Your Privacy is Important and a Right
We design and operate the sites of The Ikoku Group (collectively, the “Sites”) as well as our products and services (collectively, the “Products” and the “Services”) to help us and you do truly beneficial and transformative things in the communities and publics we serve together. We also design and operate our Sites, Products and Services to fully honor the trust you place in us, and to therefore secure and protect your privacy and any confidential information you may provide. We take privacy to be a fundamental right. Not to be violated by any of us in our activities within, on behalf of, or in reference to The Ikoku Group, its divisions, series, subsidiaries, or affiliates.
Our task here is to provide important information and explain our Policy on Privacy and Confidentiality (the “Policy”) for any and any part of our Sites, Products, and Services. This Policy forms an essential part of our Code of Corporate Conduct and User Agreement, which governs your use of, access to, affiliation with, reference to, and participation in activities and communities of The Ikoku Group.
An Approach to Privacy Derived from Advances in Law
Our approach to this Policy derives, in part, from three advances in the law on privacy and confidentiality:
— a set of privacy protections ratified in California, which include the recent California Consumer Privacy Act (CCPA), but also the constitutional principle codified in the State Constitution of California that “all people are by nature free and independent and have inalienable rights” to “enjoying and defending life and liberty, acquiring, possessing, and protecting property, and pursuing and obtaining safety, happiness, and privacy;”
— the European Union’s General Data Protection Regulation (GDPR); and
— the United States’ Health Insurance Portability and Accountability Act (HIPAA) governing medical and health information.
Together, these advances in legal protections for privacy and confidentiality have served as important guides to the crafting of the Policy, which makes substantive our commitment to your fundamental right to privacy, to the highest levels of protections for your data and digital life, and to the need to ensure that your confidential information is secure.
Additional Protections for You
The above commitment means that while the Policy features several standard industry-wide guarantees, we hold the right to privacy to be a constitutional one, compelling us to develop ways to maintain the highest levels of privacy you ask for while you personalize your experience with our Sites, Products and Services. It also means that, with HIPAA as guide, we adhere to the strictest codes and policies that help The Ikoku Group uphold the duty to depersonalize information and the duty to report any violations. And lastly, it also means that we commit to developing the requisite policies, resources, and technologies to meet — throughout the Sites, Products, Services, divisions, series, subsidiaries and affiliates of The Ikoku Group — the newer duties set by CCPA of California and by the GDPR set of the European Union, including responsibilities and services associated with your right of access to your data, your right to data erasure, your right to data portability, and your rights to restrict and object to data processing. We feel strongly that these additional protections emanate directly from our Founding and Governing Code of Ethics.
It is also important to note that when you visit, browse or use any or any part of our Sites, Products, or Services, and especially when you provide to us any content or personal information, you are indicating that you understand this Policy, that you are agreeing to the associated Founding Code of Ethics and policies that collectively constitute the Corporate Code of Conduct and User Agreement, as they are amended from time to time, and that you hold your Agreement to be the legal equivalent of a signed, written contract, equally binding, that you accept all the terms of this Policy, and agree to be legally bound by them.
If you are visiting or using our Sites, Products or Services for an organization, you are agreeing to this Agreement on behalf of that organization, and represent and warrant that you can do so.
Please do not use our Sites, Products or Services or provide content or personal information if you do not agree to all the Policies and terms of your Agreement or if your jurisdiction will not honor them.
As mentioned above, the Code of Corporate Conduct and User Agreement consists of several collectively formed policies, with the Terms and Conditions of Use being one of them. Thus, your use of the Site and any of our Services is also subject to our Founding and Governing Code of Ethics, our Policy on Privacy and Confidentiality, our Acceptable Use Policy, and a number of associated policies made available to you on our Policies page.
Changes in Sites, Products, Services
We may at any time, without notice or liability, change, temporarily suspend, or discontinue any aspect of our Sites, Products, or Services. We may also do the same for the availability of any feature, database, or content of our Sites, Products or Services. And we may impose limits on certain features and services or restrict your access to parts or all of our Sites, Products, or Services, again without notice or liability.
Changes in Policies
Please also note that we reserve the right to change this Policy, and any of its associated codes and policies, at any time and without liability. If we make significant material changes, we will attempt to notify you through our Sites, Products, or Services. But you also agree that notices we may provide on the Sites themselves shall be deemed reasonable notice for this purpose.
If you object to any changes, you may close any account or cease any services you maintain with us. Your continued use of our Sites, Products, or Services after we publish or send a notice about changes to this Policy, or any associated codes or policies, will constitute your acceptance of such modifications.
The Policy on Privacy and Confidentiality forms part of a legally binding agreement between The Ikoku Group and you, and they govern your use of our Sites, Products, and Services, and all information on or submitted through them. Most users of our Sites, Products, and Services are independent individuals, though many are employees or other agents of entities, so references to “you” means both: (1) the “user” individually and (2) any entity or individual that is your employer or for whom you act as agent, unless otherwise stated on our Sites, Products, or Services, or in this Policy.
Persons under 18 years of age are not authorized to use our Sites, Products, or Services.
Given the above, the details of the Policy are as follows:
1. Definition of Visitor and User Personal Information
1.1. We define personal information of our visitors and users as “User-Generated Data” (also known as “User Data”) that relates to or can be used to identify or contact a single person.
1.2. We understand an identifiable person as someone who can be directly or indirectly identified via reference to an identifier or a combination of identifying information.
1.3. Examples of 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 your username), a device identifier (such as your IP address) or to one or more items of information specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of a single person.
2. Types of Visitor and User Personal Information
The types of personal information that either you provide or we collect include the following:
2.1. Account Information: Many parts of our Sites, Products, and Services may ask you to sign up for an Account or create a publicly visible Profile. If you decide to sign up for such Services, you will be asked to provide your name, email address, telephone number, and at times, a profile photograph, a home address, and a means of payment (like a credit card) to be stored within your account or profile. If you choose to take full advantage of our Profile options, or our connecting, sharing, communication and other features, you may decide to provide more in the way of photographs and other audio-visual material, as well as contacts information. We ask that you do this with thought, and we will provide you with clear ways to control the visibility of such information.
2.2. Device Information: As you visit, browse, and use our Sites, Products and Services, we may collect information that specifically identifies the device you are using. Examples of such information include, but are not limited to, your IP address, the model of your device, your browser type and language, your operating system, and information about your mobile network that, once again, includes your phone number. Note that The Ikoku Group may connect such device-specific identifying information with your Account or Profile.
2.3. Log Information: And when you visit, browse, and use our Sites, Products and Services, we also may collect and store information via what we call log files or server logs. Such information may include your search queries and other details about how you use our Sites, Products and Services; events associated with your device such as crashes, system activity, and hardware settings; or the URLs of sites that referred you to us, as well as the date and time of your referral request.
2.4. Location Information: We may also collect, process, and store information about your geographic location as you visit or use our Sites, Products and Services. The technologies we may use to determine such information may include IP, GPS, and other sensors with the ability to connect with nearby devices, Wi-Fi access points, and cell towers.
2.5. Information Unique to Applications: There are certain applications that we may provide that create unique items of information (such as a unique application number) when you install them on your device. That information, as well as device-specific data, may be periodically sent to our servers, and there collected, processed, and stored. This may occur not only when you use the application on your device, but also when you install and uninstall that application.
2.6. Local storage: Note also that there are a range of mechanisms to collect and store information directly on your device, such as browser web storage and application data caches, and The Ikoku Group may decide to use such technologies to better understand visitor and user activity.
2.7. Cookies etc: And lastly, but perhaps most importantly, is information collected and processed via cookies and similar technologies (such as pixel tags and web beacons) that are typically placed on your browser as you visit a variety of sites and services. The Ikoku Group may choose to use such mechanisms to identify you and collect and store information when you visit and use our own Sites, Products and Services, and this may be done in conjunction with trusted and approved Third-Party Partners aiming to improve your experience with us.
2.8. Information collected via cookies and similar technologies can often be treated as non‑personal information by us. But we note whenever local law asks us to consider identifiers like IP addresses as personal information. And where any non-personal information is combined or even associated with any personal information, we ourselves consider such combined information to be personal for the purposes of this Policy.
2.9. Please note that the types of personal information listed above, as well as the technologies used to access and process them, are also very clearly explained in our Terms and Conditions. Our goal, as always, is to try every means available to us to improve public education around User-Generated Data. And to have you understand as fully as possible what you are entrusting us with.
3. Uses of Personally Identifiable Information
During your contact with The Ikoku Group, our divisions, series, subsidiaries, and affiliates, our Sites, Products, and Services, and approved Third-Party Partners, you may be asked to provide your personal information. You will not be required to provide the requested personal information to visit and browse our Sites, Products and Services. Though do note that if you decide not to do so, you might not be able to take full advantage of our Sites, Products and Services.
Whenever we collect, process, store, or use your personal information it is with the primary purpose of improving the experience you, as well as all visitors and users, have with our Sites, Products and Services. We expect everyone at The Ikoku Group, as well as our Third-Party Partners, to use your personal information consistent with this purpose and this Policy. Below are some of the ways we ensure that occurs:
3.1. Account Setup, Operation, and Maintenance: We may use your collected and verified personal information to enable you to securely activate and further enhance your Account and Profile; to help you add, amend, or clarify any information and audiovisual material you provide; to facilitate you taking full advantage of any connecting, sharing, communication and other features of our Sites, Products and Services; and to keep sufficient track of your activity and help requests to aid in any maintenance issues you bring to our attention. We may also use your information for loss prevention and anti-fraud purposes.
3.2. Personalization of Sites, Products, Services: We use your identifying information whenever you seek to personalize your experience in our Sites, Products and Services, including, for instance, browser language preference, notice of news and events associated with your preferences, updates on products or activities, preferred screen views, and adjustments to algorithms for feeds.
3.3. Troubleshooting of Sites, Products, Services: We also use personal information to help us detect and resolve repeat and developing issues within sections of our Sites, Products and Services, as well as to analyze your activity among that of other visitors in our attempt to enhance user experience and overall efficacy.
3.4. Development and Testing of Sites, Products, Services: We may use personal information for internal purposes such as auditing, data analysis, and research to improve our sites, products, services, and customer communications. We will also at times ask you to personally participate in focus groups, testing, and staged roll-outs of newer and hopefully improved versions of our Sites, Products and Services. Your initial feedback will be vital for such work and returning to you to for followup will also be essential.
3.5. Regulated, Targeted Advertising: The Ikoku Group may choose to use your personal information, in restricted and carefully regulated ways, to help with its Advertising Services. Your opt-in consent to this use (and the clear opportunity to halt it) will be required.
3.6. Surveys, Polls, Research: Because of the public benefit purposes of The Ikoku Group, we may often ask you to consider participating in surveys, polls, and other regulated and approved research. The purposes and uses of the results of such work will be made clear, as will be your right to informed consent and opportunity to end your participation at any time.
3.7. Legal Obligations: [to be included]
3.8. Updates on The Ikoku Group: From time to time, we may use your personal information to send important notices, such as communications about the company and our communities, significant changes to our terms, conditions, and policies, and major modifications of our Sites, Products and Services. This information remains among the most important to your experience of and participation in The Ikoku Group and the local and global communities you foster and help create. You may therefore not opt out of receiving these communications, and we hope you do not mind.
4. Collection and Use of Non-Personal Information
The Ikoku Group may also collect data in a form that does not, on its own, permit direct association with or identification of any specific individual. Often that form results from secure processes of encryption, de-personalization, and aggregation. Aggregated data is considered non‑personal information for the purposes of this Policy.
4.1. We may collect, use, transfer, and disclose non-personal information — especially in this form — for any purpose.
4.2. We may, for example, collect information such as occupation, language, zip code, area code, unique device identifier, referrer URL, location, and the time zone where a Site, Product or Service is being used, with the express purpose of enhancing of understanding of visitor and user behavior and improving our Sites, Products, and Services.
4.3. We may also collect information regarding visitor and user activities on our Sites, Products and Services. This information will be aggregated and analyzed to produce better information and insight about visitor and user activity in different sections and parts of our Sites, Products and Services.
4.4. Still, note, as stated earlier, that whenever we combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.
5. Broader Definition and Protection of Personal and Confidential Information
The Ikoku Group considers the privacy of Personal and Confidential Information (as described above and further below) to be essential to its operations and the achievement of its originating mission and company purposes and claims a valuable proprietary interest in such Personal and Confidential Information.
Therefore, for purposes of this Policy, our Codes and Policies, for any activity within, on behalf of and in reference to The Ikoku Group (including its divisions, series, subsidiaries and affiliates), and in our official documents and elsewhere, “Personal Information” means and includes any and all data, information, and documentation generated, or developed in the course of The Ikoku Group’s activities that relates to or can be used to identify or contact a single person.The Ikoku Group understands an identifiable person as someone who can be directly or indirectly identified via 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 physical, physiological, genetic, mental, economic, cultural, or social identity of a single person.
Also, for purposes of this Policy, our Codes and Policies, for any activity within, on behalf of and in reference to The Ikoku Group (including its divisions, series, subsidiaries and affiliates), and in our official documents and elsewhere, “Confidential Information” means and includes any and all information and documentation prepared, generated, or developed in the course of The Ikoku Group’s activities that is identified as “confidential,” discussed as “confidential,” or, in context, can reasonably be expected to be treated as confidential, as well as such information and documents that is not generally known or made available outside The Ikoku Group. Confidential Information may include files, documents, research materials, background materials, memoranda, reports, financial information, tax materials, health information, and any documentation (including letters of recommendation and evaluations) relating to any actual or potential grantee or grantor; any actual or potential employee, staff, volunteer, Manager, Trustee, Director, or Officer; and any other actual or potential participant in any activity, operations, program, project, or other undertaking of The Ikoku Group.
No Manager, Director, Trustee, Officer, staff or committee member, employee, volunteer, representative, partner, third-party or other agent of The Ikoku group shall be asked to or allowed to conduct a violation of privacy or confidentiality that is either unlawful or without prior express and written consent of the original owner of the Personal or Confidential Information, or shall be permitted access to, use of, or disclosure of any Personal or Confidential Information that is either unlawful or without the prior express and written consent of the original owner of the Personal or Confidential Information.
6. Activity and Operations Consistent with Privacy Laws
No Manager, Trustee, Director, Officer, Committee member, staff member, employee, volunteer, representative, partner, third-party, visitor, user, or other agent of The Ikoku Group shall be permitted to access, disclose, or use Personal or Confidential Information in a manner that violates privacy laws in California, Delaware, the United States, or other Nations, as they now exist or as they may hereafter be amended.
7. No Privacy or Confidentiality Violation in Service of the Group, the Public, or Individual Benefit
No activities of The Ikoku Group shall entail an invasion of privacy or confidentiality of any individual, nor shall they come into conflict or be inconsistent with the most robust protections of privacy and confidentiality or with the strictest interpretations of privacy and confidentiality laws, as they are described in the Founding and Governing Code of Ethics, these Codes and Policies, and state, federal and international statute, including where such proposed activities may seem justified via conceptions of or arguments for public benefit or the public good, or via conceptions of or arguments for presumed care, safety or security for individuals or communities.
8. No Privacy or Confidentiality Abrogation or Diminshment
No access, activity, or operations in, on behalf of, in reference to, or more generally pertaining to The Ikoku Group, its leaders, employees, agents, or communities, its divisions, series, subsidiaries, or affiliates, or our Sites, Products or Services may abrogate or diminish any privacy or confidentiality right or protection, even when seemingly justified via “expectation of privacy,” “one-party consent,” “third-party doctrine” or “good faith” argumentation or their equivalent, by any individual or entity, corporate, private, public, or otherwise. Any such activity shall be contrary to the originating mission and purposes of The Ikoku Group and its Founding and Governing Code of Ethics.
Updates and Keeping Informed
We may update this Policy from time to time and encourage you to check back periodically and review our most current, updated version. If you are an active user of our Sites, Products and Services, it remains your responsibility to keep informed about such posted changes.
Questions and Violations
If you have any questions regarding this Policy, or wish to report any violations you notice (or feel may be occurring), please contact us at firstname.lastname@example.org.
Download PDF of The Policy on Privacy and Confidentiality
And below are the governing policies that have been thoughtfully derived from The Founding Codes of Ethics for The Alvan Ikoku Group LLC.
Privacy and Confidentiality
Privacy and Confidentiality (HTML and PDF)
Intellectual Property (HTML and PDF)
All Policies (HTML and PDF)
Areas of Focus Chosen for the Group’s Mission and Work
The Group’s Areas of Focus have been expressly chosen — and periodically evaluated — to ensure specified and full attention to communities and issues of enduring concern and commitment to the Founder and partners.
Divisions Formed and Administered for the Group’s Operations
The Group’s Divisions have also been expressly formed, administered — and periodically evaluated — to ensure efficacious operations in conceptualizing, developing, and carrying out ideas, objectives, and solutions.
Founding Ethics, Agreement and Policies for Group Governance
And guiding the Group through all its work are the Founding and Governing company agreements, codes, and attendant policies — collectively constituting its governance structure and standards.
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 Us
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 offering services to communities and entities located across borders.
— Founding & Governance
Nature, Leadership, Ethics
The Ikoku Group is governed by its Founder‘s Agreement, by its Founding Ethics, and by a set of associated Policies — each thoughtfully derived from the above and collectively constituting the Group governance documents.
Agreement, Laws, Terms, Conditions
Where available, The 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 Group also provides alerts, newsletters and periodic reports for those who wish to sign up for, receive them — and thus become more deeply informed of recent developments and our past and ongoing work.
Alerts, Newsletters, Periodicals
Those interested in its mission, objectives and work may contact The Ikoku Group for positions in its management, employee and contributing staff, and board and committee membership. A career at The Group will likely be deeply rewarding.
— Careers at The Ikoku Group
Boards, Jobs, Contributions