity, communication, operation or participation in, within, with, for, on behalf of, in reference to or otherwise pertaining to The Ikoku Group, its divisions, series, subsidiaries and affiliates, and its Products and Services, including the Sites.

‘Confidentiality’ and ‘Confidential Data and Information’

References to “confidential data” and “confidential information” mean and include the following:

As Defined, Described, Discussed, Identified or Processed
any and all data, documentation and information accessed, gathered or otherwise processed at or by The Ikoku Group (including its Products and Services), or in the course of its activities or operations, that are defined, described, discussed, identified or otherwise processed as “confidential,” or, in context, can meaningfully or reasonably be expected to be treated as confidential, as well as such data, documentation and information that is not generally known or made available outside The Ikoku Group.
No Observation or Recording Meaningfully or Reasonably Expected
any and all of the above such data, documentation and information about activity or behavior that occurs in a context in which an individual or person can meaningfully or reasonably expect that no observation or recording is taking place.
No Observation or Recording Without Meaningful Consent
any and all of the above such data, documentation and information about activity or behavior that occurs in a context in which an individual or person can meaningfully or reasonably expect to need to and be able to consent for the observation or recording to take place and also be able to refuse or revoke such consent.
As Provided With Expectation To Not Make Public
any and all of the above such data, documentation and information that has been provided for specific purposes by an individual or person where that individual or person can meaningfully and reasonably expect the data, documentation and information will not be made public.
Examples of Confidential Data and Information
include, but are not limited to, background materials, documents, files, financial information, health information, memoranda, reports, research materials, tax materials, and any data, documentation and information (including evaluations and letters of recommendation) relating to any actual or potential Founder, Trustee, Director, Manager, Officer, staff, employee or volunteer, donor, grantor or grantee, affiliate, partner, contractor, third party or other agent; and any other actual or potential participant in any activity, communications, operations, program, product, project, service, site, use, visit or other undertaking of The Ikoku Group.
Expected for Personal, Private and Sensitive
also include, but are not limited to, data, documentation and information accessed, gathered or otherwise processed at or by The Ikoku Group (including its Products and Services), or in the course of its activities or operations, that are defined, described, discussed or otherwise identified or processed as “personal,” “private” or “sensitive” — and the protection of such data, documentation and information (including prohibitions of processing) is an essential way in which The Ikoku Group complies with and fulfills the rights of persons to “confidentiality” and to “confidential conversation.”
Biospecimens, Especially for Care and Research
and for the reasons above as well as a matter of Policy, biospecimens — especially when processed as part of care, research or investigation — are considered confidential and the protection of such biospecimens (including prohibitions on their processing) is also an essential way in which The Ikoku Group complies with and fulfills the rights of persons to “confidentiality” and to “confidential conversation.”

And furthermore, by using or visiting, in any way, The Ikoku Group, any part or section of The Ikoku Group, any part or section of its divisions, subsidiaries or affiliates, as well as any of its Products or Services, you accept and agree to the terms, conditions and requirements described above, and in these Codes and Policies, in their entirety without modification.

‘Consent’

References to “consent” and “consented” mean and include only an affirmative, revocable and unambiguous indication of a natural or legal person’s wishes via a written communication or instrument that meets the following standard:

Revocable Consent to Specific Activity
the communication or instrument explicitly states an unrevoked, though revocable, permission for a specified activity or specified form of activity by the person indicating and giving permission.
Affirmative, Clear and Unambiguous
the above consent indicated in the communication or instrument is affirmative, clear and unambiguous.
Reasonably Informed
the communication or instrument indicates that the above consenting person is reasonably informed before, during and after the consent process and decisions.
Freely Given and Meaningful
the communication or instrument indicates that the above consent is freely given and meaningful.
Accessible, Clear and Informing Consent Request
the communication or instrument has been preceded by or includes an accessible, clear, easily legible and understandable, informing and written request for the above consent.
Clear Statement of Rights to Record
the communication or instrument has been preceded by or includes a clear written statement to the consenting person as to any right of such person to have and retain a record of the agreed consent in electronic, paper and in nonelectronic form.
Clear Application of Consent
the communication or instrument has been preceded by or includes a clear written statement to the consenting person as to whether the consent applies only to that specified activity, to specified categories or forms of that activity, or to all activity within, for, on behalf of, in reference to or generally pertaining to The Ikoku Group.
Clear Revocation Process
and the communication or instrument has been preceded by or includes a clear written statement to the consenting person as to the procedures such person must use to revoke or withdraw consent.

“Consent” should not be confused with “agreement” or “contract” and the requirements for these three types of written instruments should not be conflated.

Furthermore, consent has particular implications and requirements explained twice in the Codes and Policies — first, in the Policy on Data and Information and second, in the Policy on Human Subjects Research and Investigation — and The Ikoku Group advises you to regularly visit those sections for an extended and updated explanation of aspects of consent relevant to several processes at the company, where your in-depth understanding of consent’s requirements will likely be of benefit to all involved.

‘Data Aggregation’

References to “aggregation” and “aggregated” in the context of processing data and information mean and include processing where raw data and information are accessed and collected, deidentified and compiled, then transformed and rendered in a summary form — using categories and ranges — for statistical analysis. Anonymization, as well as transformation from individual data points and persons to categories and ranges, is often expected, preferred and at times required. The raw data and information can be aggregated to provide numerical and non-numerical insights, insights about a specific action or characteristics over time, opportunities for comparison with and across other similarly aggregated or prepared datasets, and greater opportunities for analysis, compiling and merging with multiple other similarly aggregated or prepared datasets.

‘Data Review Board’

References to “data review board” (also the “DRB”) in the context of processing data and information mean and include a board of data and information ethics evaluators established and maintained in accord with and for the purposes of determination, review and approval or non-approval as described in the Policy on Data and Information.

References to “DRB approval” mean and include determinations of the DRB that the data or information or their processing has been reviewed and may be processed or conducted at a specific part, product, section, service or site of The Ikoku Group within the constraints set forth by the DRB, by the Policy on Data and Information, by these Codes and Polices, and by applicable guidelines, law and regulations.

‘De-identification’

References to “de-identification” — in the context of either research and investigation or processing biospecimens, data and information — mean and include the access, collection or other processing of personal biospecimens, data and information by means that do not actively or immediately identify a specific natural or legal person.

Typically, de-identification de-links or uncouples the connection between personal biospecimens, data and information and the identity of the natural or legal person concerned, but also keeps identifying information that can — relatively easily or quickly — be recoupled or re-linked in certain situations and for certain purposes.

Personal biospecimens, data and information that have undergone a process of de-identification or have been described as “de-identifying” or “de-identified” are and remain personal biospecimens, data and information (since they could be used to identify a natural or legal person, for example, when combined with additional information like a security question, reversible barcode or original un-redacted document).

For this reason, such de-identified personal biospecimens, data and information, as well as their access, collection and other processing, require and remain under the stringent protections and regulations delineated and described in these Codes and Policies and in either the Policy on Data and Information or the Policy on Human Subjects Research and Investigation. Moreover, natural or legal persons concerned still have Policy-specified rights to ensure and verify that such de-identification has been and remains properly and truly conducted.

‘Health Care Operations’

References to “health care operations” mean and include any of the following activities:

Health Care Administration and Management
business management and general administrative activities of the health care entity, including, but not limited to: (a) management activities relating to implementation of and compliance with the requirements of regulation; (b) customer service, including the provision of data analyses for policy holders, plan sponsors, or other customers, provided that protected health information is not disclosed to such policy holder, plan sponsor, or customer; (c) resolution of internal grievances; (d) sale, transfer, merger, or consolidation of all or part of the health care entity with another entity, or an entity that following such activity will become the health care entity and due diligence related to such activity; and (e) creating de-identified health information or a limited data set, and fundraising for the benefit of the health care entity.
Health Care Compliance
conducting or arranging for medical review, legal services, and auditing functions, including fraud and abuse detection and compliance programs.
Health Care Insurance
underwriting, enrollment, premium rating, and other activities related to the creation, renewal, or replacement of a contract of health insurance or health benefits, and ceding, securing, or placing a contract for reinsurance of risk relating to claims for health care (including stop-loss insurance and excess of loss insurance), provided that certain US-mandated requirements of are met, if applicable.
Health Care Personnel
reviewing the competence or qualifications of health care professionals, evaluating practitioner and provider performance, health plan performance, conducting training programs in which students, trainees, or practitioners in areas of health care learn under supervision to practice or improve their skills as health care providers, training of non-health care professionals, accreditation, certification, licensing, or credentialing activities.
Health Care Planning and Development
business planning and development, such as conducting cost-management and planning-related analyses related to managing and operating the entity, including formulary development and administration, development or improvement of methods of payment or coverage policies.
Health Care Quality, Safety, Costs and Coordination
conducting quality assessment and improvement activities, including outcomes evaluation and development of clinical guidelines, provided that the obtaining of generalizable knowledge is not the primary purpose of any studies resulting from such activities; patient safety activities; population-based activities relating to improving health or reducing health care costs, protocol development, case management and care coordination, contacting of health care providers and patients with information about treatment alternatives; and related functions that do not include treatment.

And furthermore, by using or visiting, in any way, The Ikoku Group, any part or section of The Ikoku Group, any part or section of its divisions, subsidiaries or affiliates, as well as any of its Products or Services, you accept and agree to the terms, conditions and requirements described above, and in these Codes and Policies, in their entirety without modification.

‘Human Subject’

References to “human subject,” “human subject under study” and “human subject concerned” in the context of research or investigation mean and include a living individual or natural person about or from whom a researcher or investigator (whether non-professional, professional or student) conducting research or investigation:

— (a) obtains biospecimens, data or information through interaction or intervention with the individual, and analyzes, studies, uses or otherwise processes the biospecimens, data or information; or

— (b) analyzes, generates, obtains, studies, uses or otherwise processes identifiable biospecimens, identifiable private or sensitive data, or identifiable private or sensitive information.

‘Identifiable Biospecimen’

References to “identifiable biospecimen” and “personal biospecimen” in the context of research or investigation mean and include a biospecimen for which the identity of a human subject is or may be ascertained or associated with the biospecimen.

References to “identifiable biospecimen” and “personal biospecimen” in the context of research or investigation also mean and include a biospecimen accessed or otherwise processed by means that relates to, identifies or can be used to identify or contact a human subject or natural person.

‘Identifiable Person’ and ‘Identifier’

References to “identifiable person” in the context of processing data and information mean and include someone who can be directly or indirectly identified via use of or reference to an “identifier” or a combination of “identifying information,” and examples of such identifiers or identifying information include, but are not limited to, a name, an identification number, a phone number, location data, an online identifier (such as a username), a device identifier (such as an IP address), or one or more items of information specific to the cultural, economic, financial, genetic, mental, physical, physiological, psychological, religious, social or spiritual identity or characteristics of a natural or legal person.

We also refer to such an identifiable person as a “natural or legal person who is a subject of, or identifiable by, the data and information” as well as a “natural or legal person concerned” in the context of activities, operations, policies or statements pertaining to personal data and information.

Such an identifiable person is also known as a “data subject” in the European Union’s GDPR law and is also included in the definition and use of “consumer” in the California Consumer Privacy Act (CCPA).

‘Intellectual Property, External’

References to “external intellectual property” in the context of real and intellectual property and proprietary rights mean and include content, media, materials and other copyrightable, patentable and service- or trademarkable real or intellectual property created outside of The Ikoku Group; outside of its series, divisions, subsidiaries and affiliates; outside of its Products and Services, including the Sites; outside and without any usage of The Ikoku Group copyright, logo, name, patent, slogan, symbol, service- or trademark or any other intellectual property; outside of agreements, contracts, contractorships, partnerships and other equivalent arrangements The Ikoku Group makes; and without any use of The Ikoku Group resources.

‘Interaction, Research’

References to “interaction” in the context of research or investigation mean and include communication or interpersonal contact between a researcher or investigator and a human subject, either for research or investigation purposes or as part of activity determined to constitute research or investigation.

Also, references to “benign behavioral interactions” or “benign interactions” in the context of research or investigation mean and include interactions that are, after rigorous assessment and by written consent and written instrument, confirmed by the human subject, institutional review board and researcher or investigator to be:

— (a) brief in duration;

— (b) harmless;

— (c) painless;

— (d) not physically invasive,

— (e) not likely to have a significant adverse lasting impact on the human subject; and

— (f) neither offensive nor embarrassing.

‘Internal Review Board’

References to “internal review board” (also the “IRB”) in the context of research or investigation mean and include a board of research ethics evaluators established and maintained in accord with and for the purposes of determination, review, and approval or non-approval as described in the Policy on Human Subjects Research and Investigation.

References to “IRB approval” mean and include determinations of the IRB that the research or investigation has been reviewed and may be conducted at a specific at a specific part, product, section, service or site of The Ikoku Group, or other institution and setting, within the constraints set forth by the IRB, by the Policy on Human Subjects Research and Investigation, by these Codes and Polices, by other institutional policy, and by applicable guidelines, law and regulations.

‘Intervention, Research’

References to “intervention” in the context of research or investigation mean and include both:

— (a) procedures by which biospecimens, data or information are accessed, gathered or otherwise processed; and

— (b) manipulations of a human subject or a human subject’s environment that are performed for research or investigation purposes or as part of activity determined to constitute research or investigation.

Also, references to “benign behavioral interventions” or “benign interventions” in the context of research or investigation mean and include interventions that are, after rigorous assessment and by written consent and written instrument, confirmed by the human subject, institutional review board and researcher or investigator to be:

— (i) brief in duration;

— (ii) harmless;

— (iii) painless;

— (iv) not physically invasive,

— (v) not likely to have a significant adverse lasting impact on the human subject; and

— (vi) neither offensive nor embarrassing.

‘Irreversible Anonymization’

References to “irreversible anonymization” (or “anonymization” for The Ikoku Group) — in the context of either research and investigation or processing biospecimens, data and information — mean and include the access, collection or other processing of biospecimens, data and information by means that do not permit and irreversibly prevents the biospecimens, data and information from being attributable to, or identifying, a specific natural or legal person.

Only after biospecimens, data and information have undergone processes of irreversible anonymization, and thus become irreversibly anonymized, may they be described as “anonymized” biospecimens, data and information, whose access, collection or other processing may not require the stringent protections and regulations delineated and described in these Codes and Policies and in either the Policy on Data and Information or the Policy on Human Subjects Research and Investigation.

It must be noted that there are ongoing concerns that such “anonymized” biospecimens, data and information may possibly and technically become comparatively or increasingly “un-anonymized” or even personal (for example, when cross-referenced with datasets or information specifying physical and temporal location, or when subjected to certain methods of data aggregation, preparation and mining). For this reason, natural or legal persons concerned still have Policy-specified rights to ensure and verify that such irreversible anonymization has been and remains properly and truly conducted.

‘Minimal Risk’

References to “minimal risk” in the context of research or investigation and processing biospecimens, data and information mean and include the likelihood, magnitude and probability of physical or psychological harm that is normally encountered in the daily lives — or in the routine professionally licensed dental, medical or psychological examination or routine educational situations  — of healthy, undiscriminated and unharassed persons.

‘Non-Identification’

References to “non-identification” — in the context of either research and investigation or processing biospecimens, data and information — mean and include the access, collection or other processing of biospecimens, data and information by means that do not permit or require the biospecimens, data and information to be attributable to, or identify, a specific natural or legal person.

Personal biospecimens, data and information that have undergone a process of non-identification or have been described as “non-identifying” may still be personal biospecimens, data and information (in cases where they could be used to identify a natural or legal person, for example, when combined or cross-referenced with additional information or data sets), and so may still require and remain under the stringent protections and regulations delineated and described in these Codes and Policies in either the Policy on Data and Information or the Policy on Human Subjects Research and Investigation.

Moreover, natural or legal persons concerned still have Policy-specified rights to ensure and verify that such non-identification has been and remains properly and truly conducted. For this reason, we make clear distinctions between de-identification, pseudo-anonymization or pseudonymization, and irreversible anonymization.

‘Notice,’ ‘Giving’ and ‘Delivery’

Reference to “notice” mean and include only written communication or notification properly delivered to its recipient; and “delivery” and “giving notice” shall be deemed to have been properly initiated and conducted if:

— (a) served in person;

— (b) sent via electronic mail;

— (c) posted by United States mail, full postage prepaid thereon;

— (d) sent by special courier service; or

— (e) sent by telecopy, any of these options if conducted via a manner and form consented to by the recipient for such purposes, and if sent to the correct mailing or electronic address or number designated by and consented to by the recipient for such purposes, or if none is designated, at the correct address or number of the recipient listed on the records of The Ikoku Group.

Furthermore, such delivery and notice shall be deemed to have been completed:

— (i) in the case of personal or special courier delivery, on the date of actual receipt of such notice by the recipient;

— (ii) in the case of mail delivery, when deposited in the United States mail, postage prepaid thereon, addressed to the recipient at designated or correct address as it appears on the records of The Ikoku Group;

— (iii) if electronically transmitted, as provided in these Codes and Policies; or

— (iv) in the case of facsimile delivery, when transmitted to the recipient at designated or correct fax number as it appears on the records of The Ikoku Group.

‘Personal Data’ and ‘Personal Information’

References to “personal data” and “personal information” mean and include data and information for which the identity of a specific natural or legal person is or may be ascertained or associated with the data and information.

References to “personal data” and “personal information” also mean and include data and information accessed or otherwise processed by means that relate to, identify or can be used to identify or contact a natural or legal person.

‘Privacy,’ ‘Private Data’ and ‘Private Information’

References to “private data” and “private information” mean and include the following:

As Defined, Described, Discussed, Identified or Processed
any and all data, documentation and information accessed, gathered or otherwise processed at or by The Ikoku Group (including its Products and Services), or in the course of its activities or operations, that are defined, described, discussed, identified or otherwise processed as “private,” or, in context, can meaningfully or reasonably be expected to be treated as private, as well as such data, documentation and information that is not generally known or made available outside The Ikoku Group.
No Observation or Recording Meaningfully or Reasonably Expected
any and all of the above such data, documentation and information about activity or behavior that occurs in a context in which an individual or person can meaningfully or reasonably expect that no observation or recording is taking place.
No Observation or Recording Without Meaningful Consent
any and all of the above such data, documentation and information about activity or behavior that occurs in a context in which an individual or person can meaningfully or reasonably expect to need to and be able to consent for the observation or recording to take place and also be able to refuse or revoke such consent.
As Provided With Expectation To Not Make Public
any and all of the above such data, documentation and information that has been provided for specific purposes by an individual or person where that individual or person can meaningfully and reasonably expect the data, documentation and information will not be made public.
Examples of Confidential Data and Information
include, but are not limited to, background materials, documents, files, financial information, health information, memoranda, reports, research materials, tax materials, and any data, documentation and information (including evaluations and letters of recommendation) relating to any actual or potential Founder, Trustee, Director, Manager, Officer, staff, employee or volunteer, donor, grantor or grantee, affiliate, partner, contractor, third party or other agent; and any other actual or potential participant in any activity, communications, operations, program, product, project, service, site, use, visit or other undertaking of The Ikoku Group.
Expected for Confidential, Personal and Sensitive
also include, but are not limited to, data, documentation and information accessed, gathered or otherwise processed at or by The Ikoku Group (including its Products and Services), or in the course of its activities or operations, that are defined, described, discussed or otherwise identified or processed as “confidential,” “personal,” or “sensitive” — and the protection of such data, documentation and information (including prohibitions of processing) is an essential way in which The Ikoku Group complies with and fulfills the rights of persons to “privacy,” to “private conversation” and to “private thought.”
Biospecimens, Especially for Care and Research
and for the reasons above as well as a matter of Policy, biospecimens — especially when processed as part of care, research or investigation — are considered confidential and the protection of such biospecimens (including prohibitions on their processing) is also an essential way in which The Ikoku Group complies with and fulfills the rights of persons to “privacy,” to “private conversation” and to “private thought.”

And furthermore, by using or visiting, in any way, The Ikoku Group, any part or section of The Ikoku Group, any part or section of its divisions, subsidiaries or affiliates, as well as any of its Products or Services, you accept and agree to the terms, conditions and requirements described above, and in these Codes and Policies, in their entirety without modification.

‘Processing, of Biospecimens, Data, Information’

References to “processing,” “process” or “processed” — in the context of biospecimens, data and information or research and investigation — mean and include any activities or operations or sets of activities or operations that are performed on biospecimens, data or information or on their sets — whether confidential, identifiable, identifying, personal, private, sensitive or not — and whether or not by automated means.

Such activities, operations and their means include, but are not limited to, accessing, adaptation or alteration, alignment or combination, archiving or filing, bartering or trading, borrowing or renting or leasing, buying or purchasing, circulation or dissemination or otherwise making available, collection, consultation, deletion or erasure or destruction, detecting, disclosure, documenting, developing, gathering or compiling, generating or preparing, evaluating or assessing, examining or analyzing, filming or streaming, giving or donating, organization, profiling or predicting, publication, publishing or otherwise making public, receiving, recording, reporting, restriction, retrieval, saving or storage, searching or searching for, selling or trading in, structuring, tracking, transferring, transmission, use or otherwise putting into activity or operation.

‘Profiling, with Biospecimens, Data, Information’

References to “profiling” — in the context of processing biospecimens, data and information or research and investigation — mean and include any processing of personal biospecimens, data and information or any research and investigation that uses such biospecimens, data and information to evaluate certain personal aspects or attributes relating to a natural person, including, but not limited to, analyzing or predicting aspects concerning that natural person’s behavior, choices or decision-making, economic or financial situation, health, fitness or wellness, hobbies or interests, location or movements, performance at work, personal preferences, psychology, reliability, rest or sleep.

Profiling commonly accesses, collects, tracks then analyzes biospecimens, data and information associated with an individual’s behavior, habits, interests and personality in order to make decisions and predictions about that individual. A good number of these decisions and predictions have or lead to legal or similarly significant effects, implications and even consequences for that individual. Think, for instance, of decisions not to offer that individual a job, loan or mortgage — or to present to that individual mostly or only apartment listings in certain neighborhoods, mostly or only certain health or medical treatment options, mostly or only a set of individuals to monitor or police — based on profiling working with personal biospecimens, data and information.

To more easily clarify whether profiling is occurring in relation to you, you may ask whether a person or entity is:

— (a) collecting personal biospecimens, data and information about you from a variety of sources, some publicly accessible, some you thought were private;

— (b) analyzing that collected personal biospecimens, data and information, on an intimate or large scale, for aspects, attributes or characteristics of you and other individuals;

— (c) looking for associations in the collected biospecimens, data and information to identify correlations between those aspects, attributes or characteristics and behaviors of you and other individuals;

— (d) creating profiles that can be associated with, applied to and tracked with you; (e) predicting your behavior based on the assigned, applied or tracked profiles; or

— (f) making decisions about you based on assessments during this process.

Where such profiling is primarily or solely conducted by automated means — using, for instance, algorithms, artificial intelligence or machine-learning — it is considered one approach or method under “automated individual decision-making” and “automated decision-making.”

Automated individual decision-making often involves no human participation in the analysis, equally low human discernment in the decision-making, and thus often reduced opportunity for holding an entity accountable or responsible when errors or adverse effects result.

Note that just because an association or correlation is found in the collected biospecimens, data and information does not mean that it is significant or that it would be accurate, appropriate, ethical or correct to use it in making the decisions in question.

Thus, The Ikoku Group recommends the following in these processing and research contexts:

— (i) that you be reasonably informed before, during and after the processing or research;

— (ii) that in certain instances — where the individual is a child — such processing and research be strictly prohibited;

— (iii) that in other instances — where sensitive biospecimens, data and information are involved — additional protections be in place;

— (iv) that in other instances — for instance, large-scale processing, or monitoring a publicly accessible place — such collected biospecimens, data or information and their associated risks be minimized by conducting a “data processing risks assessment” or a “research and processing risks assessment” then addressing any concerns found; and finally

— (v) that you be asked to consent, where you are permitted to consent.

‘Pseudo-anonymization’ or ‘Pseudonymization’

References to “pseudo-anonymization” and “pseudonymization” — in the context of either research and investigation or processing biospecimens, data and information — mean and include the access or other processing of biospecimens, data and information conducted by means that do not permit the personal biospecimens, data or information to be attributed to, or identify, a specific natural or legal person without the use of additional information — provided that such additional information is kept separately and is subject to “technical and organizational measures” to ensure that the personal biospecimens, data or information are not attributed to, or identify, the natural or legal person concerned.

Pseudo-anonymization and pseudonymization are employed in processing that is highly protective and respectful of the consent decisions, confidentiality, privacy, security and for-purpose-only uses of the natural or legal person concerned and of the biospecimens, data and information themselves. The “technical and organizational measures” (required, for example, by the European Union GDPR law) serve as a means for us to increase the confidentiality, privacy and security around “re-identifying information” that — when necessary or upon an authorized or authenticated user’s request — could be combined to re-attribute personal biospecimens, data and information to a natural or legal person.

Therefore, personal biospecimens, data and information that have undergone a process of pseudo-anonymization or pseudonymization are and remain personal biospecimens, data and information (since they could be used to identify a natural or legal person, for example, when locked-out users request to regain access to their account or stored content).

For this reason, “pseudo-anonymized” or “pseudonymized” personal biospecimens, data and information, as well as their access and other processing, require and remain under the stringent protections and regulations delineated and described in these Codes and Policies and in either the Policy on Data and Information or the Policy on Human Subjects Research and Investigation. Moreover, natural or legal persons concerned still have Policy-specified rights to ensure and verify that such pseudonymization has been and remains properly and truly conducted.

‘Research and Investigation’

References to “research” or “investigation” mean and include a systematic study designed to contribute to or develop generalizable knowledge, with such study including research development, evaluation and testing. Activities that meet this definition constitute research or investigation for purposes of these Codes and Policies, whether or not they are conducted or supported under a program that is considered research or investigation for other purposes.

‘Restriction of Processing’

References to “restriction of processing” of biospecimens, data and information mean and include any activities or operations or sets of activities or operations which mark stored biospecimens, data and information, or their sets, with the aim of limiting their processing in the future.

‘Risks of Processing’

References to “risks” and “risks of processing” in the context of personal biospecimens, data and information mean and include the anticipated, assessed or reported risks of any processing of personal biospecimens, data and information to the personal biospecimens, data and information and also to the rights and associated interests of the natural and legal persons concerned or the human subject under study.

Such risks, of varying likelihood and severity, may result from processing that leads to physical, material or non-material damage. Think, for instance, of processing that results in discrimination or discriminatory effects, financial loss, fraud, identity theft, reputational damage, unauthorized reversal of anonymization, deidentification or pseudonymisation, violations of confidentiality or privacy, or any other significant economic or social disadvantage. Think, too, of processing that deprives natural and legal persons of their rights or prevents them from exercising their personal data and information rights.

Those risks are considered high where processing entails, and possibly reveals, sensitive personal biospecimens, data and information, criminal convictions and offenses or related security measures. Processing is high-risk, too, where automated individual decision-making, including profiling, is involved; where personal biospecimens, data and information of vulnerable natural persons, including children, are processed; where personal biospecimens, data and information is being processed from or to monitor publicly accessible spaces; and where processing is done on a large scale and involves a large amount of personal biospecimens, data and information, affecting a large number of persons who may also not be able to as easily exercise their Policy-specified rights pertaining to the biospecimens, data and information. Think, also, of processing that may be sound in its methods but is conducted on personal biospecimens, data and information that are sensitive or valuable, and where it would be considerably harmful to natural and legal persons if there were accidental, malicious, unauthorized or unlawful access, alteration, destruction, disclosure, exposure, leakage, loss or theft.

For many of these situations, processing is strictly prohibited. But at times it may be permitted by conducting a “data processing risks assessment” or “research and processing risks assessment” then effectively addressing any concerns found and reported, including eliminating any identified factors leading to risks and further anonymizing or minimizing the personal biospecimens, data and information.

‘Seal’ and ‘Sealed’

The Founder, President and Chair shall provide for a company seal, which may have the name of The Ikoku Group or the pertinent divisions, series, subsidiary or affiliate inscribed thereon and shall otherwise be in such form as may be approved from time to time by the Founder. Thus, references to “seal,” “sealed” and requirements for any instrument to be sealed mean only the use of said approved company seal by causing it to be personally impressed or affixed on an official instrument of The Ikoku Group by a person authorized to do so by the Founder, President and Chair via express and written instrument signed and sealed. No person or entity shall use the said approved company seal in any manner, including “for identification purposes only,” unless such use has been approved by the Founder, President and Chair via express and written instrument signed and sealed.

‘Sensitive Data’ and ‘Sensitive Information’

References to “sensitivity” mean and include a working definition of sensitivity — as delineated below — that helps The Ikoku Group determine or decide whether and what to treat as sensitive personal data and information:

Determination of Sensitivity via Risks to Rights of Persons
that “sensitive data and information” include personal data and information where a breach in protection or security produces high risk to the civil liberties, civil rights and fundamental rights of the natural or legal person concerned.
Determination of Sensitivity via Risks for Identity Theft
that “sensitive data and information” include personal data and information where a breach in protection or security produces high risk and capacity for harm to the natural or legal person concerned in the case of identity theft.
Determination of Sensitivity via Risks of Private and Confidential Access
that “sensitive data and information” include personal data and information processed at or from points of access that produce an especially high risk of, or themselves constitute, a breach or violation of privacy and confidentiality for the natural or legal person.
Determination of Sensitivity via Demarcation
The Ikoku Group also confers a determination of sensitivity for personal data and information demarcated, described or discussed as “confidential,” “private” or “sensitive” — as defined under Confidentiality and Privacy in these Codes and Policies.
Examples of Sensitive Data and Information
therefore that “sensitive data and information” include, but are not limited to, personal data and information — concerning, containing, disclosing, revealing or otherwise relating to birthdate; biometric or genetic data or information; disability; economic and financial condition or information; geolocation or physical movements; government-issued identification and credentials; health, fitness, medical or wellness condition, data or information; ethnic, national or racial origin; gender or gender identity; login, authentication or security credentials and passwords; marital or reproductive choices or status; political affiliations or opinions; philosophical, religious or spiritual beliefs; sex life or sexual orientation; trade or professional union membership; or any other real or perceived characteristic, class or status protected by applicable local, state, federal, national or international law — that are attributable to any actual or potential Founder, Trustee, Director, Manager, Officer, staff, employee or volunteer, donor, grantor or grantee, affiliate, partner, contractor, third party or other agent; and any other actual or potential participant in any activity, communications, operations, program, product, project, service, site, use, visit or other undertaking of The Ikoku Group.
Expected for Confidential, Personal and Private
also include, but are not limited to, data, documentation or information accessed, gathered or otherwise processed at or by The Ikoku Group (including its Products and Services), or in the course of its activities or operations, that are defined, described, discussed or otherwise identified or processed as “sensitive” — and the protection of such data, documentation and information (including prohibitions on their processing) is an essential way in which The Ikoku Group complies with and fulfills the rights of persons to “confidentiality,” to “privacy,” to “confidential conversation,” to “private conversation” and to “private thought.”
Biospecimens, Especially for Care and Research
and for the reasons above as well as a matter of Policy, biospecimens — especially when processed as part of care, research or investigation — are considered sensitive and the protection of such biospecimens (including prohibitions on their processing) is also an essential way in which The Ikoku Group complies with and fulfills the rights of persons to “confidentiality,” to “privacy,” to “confidential conversation,” to “private conversation” and to “private thought.”
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And furthermore, by using or visiting, in any way, The Ikoku Group, any part or section of The Ikoku Group, any part or section of its divisions, subsidiaries or affiliates, as well as any of its Products or Services, you accept and agree to the terms, conditions and requirements described above, and in these Codes and Policies, in their entirety without modification.

‘Signature’ and ‘Signed’

In a number of state, federal and international statutes pertaining to activities, operations and jurisdictions of importance to The Ikoku Group, the definition of signature does not include a stamped, computer generated, digital or electronic signature. Thus, references to “signed,” “signature” and requirements for any instrument to be signed mean only a personally signed and handwritten mark by the person whose signature is so required and authorized, with stamped, computer generated, facsimile, digital or electronic forms of signature not permitted to serve as substitute.

‘Third Party’ and ‘Third Country’

The Ikoku Group endeavors, in its official documents and policies, to clearly and consistently consider and describe varied persons and relations that help with the fulfillment of the originating mission and purposes. Thus, references to “third party” mean and include a person or entity who is not one of the principals of an activity or relationship (i.e. an agreement, contract, operation, service or transaction) but is involved in that activity or relationship in an official or recognized capacity.

Meanwhile, references to “third country” mean and include a person or entity located in a country different from the principal country (or region) that serves as the expected or typical setting for an activity or relationship. But (similar to a third party) that person or entity and associated country has become a party to and setting for the activity or relationship in an official or recognized capacity.

All activities, relationships and equivalent arrangements between The Ikoku Group and a third party or third country require, in addition to our official documents and policies, approval and authorization from the Founder as well as a written contract or equivalent legal instrument, the further requirements for which are often delineated and described in these Codes and Policies.

‘Trial,’ ‘Clinical’ or ‘Research’

References to “clinical trial,” “research trial” or “trial” in the context of research mean and include a research or investigation study in which one or more human subjects are prospectively assigned to one or more interactions or interventions (which may include placebo or other control) to evaluate the effects of the interactions or interventions on biomedical, behavioral, physiological, psychological or technological outcomes.

‘User Content, Data and Feedback’

References to “user content, data or information and feedback” mean and include the following:

User Content
content, media and other material created by a user or other person outside of The Ikoku Group and its Products and Services, and without use of names, marks or other properties or resources of The Ikoku Group or its Founder and Owner, Alvan Azinna Chibuzo Ikoku.
User Data and Information
data and information created, generated or further processed during processes of The Ikoku Group integral or incidental to a user’s or other person’s activity, communication, visit or other use pertaining to The Ikoku Group and its Products and Services.
User Feedback
content, media and other material generated or provided by a user or other person in concert with, within or in response to The Ikoku Group and its Products and Services, and while making authorized use of or reference to names, marks or other properties or resources of The Ikoku Group or its Founder and Owner, Alvan Azinna Chibuzo Ikoku.
User Feedback, Examples and Scope
User Feedback includes but is not limited to comments, conversations, dialogues, feedback, forums, groups, polls, remarks, reports, responses, reviews, solutions, suggestions, support, surveys and their equivalent, whether generated or provided by using The Ikoku Group or its Products and Services; about any aspect of The Ikoku Group or its Products and Services; to or through The Ikoku Group or its Products and Services; to or through persons working with The Ikoku Group, with the Products and Services or with such generated or provided material; or through other means, media, materials or otherwise.
Contributor, Participant, Visitor for User
note that for Policies featuring the above references, “user” can at times be followed, preceded or replaced with “contributor,” “participant” or “visitor.”
Note on Identifying and so Personal Nature
note that any and all user content, data or information and feedback may be identifying if attributable to a single user or visitor, has not undergone processes of irreversible anonymization and aggregation, and so has also remained or returned to being personal.

Please do also see the Policies on Data and Information, on Human Subjects Research and Investigation, and on Intellectual Property for further pertinent details concerning user content, data and feedback.

‘Writing,’ ‘Written,’ and ‘Electronic Communication’

References to “writing” and “written” mean and include only a recorded textual message in a recognized and standardized official language, expressly transcribed into physical, character- and letter-based form by a consenting person being the “writer,” to a consenting natural or legal person being the “recipient,” capable of comprehension by ordinary standardized visual, tactile or auditory means of reading and interpretation, and shall include “electronic mail (email)” and very similarly written “electronic communication,” provided that the conditions set forth below are met:

(1) Clarity, Legibility and No Inference — As with all actionable, applicable, approvable, legitimate and official communication from, for, of, in, within or pertaining to The Ikoku Group, “electronic communication” must be expressly written, clearly legible and require no inference (or “guesswork”) as to its content, meaning, sender or writer, and such communication must also create a record that:

Retained, Retrieved and Reviewed by Recipient
(a) may be retained, retrieved and reviewed by a recipient thereof and by other persons thereafter.
Reproduced by Recipient
(b) may be directly reproduced in clearly legible paper form by such a recipient through an automated process.
Later Rendered into Legible Form
(c) may thereafter be similarly rendered into clearly legible tangible form.

(2) Approval of Means of Communication — As with all actionable, applicable, approvable, legitimate and official communication from, for, of, in, within or pertaining to The Ikoku Group, acceptable forms of electronic communication must adhere to the above and furthermore be approved for conducting specified purposes of The Ikoku Group via unanimous agreement and consent of the following:

Founder and Leadership
(a) Founder, President and Chair of The Ikoku Group.
Administration, Executive and Management
(b) any pertinent Managers, Directors and Officers using such communication to carry out their activity pertaining to The Ikoku Group.
Stakeholders and Partners
(c) any pertinent interests-holders, shareholders and equivalently significant stakeholders and partners using such communication to carry out their activity pertaining to The Ikoku Group.
Employees and Agents
(d) any pertinent employees, staff, volunteers, third parties and other agents using such communication to carry out their activity pertaining to The Ikoku Group.
Customers, Users and Visitors
(d) any pertinent customers, visitors, users and communities using such communication to carry out their activity pertaining to The Ikoku Group.

(3) Provided and Unrevoked Consent — As with all actionable, applicable, approvable, legitimate and official communication from, for, of, in, within or pertaining to The Ikoku Group, writing by electronic communication may be deemed validly delivered, and any contracts or agreements thereof dependably enforceable, only if delivered to a recipient who has provided an unrevoked and written consent to the use of such means of transmission and communication for the specified activity pertaining to The Ikoku Group.

(4) Clear Conditions of Consent — As with all actionable, applicable, approvable, legitimate and official communication from, for, of, in, within or pertaining to The Ikoku Group, such electronic transmission is not formally authorized, and no contracts or agreements thereof are dependably enforceable, unless in addition to satisfying the aforementioned conditions — as well as the requirements for consent — the consent to the transmission has been preceded by or includes a clear written statement to the recipient as to:

Right of Recipient to Record
(a) any right of the recipient to have the record provided or made available on paper or in nonelectronic form.
Applicability of Consent to Communications
(b) whether the consent applies only to that transmission, to specified categories of communications, or to all communications from, to and pertaining to The Ikoku Group.
Procedures to Withdraw Consent
(c) the procedures the recipient must use to withdraw consent.

(5) Facsimile, Email, Message Boards and Networks: Furthermore, electronic communication or transmission shall include only:

When Directed to Number or Address on Record
(a) facsimile telecommunication or electronic mail when directed to the facsimile number or electronic mail address, respectively, for that recipient on record with The Ikoku Group.
When Using Clearly Designated Electronic Board or Network
(b) posting on an electronic message board or network which The Ikoku Group has designated for those communications, together with a separate notice to the recipient of the posting, which transmission shall be validly delivered upon the later of the posting or delivery of the separate notice thereof.

No official means of communication can in itself entail a violation of confidentiality or privacy or a significant risk to the civil liberties, civil rights and fundamental rights of a natural or legal person — nor shall the performance of any official agreements, contracts, duties or responsibilities of The Ikoku Group require such means of communication. Where the conditions above have not been met The Ikoku Group considers such communication to have not been approved and require that both the Founder be notified immediately and a remedy of the situation be promptly achieved.

Further References

Where duties, expectations, freedoms, principles, rights, responsibilities, standards as well as means, measures, methods and practices are referred to, they are as delineated and described in these Codes and Policies. And unless where normally expected and the context otherwise clearly indicates — for instance, there is only one primary company, The Ikoku Group, one Founder and one Owner — words used in the singular include the plural, and the plural includes the singular.

The Central Policies

Provision

As stated earlier, The Ikoku Group User Agreement and Code of Conduct consist of several Codes and Policies that collectively govern all of your activity with, within, for, in reference to and otherwise pertaining to The Ikoku Group, including its divisions, series, subsidiaries and affiliates, and its Products and Services. By continuing, you indicate that you understand that these Codes and Policies include — but are not limited to — the Founding and Governing Code of Ethics, the Policy on Privacy and Confidentiality, the Terms and Conditions of Use and Service, and the Acceptable Use Policy along with all Associated Codes and Policies. Access to the aforementioned is provided below.

Founding Code of Ethics

Founding Code of Ethics (HTML and PDF)

Privacy and Confidentiality

Policy on Privacy and Confidentiality (HTML and PDF)

Terms and Conditions

Terms and Conditions of Use and Service (HTML and PDF)

Acceptable Use Policy

Acceptable Use Policy (HTML and PDF)

All Policies

All Policies (HTML and PDF)

Incompatibility with Founding

Incompatibility with Founding and Mission of The Ikoku Group — The Ikoku Group was founded by Alvan Azinna Chibuzo Ikoku partially in response to a set of consistent, extensive, pervasive and dehumanizing practices of violations of the privacy, confidentiality, civil liberties and fundamental freedoms and rights of the Founder. Any version of these practices — as well as the accruing of benefit or information from such practices, and also persons assisting, employing, permitting or otherwise condoning such practices — are by definition incompatible with The Ikoku Group and its development and operation (and remedies to and with the Founder should be sought immediately upon their discovery).

For these reasons, no person or entity may become or remain qualified as manager, director, trustee, officer, executive, board or committee member, staff or employee, advisor or consultant, provider of care, education, mentorship, or training, affiliate, partner, representative, recipient of funds or resources, researcher or observer, sponsor, supervisor, volunteer, parental entity, voting or decision-making entity, member or stakeholder, or other agent of The Ikoku Group (including its divisions, series, subsidiaries, affiliates and partners) if conducting any of the aforementioned activities or their equivalent, as well as if in intentional violation of The Ikoku Group ethics, policies, protections and rights concerning privacy and confidentiality, unconsented monitoring, supervision, surveillance or tracking, and especially the Founding and Governing Code of Ethics.

Due to this stipulation, under no circumstances shall the following persons — as well as any affiliates, associates, collaborators, employees, employers, executives, leadership, members, partners, representative, staff, volunteers, third parties and other agents of said persons — qualify:

Example of Natural Person
Eleanor Marie Brown (of Jamaica and the United States, Brown University, University of Oxford and Yale Law School).
Example of Legal Person
Leland Stanford Jr University, also known as Stanford University (of Palo Alto, California).
Example of Government Person
as well as, additionally, for related ethics, policies and protections reasons — any government or public authority, entity, office or official, and any person who has held such authority, office, position or equivalent capacity, function or relationship within the preceding five (5) years.

And furthermore, by using or visiting, in any way, The Ikoku Group, any area, part, section or properties of The Ikoku Group, any area, part, section or properties of its divisions, series, subsidiaries or affiliates, as well as any of its Products or Services, including the Sites, you accept and agree to the terms, conditions and requirements described above, and in these Codes and Policies, in their entirety without modification.

Child Looking Up Among Adult Celebrants
Child at Ceremony, Ikorodu, Nigeria, 2016 (Oshomah Abubakar)
Boy Smiling While Showing Hand String Game
Boy Playing Hand Game, 2017 (Alexander Radelich)
Child in Costume Looking at Camera
Niño, Cusco, Peru, 2018 (Ben Ostrower)
Tatooed Map on Outstretched Arm
Map on Arm, Dayton, US, 2017 (Don Ross III)
Woman with Arm on Head, Smiling
Woman in Joy, Kolkota, India, 2017 (Loren Joseph)
Boy Among Chidlren in Class, Looking at Camera
Children in Classroom, Nakasaki District, Kampala, Uganda, 2017 (Bill Wegener)
Woman Seated on Mat on Floor, Holding Fan
Seated by Kpone Katamanso District Assembly Office, Tema, Ghana, 2017 (Nathaniel Tetteh)
Girl Kneeling in Busy Street
Tibetan Girl, 2017 (Journey Yang)

Associated Policies

Provision

Provided further below is access to Associated Policies that, along with the above Central Codes and Policies, collectively constitute The Ikoku Group User Agreement and Code of Conduct. Much of the principles articulated in these Associated Policies are included either explicitly or by extension in the above Central Codes and Policies; but they are worth articulating separately, for the purposes of clarity, detail, and reproducible company and community ethos and standards.

Accessibility and Disability

Accessibility and Disability (HTML and PDF)

Conflicts of Interest

Conflicts of Interest (HTML and PDF)

Company Integrity

Company Integrity (HTML and PDF)

Data and Information

Data and Information (HTML and PDF)

Discrimination and Harassment

Discrimination and Harassment (HTML and PDF)

Diversity and Inclusion

Diversity and Inclusion (HTML and PDF)

Fairness and Justice

Fairness and Justice (HTML and PDF)

Financial Transactions

Financial Transactions (HTML and PDF)

Forced Labor, Trafficking, Slavery

Forced Labor, Trafficking, Slavery (HTML and PDF)

Human Subjects Research and Investigation

Human Subjects Research and Investigation (HTML and PDF)

Independence and Freedoms

Independence and Freedoms (HTML and PDF)

Intellectual Freedom and Speech

Intellectual Freedom and Speech (HTML and PDF)

Intellectual Property

Policy on Intellectual Property (HTML and PDF)

Members and Voting

Members and Voting (HTML and PDF)

Private Nature and Public Good

Private Nature and Public Good (HTML and PDF)

Reasonable Transparency

Reasonable Transparency (HTML and PDF)

Safety and Security

Safety and Security (HTML and PDF)

Societal Impact and Sustainability

Societal Impact and Sustainability (HTML and PDF)

Updates and Keeping Informed

Once again, by continuing to engage in activity within, on behalf of, and in reference to The Ikoku Group, and by continuing to visit and use the Products and Services, including the Sites, you indicate that you understand that The Ikoku Group reserves the right to update these Codes and Policies from time to time, and at any time, and that you are encouraged to check back periodically to review the most current, updated version of these Codes and Policies. As a person or entity engaging in any activity with, within, for, on behalf of, in reference or otherwise pertaining to The Ikoku Group, or a visitor or user of the Products or Services, including the Sites, it remains your responsibility to keep informed about such posted changes.

Ethics at the Company, in Company

The Codes and Policies above deeply reflect the founding and mission of The Ikoku Group. They inform the work of The Ikoku Group and efforts to achieve benefit, impact and success. The result, therefore, are three features evident in the company, its products and services, and most importantly, its communities:

01.

The Ikoku Group as a Company of and about Ethics

The company ethics and policies are carefully crafted, then adhered to by a range of individuals and divisions working in varied relation to The Ikoku Group to establish, develop and provide a private company dedicated to fostering care and creativity, ethics and innovation.

02.

Built with Integrity and Respect in Mind

Who take as their basis the most robust conceptions of respect, humanity, integrity, civil liberties and civil rights — up to and beyond what the law protects and provides for — as they carry out and embody the mission and purposes of The Ikoku Group.

03.

In Divisions that are Safe, Secure and Respectful

And who also join in ongoing efforts to ensure that The Ikoku Group, its Divisions and its Products and Services remain safe, secure and respectful places to do work, to express and discuss, to teach and learn, to form, inform and even alter local and global communities.

More About Us

The Ikoku Group

The Ikoku Group was formed to foster care and creativity, ethics and innovation in work and communities of enduring concern to its founder, Alvan Azinna Chibuzo Ikoku, and partners.

— About The Group

Mission, Scope, Founder

Founded as a US limited liability company, The Ikoku Group is engaged in work that is both domestic and international in scope, concerned as it is with communities and entities located across borders.

— Founding & Governance

Nature, Leadership, Ethics

The Ikoku Group is governed by its Founder‘s Agreement, Code of Ethics and associated Policies — each thoughtfully developed and collectively constituting the governance documents of The Ikoku Group.

— Policies

Agreement, Codes, Terms, Conditions

Where available, The Ikoku Group provides updates on news, events and media coverage pertaining to its operation, development, work, and communities.

— Press & Media

News, Events, Coverage

Where appropriate, The Ikoku Group also provides periodic alerts, newsletters and reports for those who wish to become more deeply informed of recent developments as well as past and future work.

— Reports

Alerts, Newsletters, Periodicals

Those interested in its mission, objectives and work may contact The Ikoku Group and its Founder for available positions, contributorships and partnerships. A career at and with The Ikoku Group will likely be deeply rewarding.

— Careers at The Ikoku Group

Positions, Volunteers, Contributors