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Preamble

Overview

The Codes and Policies of The Alvan Ikoku Holdings (collectively, the ā€œPoliciesā€ or ā€œCodes and Policiesā€)* constitute The Ikoku Holdings User Agreement and Code of Conduct, and as such govern any and all activity conducted at, by, for, in, on behalf of, with or otherwise pertaining to The Ikoku Holdings.

Therefore, persons engaged in any such activity are expected to uphold the principles delineated below.

Your Agreement

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

Persons Adhering to Agreement
that the Codes and Policies areĀ 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 Holdings.
Applicability and Governance of Agreement
that the Codes and Policies governĀ any and all of your activity, communication, operation, participation, visit, and other use, in any way, pertaining to The Ikoku Holdings, its series, subsidiaries, and affiliates, and the Products and Services, and that you agree to abide by, assist, fully cooperate with and not interfere with The Ikoku Holdings 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 Holdings, the divisions, series, subsidiaries, or affiliates, and the Products and Services — directly or indirectly as further described below — you are agreeing to theĀ Codes and PoliciesĀ that collectively constitute The Ikoku Holdings 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 Holdings, the divisions, series, subsidiaries, or affiliates, and the Products and Services; or through persons and entities working with The Ikoku Holdings, the divisions, series, subsidiaries, or affiliates, and the Products and Services; 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 Holdings 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 ā€œAgreementā€).
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 engaging in any activity at, by, for, in, on behalf of, with or otherwise pertaining to The Ikoku Holdings, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of The Ikoku Holdings, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the divisions, series, subsidiaries, or affiliates, as well as any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the Products or Services, you accept and agree to the terms, conditions, and requirements described above, and in the 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 Holdings 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,Ā and especially The Ikoku Holdings 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 Holdings, its series, subsidiaries, and affiliates, or the Products and ServicesĀ with the permission and supervision of an adult parent or guardian.
Reading and Understanding
that you have read and understood the Codes and Policies,Ā and especially The Ikoku Holdings User Agreement and Code of Conduct.
Voluntary Nature of Consent
that you understand your consent to be voluntary in nature.
Agreement and Consent
that you consented to and agreed to be legally bound by the Codes and Policies,Ā and especially The Ikoku Holdings User Agreement and Code of Conduct.

And furthermore, by engaging in any activity at, by, for, in, on behalf of, with or otherwise pertaining to The Ikoku Holdings, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of The Ikoku Holdings, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the divisions, series, subsidiaries, or affiliates, as well as any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the Products or Services, you accept and agree that your consent meets the conditions, principles, and requirements for consent as delineated and described in theseĀ 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 Holdings User Agreement and Code of Conduct, you have read, understood, consented to, and agreed to be legally bound by and abide by The Ikoku Holdings User Agreement and Code of Conduct, and the Codes and Policies, in their entirety without modification, including as they are amended from time to time by The Ikoku Holdings.

Your Duty to the Policies

With respect to your attendant duty to the Codes and Policies — and your legally binding agreement to not diminish, interfere, or violate, in any way, their principles, protections, requirements, or rights — you represent and warrant that you understand and shall adhere to the following:

Refraining from Any Intentional Breach or Violation
avoiding, refraining from, and stopping any access, action, activity, communication, operation, or other use and any collaboration, collusion, coordination, planning, or other preparation you or any person engage in that may encourage, result in, or otherwise foster any intentional breach, diminishment, disruption, impediment, interference, or other violation pertaining to the Codes and Policies; and that may encourage, result in, or otherwise foster any intentional breach, diminishment, disruption, impediment, interference, or other violation pertaining to policy, legal and regulatory protections and rights of The Ikoku Holdings, The Ikoku Group, and the sole Founder, Owner, and President.
Refraining from Any Unintentional Breach or Violation
avoiding, refraining from, and stopping any access, action, activity, communication, operation, or other use and any collaboration, collusion, coordination, planning, or other preparation you or any person engage in that may encourage, result in, or otherwise foster any unintentional breach, diminishment, disruption, impediment, interference, or other violation pertaining to the Codes and Policies; and that may encourage, result in, or otherwise foster any unintentional breach, diminishment, disruption, impediment, interference, or other violation pertaining to policy, legal and regulatory protections and rights of The Ikoku Holdings, The Ikoku Group, and the sole Founder, Owner, and President.
Reporting Any Intentional Breach or Violation
reporting — directly and specifically to Alvan Azinna Chibuzo Ikoku, the sole Founder, Owner, and President of The Ikoku Group and The Ikoku Holdings — any access, action, activity, communication, operation, or other use and any collaboration, collusion, coordination, planning, or other preparation you or any person engage in that may encourage, result in, or otherwise foster any intentional breach, diminishment, disruption, impediment, interference, or other violation pertaining to the Codes and Policies; and that may encourage, result in, or otherwise foster any intentional breach, diminishment, disruption, impediment, interference, or other violation pertaining to policy, legal and regulatory protections and rights of The Ikoku Holdings, The Ikoku Group, and the sole Founder, Owner, and President.
Reporting Any Unintentional Breach or Violation
reporting — directly and specifically to Alvan Azinna Chibuzo Ikoku, the sole Founder, Owner, and President of The Ikoku Group and The Ikoku Holdings — any access, action, activity, communication, operation, or other use and any collaboration, collusion, coordination, planning, or other preparation you or any person engage in that may encourage, result in, or otherwise foster any unintentional breach, diminishment, disruption, impediment, interference, or other violation pertaining to the Codes and Policies; and that may encourage, result in, or otherwise foster any unintentional breach, diminishment, disruption, impediment, interference, or other violation pertaining to policy, legal and regulatory protections and rights of The Ikoku Holdings, The Ikoku Group, and the sole Founder, Owner, and President.
Determination of Compliance
not diminishing or interfering with, in any way, the ability, opportunity, and sole discretion and rights of The Ikoku Holdings, The Ikoku Group, and the sole Founder, Owner, and President, Alvan Azinna Chibuzo Ikoku, to determine compliance with the Codes and Policies and to have their decision be final and binding and not subject to challenge or appeal.

And furthermore, by engaging in any activity at, by, for, in, on behalf of, with or otherwise pertaining to The Ikoku Holdings, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of The Ikoku Holdings, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the divisions, series, subsidiaries, or affiliates, as well as any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the Products or Services, you accept and agree to the terms, conditions, and requirements described above, and in the Codes and Policies, in their entirety without modification.

Your Duty to Organizational Integrity

With respect to your attendant duty to organizational integrity — and your legally binding agreement to not diminish, interfere, or violate, in any way, its principles, protections, requirements, or rights — you represent and warrant that you understand and shall adhere to the following:

Your Duty to Policy
To protect the organizational integrity of The Ikoku HoldingsĀ and The Ikoku Group — as well as the properties, rights, and protections of the company division and its official persons — The Ikoku HoldingsĀ 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 CompanyĀ and Division Integrity.
Your Acceptance of Policy
The Ikoku HoldingsĀ reminds you that the Policy on CompanyĀ and Division Integrity forms part of The Ikoku HoldingsĀ User Agreement and Code of Conduct. Thus, The Ikoku HoldingsĀ takes your continued engagement in any activity involving, referring, relating, or otherwise pertaining to The Ikoku Holdings as active indication of your legally binding acceptance of this Policy as well as the Codes and Policies.
Your Acceptance of Sole Ownership
Furthermore, you represent, warrant, and covenant that, given the above, your continuation in using or visiting, in any way, The Ikoku Holdings, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent ofĀ The Ikoku Holdings, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the divisions, series, subsidiaries, or affiliates, as well as any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the Products or Services, is an active indication of your legally binding acceptance of the sole administration, control, management, and ownership of The Ikoku HoldingsĀ by the Founder, Alvan Azinna Chibuzo Ikoku, as further described in the Policy on Company and Division Integrity.

And you further legally accept and agree that no application, interpretation, judgment, or other compliance, proceeding, or reading from, of, with, or otherwise relating to the Founding Ethics, the Codes and Policies, or any equivalent code, policy, or other document or material shall, in any way, entail any abrogation, diminishment, interference, or violation pertaining to any of the terms, conditions, principles, requirements, rights — including the attendant properties and protections — of company and organizational integrity.

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 Holdings User Agreement and Code of Conduct, you ensure that your abiding by and adhering to their conditions, policies, principles, requirements, and rights shall further remain in accordance with the Founding and Governing Code of Ethics.

Your Accordance with Mission

— You represent, warrant, and covenant that, given the above attestation about your consent to the Codes and Policies, and The Ikoku HoldingsĀ User Agreement and Code of Conduct, you ensure that your abiding by and adhering to their conditions, policies, principles, requirements, and rights shall further remain in accordance with the founding mission and purposes of The Ikoku Holdings and The Ikoku Group, without incompatibility, as described and delineated in the Codes and Policies and the Founder’s Operating Agreement of The Alvan Ikoku Group LLC (the ā€œFounder’s Operating Agreementā€ and the ā€œFounder’s Agreementā€).†

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 Holdings reserves to rightĀ to, at any time,Ā without notice or liability, change, temporarily suspend or discontinue any aspect of the Products and Services; the right also do the same for the availability of any feature, database or content of the Products and Services; 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, again without notice or liability.
Changes to Codes and Policies
that The Ikoku Holdings reserves the right to change and update the Codes and Policies, from time to time and at any time and without liability; that The Ikoku Holdings strongly encourages you to check back periodically to review the most current, updated version of the 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 Holdings, or a visitor or user of the Products or Services, it remains your responsibility to keep informed about such posted changes.
Reasonable Notice and Notification
that if The Ikoku Holdings 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 Holdings 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 Holdings; and that the continued open or active status of your account, your continued engagement in any activity, arrangement, communication, operation, services or equivalent with The Ikoku Holdings, or your continued use of the Sites or any other Products or Services, after our publishing anyĀ changes to the Codes and Policies, or sending a notice about such changes, will constitute your acceptance of such modifications.

And furthermore, by engaging in any activity at, by, for, in, on behalf of, with or otherwise pertaining to The Ikoku Holdings, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of The Ikoku Holdings, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the divisions, series, subsidiaries, or affiliates, as well as any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the Products or Services, you accept and agree to the terms, conditions, and requirements described above, and in the Codes and Policies, in their entirety without modification.

Your Questions and Feedback

Your questions regarding the Codes and Policies will help tremendously to make The Ikoku Holdings, including the divisions, series, subsidiaries, and affiliates, as well as the Products and Services, including theĀ Sites, 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@ikokuholdings.com.

How to Report

And the reporting of any violations of the Codes and Policies will also help to make The Ikoku Holdings, including the divisions, series, subsidiaries, and affiliates, as well as the Products and Services, including theĀ Sites, 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@ikokuholdings.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 Holdings and the Founder and Owner, Alvan Azinna Chibuzo Ikoku.

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

Notes

*
*as originally adopted, amendable and amended from time to time only by express written instrument signed and sealed of the Founder, Alvan Azinna Chibuzo Ikoku, with no other document capable of serving as or being taking as its equivalent (in other words, the ā€œsole Codes and Policiesā€ and the ā€œsole Policiesā€).
†
†as originally adopted, amendable and amended from time to time only by express written instrument signed and sealed of the Founder, Alvan Azinna Chibuzo Ikoku, with no other document capable of serving as or being taking as its equivalent (in other words, the ā€œsole Founder’s Operating Agreementā€ and the ā€œsoleĀ Founder’s Agreementā€).

Interface, December 2019 (Iwona Castiello D'Antonio)

Definitions

Provision

Provided below are definitions of terms to be used for purposes of the 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 Holdings, its series, subsidiaries, and affiliates, and the Products and Services.

Basic Definitions

What is ā€˜Respect for Persons’

The Ikoku Holdings holds the fullest and most humane understanding of respect for personsĀ to be essential to its formation, development, management, and operations. These Codes and Policies are to constitute a central means of defining, determining, obtaining, safeguarding and ultimately having persons enjoy such respect. Therefore, it should be understood that The Ikoku Holdings 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 Holdings — particularly those it helps create, develop, foster, and support — should emanate from, and be informed by, all of the aforementioned.

Who are ā€˜The Ikoku Holdings’

— In the Codes and Policies, and in all official documents, materials, and statements, including as presented on the Products and Services, the Sites, and elsewhere, ā€œThe Ikoku Holdingsā€ refers to The Alvan Ikoku Holdings, a private, nongovernmental, nonpolitical and nonreligious organization formed as a registered series and division of The Alvan Ikoku Group LLC, which is itself a series limited liability company in the State of Delaware — also officially doing business as The Alvan Azinna Chibuzo Ikoku Holdings and The Ikoku Holdings — as well as any and all of the divisions, series, subsidiaries, and affiliates of The Ikoku Holdings, any and all of the Products and Services of The Ikoku Holdings, and any and all of the areas, offices, parts, sections, and assets and properties of The Ikoku Holdings, including but not limited to the following:

Alvan Ikoku Holdings
— The Alvan Ikoku Holdings (ā€œThe Ikoku Holdingsā€ and ā€œThe Alvan Azinna Chibuzo Ikoku Holdingsā€) which constitutes a division and its series, subsidiaries, and affiliates wholly owned and managed by The Ikoku GroupĀ and the Founder, Alvan Azinna Chibuzo Ikoku.
The Ikoku Holdings Administration
also constituting part of The Ikoku Holdings is The Ikoku Holdings Administration as defined and described in the Codes and Policies and specifically the Policy on Organizational Integrity.
The Ikoku Holdings Offices and Properties
also constituting part of The Ikoku Holdings are the assets and properties of the aforementioned, and the offices and official addresses of The Ikoku Holdings, as determined by express written instrument signed and sealed of the Founder, Alvan Azinna Chibuzo Ikoku.
No Other Ikoku or Publiks Entity, Office or Service
the aboveĀ with the understanding that The Ikoku Holdings, the divisions, series, subsidiaries, and affiliates, as well as the Products and Services, shall not include (nor be construed or represented as including) anyĀ divisions, series, subsidiaries, or affiliates, any Products Services or Sites, any assets or properties, or any areas, offices, parts, and sections of other Ikoku or Publiks entities, including those that have Alvan Azinna Chibuzo Ikoku as Founder, President or Chair, such as but not limited to The Alvan Ikoku Group LLC (except The Ikoku Holdings division of The Ikoku Group), Publiks Inc, The Chinyere and Chinelo Ikoku Charitable Trusts, The Chinyere and Chinelo Ikoku Foundation and The Alvan Azinna Chibuzo Ikoku Foundation.
No Government or Public Entity, Office or Service
and the aboveĀ with the understanding that The Ikoku Holdings, the divisions, series, subsidiaries, and affiliates, as well as the Products and Services, 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 entities, nor their employees, officials, representatives, or other agents.

And furthermore, by engaging in any activity at, by, for, in, on behalf of, with or otherwise pertaining to The Ikoku Holdings, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of The Ikoku Holdings, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the divisions, series, subsidiaries, or affiliates, as well as any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the Products or Services, you accept and agree to the terms, conditions, and requirements described above, and in the Codes and Policies, in their entirety without modification.

What are ā€˜Products,’ ā€˜Services’ and ā€˜Sites’

— And in the Codes and Policies, as well as in all of the official documents, materials, and statements of The Ikoku Holdings, including as they present on the Products and Services of The Ikoku Holdings and elsewhere, ā€œProductsā€ and ā€œServicesā€ 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 Holdings and of the 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, sitesĀ and their equivalent of The Ikoku Holdings and of its series, subsidiaries, and affiliates.
Above as Applies to Sites
any and all of theĀ above as it applies to theĀ Sites of The Ikoku Holdings and to the Sites of its series, subsidiaries, and affiliates (collectively the ā€œSitesā€) areĀ included within the Products and Services.
No Government or Public Entity, Office or Service
and the aboveĀ with the understanding that the Products and Services, of The Ikoku Holdings and of its 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 entities, nor their employees, officials, representatives, or other agents.

And furthermore, by engaging in any activity at, by, for, in, on behalf of, with or otherwise pertaining to The Ikoku Holdings, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of The Ikoku Holdings, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the divisions, series, subsidiaries, or affiliates, as well as any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the Products or Services, you accept and agree to the terms, conditions, and requirements described above, and in the Codes and Policies, in their entirety without modification.

Who Is ā€˜The Founder’ and ā€˜The Owner’

— For the purposes of the Codes and Policies — as well as any other official communications, documents, statements and other materials of The Ikoku Group — ā€œthe Founderā€ and ā€œthe Ownerā€Ā are understood to entail agreement and adherence to the following:

Sole Founder of The Group and The Holdings
that references to ā€œthe Founderā€ mean and include only Alvan Azinna Chibuzo Ikoku as the soleĀ Founder of The Alvan Ikoku Group Holdings, The Alvan Ikoku Group LLC, the divisions, series, subsidiaries, and affiliates, and the Products and Services.
Sole Owner of The Group and The Holdings
that references to ā€œthe Ownerā€ mean and include only Alvan Azinna Chibuzo Ikoku as the sole Owner of The Alvan Ikoku Group Holdings, The Alvan Ikoku Group LLC, the divisions, series, subsidiaries, and affiliates, and the Products and Services.

And furthermore, by engaging in any activity at, by, for, in, on behalf of, with or otherwise pertaining to The Ikoku Holdings, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of The Ikoku Holdings, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the divisions, series, subsidiaries, or affiliates, as well as any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the Products or Services, you accept and agree to the terms, conditions, and requirements described above, and in the Codes and Policies, in their entirety without modification.

Who Are ā€˜We,’ ā€˜Our’ and ā€˜Us’

— For the purposes of the Codes and Policies, ā€œwe,ā€ ā€œourā€ and ā€œusā€ are understood to entail agreement and adherence to the following:

The Ikoku Holdings and its Entities
references to ā€œwe,ā€ ā€œourā€Ā  and ā€œusā€Ā mean and include The Alvan Ikoku Group Holdings as well as its series, subsidiaries, and affiliates, wholly owned and managed by Alvan Azinna Chibuzo Ikoku, the sole Founder and Owner.
Founder and Owner of The Group and The Holdings
references to ā€œwe,ā€ ā€œourā€Ā  and ā€œusā€ also mean and include Alvan Azinna Chibuzo Ikoku, as sole Founder and Owner of The IkokuĀ Holdings and The Ikoku Group, the divisions, series, subsidiaries, and affiliates, and the Products and Services.
Any Person Approved, Authorized and Employed by Founder
finally,Ā references to ā€œwe,ā€ ā€œourā€Ā  and ā€œusā€ also mean and include a natural person appointed or employed by Alvan Azinna Chibuzo Ikoku, sole Founder and Owner of The Ikoku Holdings, via express 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 Holdings in a manner in accordance with the Codes and Policies.

And furthermore, by engaging in any activity at, by, for, in, on behalf of, with or otherwise pertaining to The Ikoku Holdings, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of The Ikoku Holdings, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the divisions, series, subsidiaries, or affiliates, as well as any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the Products or Services, you accept and agree to the terms, conditions, and requirements described above, and in the Codes and Policies, in their entirety without modification.

Who Are ā€˜You,’ ā€˜User’ and ā€˜Visitor’

— For the purposes of the Codes and Policies, ā€œyouā€ is understood to entail agreement and adherence to the following:

Any Person Engaging in Activity, Especially User and Visitor
that, with the exception of those defined above as ā€œwe,ā€Ā ā€œourā€ and ā€œus,ā€ references to ā€œyouā€ and ā€œyourā€Ā mean and include any person engaging in any activity — especially as a visitor or user — in any way pertaining to The Ikoku Holdings, its series, subsidiaries, and affiliates, and the Products and Services.
Any Person Thus Entering into Agreement
that the Codes and Policies are a legally binding agreement between The Ikoku Group and ā€œyou,ā€ and they govern any and all of ā€œyourā€ activity in any way pertaining to The Ikoku Holdings, its series, subsidiaries, and affiliates, and the Products and Services.
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 Holdings, are independent individuals, though many are employees or other agents of entities, so the meaning of and references to ā€œyouā€ include both: (1) the ā€œuserā€ or ā€œvisitorā€ individually and (2) any entity or individual that is your employer or for whom you act as agent, unless otherwise stated in the 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 engaging in any activity at, by, for, in, on behalf of, with or otherwise pertaining to The Ikoku Holdings, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of The Ikoku Holdings, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the divisions, series, subsidiaries, or affiliates, as well as any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the Products or Services, you accept and agree to the terms, conditions, and requirements described above, and in the Codes and Policies, in their entirety without modification.

Further Definitions

ā€˜Activity’

References to ā€œactivityā€ and ā€œactivitiesā€ mean and include the following:

Common Usage
any and all common usage meanings of ā€œactivityā€ and ā€œactivities.ā€
Definitional and Reference-Based
any and all definitional meanings of ā€œactivityā€ and ā€œactivitiesā€ as provided in references such as long-established and highly reputable, standardized and verified and regularly updated dictionaries.
Legal and Legislative
any and all legal and legislative meanings of ā€œactivityā€ and ā€œactivitiesā€ as provided for in applicable law and regulation of government, judicial and other public state bodies and offices.
Ordinary and Public
any and all ordinary and public meanings of ā€œactivityā€ and ā€œactivities.ā€
Other Literal
any and all other literal meanings and understandings of ā€œactivityā€ and ā€œactivities.ā€
In Every Domain
as the meanings and understandings of ā€œactivityā€ and ā€œactivitiesā€ are applied, employed and otherwise used in every domain, including but not limited to industries, professions, sectors as well as sets and spheres of communal, individual, personal and public acts and actions.
In Any Manner
as ā€œactivityā€ and ā€œactivitiesā€ are conducted, engaged in and otherwise employed in any manner or way and via any means or method.
Not Including
though not including activities or functions of the brain or mind such as cognizing, perceiving, or thinking, and also not including thinking aloud by, to or with oneself.
Some Examples
with examples including but not limited to any act or action involved in or pertaining to accessing, administering, adopting, advising, advocating, affiliating, aiding, altering, analyzing, approving, assembling, assessing, associating, authorizing, benefiting, betting, broadcasting, browsing, building, changing, checking, coaching, coding, collaborating, collecting, communicating, complying, consenting, continuing, contracting, conversing, copying, corrupting, counseling, creating, deliberating, designing, developing, diminishing, directing, disseminating, disposing, distributing, documenting, duplicating, eavesdropping, echoing, educating, employing, enacting, engaging, engineering, evaluating, examining, exchanging, facilitating, filming, financing, following, forecasting, fostering, funding, gambling, gathering, graphing, hacking, harassing, helping, housing, identifying, imaging, impeding, impersonating, implementing, informing, interfering, interviewing, investigating, listening, locating, maintaining, making available, managing, mapping, meeting, mimicking, modifying, modulating, monitoring, moving, observing, occupying, operating, organizing, parodying, participating, partnering, paying, photographing, picturing, planning, policing, posting, practicing, predicting, preparing, printing, processing, producing, programming, protecting, providing, provisioning, publicizing, publishing, reporting, receiving, recording, recycling, regulating, remunerating, rendering, repeating, replying, representing, reproducing, researching, responding, reviewing, safeguarding, safekeeping, saving, searching, servicing, sharing, showing, sponsoring, spying, studying, supervising, supporting, surveilling, surveying, teaching, testing, tracing, tracking, trading, training, transferring, transiting, transmitting, transporting, traveling, trespassing, using, utilizing, verifying, viewing, videoing, violating, visiting, volunteering, voting, watching, wiretapping, working, or equivalent.
Some Permitted
with the attendant understanding that a number of the above-listed examples of ā€œactivityā€ and ā€œactivitiesā€ are permitted, though under certain conditions, by the Codes and Polices and applicable law and regulation.
Some Prohibited
with the attendant understanding that a number of the above-listed examples of ā€œactivityā€ and ā€œactivitiesā€ are strictly prohibited by the Codes and Polices and applicable law and regulation.
To Be Referred To
as such ā€œactivityā€ and ā€œactivitiesā€ are referred to in the Codes and Polices via legally binding and equivalent clauses, such as ā€œany activity by, for, in, on, via, with, within, on behalf of, etc.ā€ and ā€œany activity at, by, for, in, on behalf of, with or otherwise pertaining to.ā€

ā€˜Applicable Law, Regulation’

References to ā€œapplicable lawā€ and ā€œapplicable regulationā€ mean and include mandatory law and mandatory regulation of an official government and competent jurisdiction agreed to by The Ikoku Holdings and the Founder, Alvan Azinna Chibuzo Ikoku, whose effect broadly regulates the economy, sector, industry, or equivalent in which The Ikoku Holdings and the Founder conduct the specific activities in question or under review and, furthermore, whose application and interpretation (a) is specified to the relevant facts and specificities pertaining to the activities in question or under review and (b) has undergone full judicial review in official bodies, courts, and tribunals of competent jurisdiction agreed to by The Ikoku Holdings and the Founder. Any law, regulation, or equivalent (e.g. policy) whose effect, enforcement, or equivalent application or interpretation is found to primarily target The Ikoku Holdings, the Founder, or activities particular to either would neither meet nor qualify nor satisfy this definition, meaning, legal standard, or equivalent application or interpretation of references to Ā ā€œapplicable lawā€ or ā€œapplicable regulation.ā€

ā€˜Arguably’ and ā€˜Clearly’

References to ā€œclearly lawfulā€ and equivalents such as ā€œclearly constitutionalā€ and ā€œclearly ethicalā€ mean and include application or interpretation of law and regulation (a) that meet, qualify, and satisfy the definition, meaning, and legal standard delineated in the Codes and Policies for references to ā€œapplicable lawā€ or ā€œapplicable regulationā€ and (b) that has been and shall be, with certainty, deemed lawful, constitutional, ethical or equivalent via full government and judicial review in official bodies, courts, and tribunals of competent jurisdiction agreed to by The Ikoku Holdings and the Founder. References to ā€œarguably lawfulā€ and equivalents such as ā€œarguably constitutionalā€ and ā€œarguably ethicalā€ mean and include argumentation, conjecture, deliberation, reasoning, or equivalent that assert, hypothesize, posit, or equivalent as to the probability that a proposed application or interpretation of law, regulation, or equivalent (e.g. policy) would meet, qualify, and satisfy this definition, meaning, and legal standard for references to ā€œclearly lawfulā€ and equivalents such as ā€œclearly constitutionalā€ and ā€œclearly ethical,ā€ and therefore, would neither meet nor qualify nor satisfy this definition, meaning, legal standard, or equivalent application or interpretation of references to ā€œclearly lawfulā€ and equivalents such as ā€œclearly constitutionalā€ and ā€œclearly ethical.ā€

ā€˜Confidentiality’ and ā€˜Confidential’

References to ā€œconfidentialityā€ and ā€œconfidentialā€ mean and include that which is entailed in definitions, meanings, principles, processes, protections, requirements, rights, and equivalent provided for in applicable law and regulation as well as in the Codes and Policies. Where biospecimens, data, information, or equivalent are concerned, references to ā€œbiospecimens,ā€ ā€œconfidential data,ā€ ā€œconfidential information,ā€ or equivalent 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 Holdings (including the Products and Services), or in the course of its activitiesĀ or operations, that are defined, described, discussed, identified or otherwise processed as ā€œconfidential,ā€ or, in context, can meaningfully or reasonably be expected to be treated as confidential, as well asĀ such data, documentation, and information thatĀ is not generally known or made available outside The Ikoku Holdings.
No Observation or Recording Meaningfully or Reasonably Expected
any and all ofĀ 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 ofĀ 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 ofĀ the above suchĀ 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,Ā 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 Holdings.
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 Holdings (including the Products and Services), or in the course of its activitiesĀ or operations, that are defined, described, discussed or otherwise identified or processed asĀ ā€œpersonal,ā€ ā€œprivateā€ orĀ ā€œsensitiveā€ — and the protection of such data, documentation, and information (including prohibitions of processing) is an essential way in which The Ikoku Holdings complies with and fulfills the rights of persons to ā€œconfidentialityā€ and to ā€œconfidential conversation.ā€
Biospecimens, Especially for Care and Research
andĀ 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 Holdings complies with and fulfills the rights of persons to ā€œconfidentialityā€ and to ā€œconfidential conversation.ā€

ā€˜Consent’

References to ā€œconsentā€ and ā€œconsentedā€ mean and include only anĀ 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,Ā 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 Holdings.
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.

ā€œConsentā€ should not be confused with ā€œagreementā€ or ā€œcontractā€ 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 theĀ Policy on Data and InformationĀ and second, in theĀ Policy on Human Subjects Research and Investigation — and The Ikoku Holdings advises you to regularly visit those sections forĀ 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.

ā€˜Data Aggregation’

References to ā€œaggregationā€ and ā€œaggregatedā€ 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 greaterĀ opportunities for analysis, compiling and merging with multiple other similarly aggregated or prepared datasets.

ā€˜Data Review Board’

References to ā€œdata review boardā€ (also the ā€œDRBā€) in the context of processing data and information mean and include aĀ 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 theĀ Policy on Data and Information.

References to ā€œDRB approvalā€ 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 Holdings 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.

ā€˜De-identification’

References to ā€œde-identificationā€ — 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 ā€œde-identifyingā€ or ā€œde-identifiedā€ are andĀ remain personal biospecimens, data, and information (since theyĀ 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 the Codes and Policies and in either the Policy on Data and InformationĀ 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.

ā€˜Government, Judicial Review’

References to ā€œgovernment reviewā€ and ā€œjudicial reviewā€ and equivalent mean and include adherence to all of the following:

By Official Body, Court, Tribunal
full review of the matter in question by official bodies, courts, and tribunals of an official government and competent jurisdiction agreed to by The Ikoku Holdings and the Founder, Alvan Azinna Chibuzo Ikoku.
Applicable Law and Regulation
full review, as above, via application and equivalent interpretation of applicable law and regulation that meet, qualify, and satisfy the definition, meaning, and legal standard delineated in the Codes and Policies for references to ā€œapplicable lawā€ or ā€œapplicable regulation.ā€
Clearly Lawful
full review, as above, via application and equivalent interpretation of applicable law and regulation that meet, qualify, and satisfy the definition, meaning, and legal standard delineated in the Codes and Policies for references to ā€œclearly lawfulā€ and equivalents such as ā€œclearly constitutionalā€ and ā€œclearly ethical.ā€
Full, Appeals Process and Protections
full review, as above, including appeals process or equivalent, where official proceedings are conducted in such a clearly lawful, constitutional and ethical manner so that all due process rights and protections, other judicial and justice rights and protections, and other rights and protections, such as those pertaining to confidentiality and privacy, are fully enjoyed by The Ikoku Holdings and the Founder, Alvan Azinna Chibuzo Ikoku.
Prior and Informing Notice
full review, as above, where onset of official proceedings are preceded by legally sufficient written notice properly and successfully served to The Ikoku Holdings and the Founder, Alvan Azinna Chibuzo Ikoku, where, furthermore, both are fully informed of the specifics of the matter in question and issue claimed or to be determined and of the specifics of the official proceeding, including confirmation of such proceeding via written instrument signed and sealed of the official body, court, or tribunal of competent and agreed jurisdiction.
Sufficient Opportunity for Response and Defense
full review, as above, where prior to the onset of any body, court or tribunal proceeding and any attendant determination, finding, holding, judgment, or equivalent The Ikoku Holdings and the Founder, Alvan Azinna Chibuzo Ikoku, are given sufficient opportunity to prepare and provide response, remedy, and defense before and with respect to the body, court or tribunal proceeding and specifics of the matter in question and issue claimed or to be determined.
Fully Informing Communication
full review, as above, where The Ikoku Holdings and the Founder, Alvan Azinna Chibuzo Ikoku, are immediately and fully informed of any subsequent decision, determination, finding, holding, judgment, or equivalent, and any attendant damages, interests, or equivalent remunerative or substantive award or relief, by written instrument signed and sealed of the body, court or tribunal of competent and agreed jurisdiction.
Determination Limited to Jurisdiction
full review, as above, where any decision, determination, finding, holding, judgment, or equivalent, and any attendant damages, interests, or equivalent remunerative or substantive award or relief is limited in effect to the competent and agreed jurisdiction of the body, court, or tribunal, without affecting, in any way, the specified matter in question or under review in any other jurisdiction.

ā€˜Health Care Operations’

References to ā€œhealth care operationsā€ 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 engaging in any activity at, by, for, in, on behalf of, with or otherwise pertaining to The Ikoku Holdings, any part or section of The Ikoku Holdings, any part or section of the divisions, series, subsidiaries, or affiliates, as well as any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the Products or Services, you accept and agree to the terms, conditions, and requirements described above, and in the Codes and Policies, in their entirety without modification.

ā€˜Human Subject’

References to ā€œhuman subject,ā€ ā€œhuman subject under study,ā€ and ā€œhuman subject concernedā€Ā in the context of research or investigation mean and includeĀ 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 otherwiseĀ 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.

ā€˜Identifiable Biospecimen’

References to ā€œidentifiable biospecimenā€ and ā€œpersonal biospecimenā€ in the context of research or investigation mean and includeĀ a biospecimen for which the identity of a human subject is or may be ascertained or associated with the biospecimen.

References to ā€œidentifiable biospecimenā€ and ā€œpersonal biospecimenā€ in the context of research or investigation alsomean 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.

ā€˜Identifiable Person’ and ā€˜Identifier’

References to ā€œidentifiable personā€ 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 ā€œidentifierā€ or a combination of ā€œidentifying information,ā€ 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.

The Ikoku Holdings also refers to such an identifiable person as aĀ ā€œnatural or legal person who is a subject of, or identifiable by, the data and informationā€ as well as a ā€œnatural or legal person concernedā€ in the context of activities, operations, policies or statements pertaining to personal data and information.

Such an identifiable person is also known as a ā€œdata subjectā€ in the European Union’s GDPR lawĀ and is also included in the definition and use of ā€œconsumerā€ in theĀ California Consumer Privacy Act (CCPA).

ā€˜Intellectual Property, External’

References to ā€œexternal intellectual propertyā€ mean and include but are not limited to content, media, materials and other copyrightable, patentable and service- or trademarkable real or intellectual property, and any other intellectual property created as follows:

External to The Ikoku Holdings
external to, outside, and without any access, activity, application, borrowing, collaboration, communication, copying, co-working, dissemination, distribution, duplication, engagement, franchising, incorporation, loaning, licensing, mimicking, monitoring, operation, participation, pirating, posting, processing, sharing, showing, stealing, taking, viewing, visiting, or other use by, from, in, of, on behalf, or otherwise relating to The Ikoku Holdings.
External to Divisions, Series, Subsidiaries
external to, outside, and without any access, activity, application, borrowing, collaboration, communication, copying, co-working, dissemination, distribution, duplication, engagement, franchising, incorporation, loaning, licensing, mimicking, monitoring, operation, participation, pirating, posting, processing, sharing, showing, stealing, taking, viewing, visiting, or other use by, from, in, of, on behalf, or otherwise relating to any of the divisions, series, subsidiaries, or affiliates of The Ikoku Holdings.
External to Areas, Parts, Sections, Properties
external to, outside, and without any access, activity, application, borrowing, collaboration, communication, copying, co-working, dissemination, distribution, duplication, engagement, franchising, incorporation, loaning, licensing, mimicking, monitoring, operation, participation, pirating, posting, processing, sharing, showing, stealing, taking, viewing, visiting, or other use by, from, in, of, on behalf, or otherwise relating to any of the activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of The Ikoku Holdings.
External to Products, Services, Sites
external to, outside, and without any access, activity, application, borrowing, collaboration, communication, copying, co-working, dissemination, distribution, duplication, engagement, franchising, incorporation, loaning, licensing, mimicking, monitoring, operation, participation, pirating, posting, processing, sharing, showing, stealing, taking, viewing, visiting, or other use by, from, in, of, on behalf, or otherwise relating to any of the Products or Services, including the Sites of The Ikoku Holdings.
External to Administration
external to, outside, and without any access, activity, application, borrowing, collaboration, communication, copying, co-working, dissemination, distribution, duplication, engagement, franchising, incorporation, loaning, licensing, mimicking, monitoring, operation, participation, pirating, posting, processing, sharing, showing, stealing, taking, viewing, visiting, or other use by, from, in, of, on behalf, or otherwise relating to, in any way, The Ikoku Holdings Administration as defined and described in the Codes and Policies.
External to Intellectual Property
external to, outside, and without any access, activity, application, borrowing, collaboration, communication, copying, co-working, dissemination, distribution, duplication, engagement, franchising, incorporation, loaning, licensing, mimicking, monitoring, operation, participation, pirating, posting, processing, sharing, showing, stealing, taking, viewing, visiting, or other use by, from, in, of, on behalf, or otherwise relating to any of the copyright, logo, name, patent, slogan, symbol, service- or trademark, or any other intellectual property of The Ikoku Holdings.
External to Real and Used Property
external to, outside, and without any access, activity, application, borrowing, collaboration, communication, copying, co-working, dissemination, distribution, duplication, engagement, franchising, incorporation, loaning, licensing, mimicking, monitoring, operation, participation, pirating, posting, processing, sharing, showing, stealing, taking, viewing, visiting, or other use by, from, in, of, on behalf, or otherwise relating to any of the real, rental, processed, purchased, loaned, licensed, leased, fee-charged, borrowed or otherwise owned, employed, financed or used property of The Ikoku Holdings.
External to Agreements, Contracts, Arrangements
external to, outside, and without any access, activity, application, borrowing, collaboration, communication, copying, co-working, dissemination, distribution, duplication, engagement, franchising, incorporation, loaning, licensing, mimicking, monitoring, operation, participation, pirating, posting, processing, sharing, showing, stealing, taking, viewing, visiting, or other use by, from, in, of, on behalf, or otherwise relating to any agreements, contracts, contractorships, partnerships, and other equivalent arrangements of The Ikoku Holdings.
External to Assets, Ideas, Designs, Work
external to, outside, and without any access, activity, application, borrowing, collaboration, communication, copying, co-working, dissemination, distribution, duplication, engagement, franchising, incorporation, loaning, licensing, mimicking, monitoring, operation, participation, pirating, posting, processing, sharing, showing, stealing, taking, viewing, visiting, or other use by, from, in, of, on behalf, or otherwise relating to any applications, assets, concepts, demonstrations, designs, diagrams, drawings and sketches, ideas, maps and blueprints, motifs, notes, patterns, schemes, solutions, themes, intangible as well as real property, labor, planning, preparation, projects, proposals, time, or any other documents, materials, resources, or work of The Ikoku Holdings.
External to Official Persons
all of the above by, from, in, of, on behalf, or otherwise relating to official persons, leadership, managers, Ā directors, trustees, executives, employees, partners, third-parties, volunteers, and other agents of The Ikoku Holdings.
External to Founder
all of the above by, from, in, of, on behalf, or otherwise relating to the sole Founder, Owner, and President, Alvan Azinna Chibuzo Ikoku.

And furthermore, by engaging in any activity at, by, for, in, on behalf of, with or otherwise pertaining to The Ikoku Holdings, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of The Ikoku Holdings, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the divisions, series, subsidiaries, or affiliates, as well as any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the Products or Services, you accept and agree to the terms, conditions, and requirements described above, and in the Codes and Policies, in their entirety without modification.

ā€˜Interaction, Research’

References to ā€œinteractionā€ in the context of research or investigation mean and include communication or interpersonal contact between a researcher or investigator and a human subject, eitherĀ for research or investigation purposes or as part of activity determined to constitute research or investigation.

Also, references to ā€œbenign behavioral interactionsā€ or ā€œbenign interactionsā€ in the context of research or investigation mean and include interactions that are, after rigorous assessment and by written consent and written instrument,Ā confirmed by the human subject, internal 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.

ā€˜Internal Review Board’

References to ā€œinternal review boardā€ (also the ā€œIRBā€) in the context of research or investigation mean and include aĀ 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 theĀ Policy on Human Subjects Research and Investigation.

References to ā€œIRB approvalā€ 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 Holdings, 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.

ā€˜Intervention, Research’

References to ā€œinterventionā€ in the context of research or investigation mean and includeĀ both:

— (a) procedures by which biospecimens, data, or information are accessed, gathered or otherwise processed;Ā 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 ā€œbenign behavioral interventionsā€ or ā€œbenign interventionsā€ in the context of research or investigation mean and include interventions that are, after rigorous assessment and by written consent and written instrument,Ā confirmed by the human subject, internal 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.

ā€˜Irreversible Anonymization’

References to ā€œirreversible anonymizationā€ (or ā€œanonymizationā€ for The Ikoku Holdings) — 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 ā€œanonymizedā€ biospecimens, data, and information, whose access, collection, or other processing may not require the stringent protections and regulations delineated and described in the Codes and Policies and in either the Policy on Data and InformationĀ or the Policy on Human Subjects Research and Investigation.

It must be noted that there are ongoing concerns that such ā€œanonymizedā€ biospecimens, data, and information may possibly and technically become comparatively or increasinglyĀ ā€œun-anonymizedā€ 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).Ā For this reason, natural or legal persons concerned still have Policy-specified rights to ensure and verify that suchĀ irreversible anonymization has been and remains properly and truly conducted.

ā€˜Minimal Risk’

References to ā€œminimal riskā€ 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.

ā€˜Non-Identification’

References to ā€œnon-identificationā€ — 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 ā€œnon-identifyingā€ may still be personal biospecimens, data, and information (in cases where theyĀ 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 stillĀ require and remain under the stringent protections and regulations delineated and described in the Codes and Policies in either the Policy on Data and InformationĀ 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, The Ikoku Holdings makes clear distinctions between de-identification, pseudo-anonymization or pseudonymization, and irreversibleĀ anonymization.

ā€˜Notice,’ ā€˜Giving’ and ā€˜Delivery’

Reference to ā€œnoticeā€ mean and include only written communication or notification properly delivered to its recipient; and ā€œdeliveryā€ and ā€œgiving noticeā€ 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 formĀ 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 Holdings.

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 Holdings;

— (iii) if electronically transmitted, as provided in the 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 Holdings.

ā€˜Official Persons’

References to ā€œofficial personā€ and ā€œofficial personsā€ of an entity mean and include — but are not limited to — natural or legal persons appointed, contracted, elected, employed, entrusted or otherwise engaged by the entity as administrators, agents, beneficiaries, conservators, contractors, directors, employees, exchangers, executives, evaluators, freelancers, guardians, interest-holders, investigators, leaders, managers, officers, partners, personnel, representatives, sellers, shareholders, stakeholders, stockholders, traders, trustees, volunteers, workers, or in any administration, affiliation, association, benefiting, business, conservatorship, contract, decision-making, directorship, employment, engagement, exchange, evaluation, finance, franchise, funding, guardianship, governance, interest-holding, investigation,Ā leadership, license, management, membership, operations, oversight, partnership, permission, representation, sales, shareholding, sponsorship, stakeholding, stockholding, supervision, regulation, third-party, trade, trusteeship or other agent or equivalent arrangement or capacity, or their equivalent.

ā€˜Personal Data’ and ā€˜Personal Information’

References to ā€œpersonal dataā€ and ā€œpersonal informationā€ mean and include data and information for which the identity of a specificĀ natural or legal person is or may be ascertained or associated with the data and information.

References to ā€œpersonal dataā€ and ā€œpersonal informationā€ 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.

ā€˜Privacy’ and ā€˜Private’

References to ā€œprivacyā€ and ā€œprivateā€ mean and include that which is entailed in definitions, meanings, principles, processes, protections, requirements, rights, and equivalent provided for in applicable law and regulation as well as in the Codes and Policies. Where biospecimens, data, information, or equivalent are concerned, references to ā€œbiospecimens,ā€ ā€œprivate data,ā€ ā€œprivate information,ā€ or equivalent 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 Holdings (including the Products and Services), or in the course of its activitiesĀ or operations, that are defined, described, discussed, identified or otherwise processed as ā€œprivate,ā€ or, in context, can meaningfully or reasonably be expected to be treated as private, as well asĀ such data, documentation, and information thatĀ is not generally known or made available outside The Ikoku Holdings.
No Observation or Recording Meaningfully or Reasonably Expected
any and all ofĀ 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 ofĀ 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 ofĀ the above suchĀ 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,Ā 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 Holdings.
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 Holdings (including the Products and Services), or in the course of its activitiesĀ or operations, that are defined, described, discussed or otherwise identified or processed as ā€œconfidential,ā€ ā€œpersonal,ā€ orĀ ā€œsensitiveā€ — and the protection of such data, documentation, and information (including prohibitions of processing) is an essential way in which The Ikoku Holdings complies with and fulfills the rights of persons to ā€œprivacy,ā€ to ā€œprivate conversationā€ and toĀ ā€œprivate thought.ā€
Biospecimens, Especially for Care and Research
andĀ 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 Holdings complies with and fulfills the rights of persons to ā€œprivacy,ā€ to ā€œprivate conversationā€ and toĀ ā€œprivate thought.ā€

ā€˜Processing, of Biospecimens, Data, Information’

References to ā€œprocessing,ā€ ā€œprocessā€ or ā€œprocessedā€ — 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,Ā adaptation or alteration, alignment or combination, archiving or filing, bartering or trading, borrowing or renting or leasing, buying or purchasing,Ā circulation orĀ dissemination or otherwise making available, collection, consultation,Ā deletion or erasure or destruction,Ā detecting, disclosure,Ā documenting, developing, gathering or compiling, generating or preparing,Ā evaluating or assessing,Ā examining or analyzing, filming or streaming, giving or donating,Ā organization, profiling or predicting,Ā publication, publishing or otherwise making public, receiving, recording, reporting, restriction,Ā retrieval, saving or storage,Ā searching or searching for, selling or trading in,Ā structuring, tracking, transferring,Ā transmission, use or otherwise putting into activity or operation.

ā€˜Profiling, with Biospecimens, Data, Information’

References to ā€œprofilingā€ — in the context of processing biospecimens,Ā 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,Ā economic or financial situation, health, fitness or wellness, hobbies orĀ 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 characteristicsĀ 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 andĀ 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 underĀ ā€œautomated individual decision-makingā€ and ā€œautomated decision-making.ā€

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 Holdings 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 ā€œdata processing risks assessmentā€ or a ā€œresearch and processing risks assessmentā€ then addressing any concerns found; and finally

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

ā€˜Pseudo-anonymization’ or ā€˜Pseudonymization’

References to ā€œpseudo-anonymizationā€ and ā€œpseudonymizationā€Ā ā€” 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 specificĀ natural or legal personĀ without the use of additional information — provided that such additional information is kept separately and is subject to ā€œtechnical and organizational measuresā€ 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. TheĀ ā€œtechnical and organizational measuresā€ (required, for example, by the European Union GDPR law) serve as a means for us to increase the confidentiality, privacy and security around ā€œre-identifyingĀ informationā€ 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 pseudonymizationĀ are andĀ remain personal biospecimens, data, and information (since theyĀ 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, ā€œpseudo-anonymizedā€ or ā€œpseudonymizedā€Ā 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 the Codes and Policies and in either the Policy on Data and InformationĀ 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 suchĀ pseudonymization has been and remains properly and truly conducted.

ā€˜Research and Investigation’

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

ā€˜Restriction of Processing’

References to ā€œrestriction of processingā€ 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,Ā with the aim of limiting their processing in the future.

ā€˜Risks of Processing’

References to ā€œrisksā€ and ā€œrisks of processingā€ 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 alsoĀ 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 wereĀ accidental, malicious,Ā unauthorized or unlawful access,Ā 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 ā€œdata processing risks assessmentā€ or ā€œresearch and processing risks assessmentā€Ā then effectively addressing any concerns found and reported, including eliminating any identified factors leading to risks andĀ further anonymizing or minimizingĀ the personal biospecimens, data, and information.

ā€˜Seal’ and ā€˜Sealed’

The Founder, President and Chair shall provide for a company seal, which may have the name of The Ikoku Group or the pertinent division, 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 ā€œseal,ā€ ā€œsealedā€ 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 Holdings 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 ā€œfor identification purposes only,ā€ unless such use has been approved by the Founder, President and Chair via express and written instrument signed and sealed.

ā€˜Sensitivity’ and ā€˜Sensitive’

References to ā€œsensitivityā€ and ā€œsensitiveā€ mean and include that which is entailed in definitions, meanings, principles, processes, protections, requirements, rights, and equivalent provided for in applicable law and regulation as well as in the Codes and Policies. Where biospecimens, data, information, or equivalent are concerned, references to ā€œbiospecimens,ā€ ā€œsensitive data,ā€ ā€œsensitive information,ā€ or equivalent mean and include the following:

As With Confidential and Private
all that is entailed in definitions, meanings, principles, processes, protections, requirements, rights, and equivalent for ā€œconfidentiality,ā€ ā€œconfidential data,ā€ and ā€œconfidential informationā€ as well as for ā€œprivacy,ā€ ā€œprivate data,ā€ and ā€œprivate information,ā€ as defined and delineated in the Codes and Policies.
As for Determination of Sensitivity
all that is entailed in assessments, procedures, protocols, or equivalent processes in determining or deciding whether and what to treat as sensitive personal biospecimens, data and information, such as delineated here further below.
Determination of Sensitivity via Risks to Rights of Persons
that ā€œsensitive data and informationā€ include personal data and information where a breach in protection or security produces high risk to the civil liberties and basic, civil and fundamental rights of the natural or legal person concerned.
Determination of Sensitivity via Risks for Identity Theft
that ā€œsensitive data and informationā€ 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 ā€œsensitive data and informationā€ 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 Holdings also confers a determination of sensitivity for personal data and information demarcated, described or discussed as ā€œconfidential,ā€ ā€œprivateā€ orĀ ā€œsensitiveā€ — as defined under Confidentiality and Privacy in the Codes and Policies.
Examples of Sensitive Data and Information
therefore thatĀ ā€œsensitive data and informationā€ include, but are not limited to,Ā personal data and information — concerning, containing, disclosing, revealing or otherwise relating to birthdate; biometric orĀ genetic data or information; disability; economic and financial condition or information;Ā geolocation or physical movements; government-issued identification and credentials;Ā health, fitness, medical or wellness condition, data or information; ethnic, national or racial origin;Ā gender or gender identity; login, authentication or security credentials and passwords;Ā marital or reproductive choices or status; political affiliations or opinions; philosophical, religious or spiritual beliefs;Ā sex life or sexual orientation; trade or professionalĀ union membership;Ā or any other real or perceived characteristic, class, or status protected by applicable local, state, federal, national or international law — that are attributable toĀ any actual or potential Founder, Trustee, Director, Manager, Officer, staff, employee or volunteer, donor,Ā 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 Holdings.
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 Holdings (including the Products and Services), or in the course of its activitiesĀ or operations, that are defined, described, discussed or otherwise identified or processed as ā€œsensitiveā€ — and the protection of such data, documentation, and information (including prohibitions on their processing) is an essential way in which The Ikoku Holdings complies with and fulfills the rights of persons to ā€œconfidentiality,ā€ to ā€œprivacy,ā€ to ā€œconfidential conversation,ā€ to ā€œprivate conversation,ā€ and toĀ ā€œprivate thought.ā€
Biospecimens, Especially for Care and Research
andĀ 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 Holdings complies with and fulfills the rights of persons to ā€œconfidentiality,ā€ to ā€œprivacy,ā€ to ā€œconfidential conversation,ā€ to ā€œprivate conversation,ā€ and toĀ ā€œprivate thought.ā€

ā€˜Signature’ and ā€˜Signed’

In a number of state, federal and international statutes pertaining to activities, operations and jurisdictions of importance to The Ikoku Holdings, the definition of signature does not include a stamped, computer generated, digital or electronic signature. Thus, references to ā€œsigned,ā€ ā€œsignature,ā€ 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.

ā€˜Third Party’ and ā€˜Third Country’

The Ikoku Holdings 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.Ā Thus, references to ā€œthird partyā€ 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 inĀ an official or recognized capacity.

Meanwhile, references to ā€œthird countryā€ 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 inĀ an official or recognized capacity.

All activities, relationships and equivalent arrangements between The Ikoku Holdings 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 the Codes and Policies.

ā€˜Trial,’ ā€˜Clinical’ or ā€˜Research’

References to ā€œclinical trial,ā€ ā€œresearch trial,ā€ or ā€œtrialā€ in the context of researchĀ 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.

ā€˜User Content, Data and Feedback’

References to ā€œuser content, data or information, and feedbackā€ mean and include the following:

User Content
content, media and other material created by a user or other person outside of The Ikoku Holdings and the Products and Services, and without use of names, marks or other properties or resources of The Ikoku Holdings or the Founder and Owner, Alvan Azinna Chibuzo Ikoku.
User Data and Information
data and information created, generated or further processed during processes of The Ikoku Holdings integral or incidental to aĀ user’s or other person’s activity, communication, visit or other use pertaining to The Ikoku Holdings and the Products and Services.
User Feedback
content, media and other material generated or provided by a user or other person in concert with,Ā withinĀ or in response to The Ikoku Holdings and the Products and Services, and while making authorized use of or reference to names, marks or other properties or resources of The Ikoku Holdings or the Founder and Owner, Alvan Azinna Chibuzo Ikoku.
User Feedback, Examples and Scope
User FeedbackĀ 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 Holdings or itsĀ Products and Services; about any aspect of The Ikoku Holdings or itsĀ Products and Services; to or through The Ikoku Holdings or the Products and Services; to or through persons working with The Ikoku Holdings, withĀ the Products and ServicesĀ 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,Ā ā€œuserā€ can at times be followed, preceded or replaced with ā€œcontributor,ā€ ā€œparticipantā€ or ā€œvisitor.ā€
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.

ā€˜Writing,’ ā€˜Written,’ and ā€˜Electronic Communication’

References to ā€œwritingā€ and ā€œwrittenā€ 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 ā€œwriter,ā€ to a consenting natural or legal person being the ā€œrecipient,ā€ capable of comprehension by ordinary standardized visual, tactile or auditory means of reading and interpretation, and shall include ā€œelectronic mail (email)ā€ and very similarly written ā€œelectronic communication,ā€ provided that the conditions set forth below are met:

(1) Clarity, Legibility and No Inference — As with allĀ actionable, applicable, approvable,Ā legitimate and official communication from, for, of, in, within or pertaining to The Ikoku Holdings, ā€œelectronic communicationā€ must be expressly written, clearly legible and require no inference (orĀ ā€œguessworkā€) 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 ofĀ Means of Communication — As with all actionable, applicable, approvable,Ā legitimate and official communication from, for, of, in, within or pertaining to The Ikoku Holdings, acceptable forms of electronic communication must adhere to the above and furthermore be approved for conducting specified purposes of The Ikoku Holdings via unanimous agreement and consent of the following:

Founder and Leadership
(a)Ā Founder, President and Chair of The Ikoku Group.
Administration, Executive and Management
(b)Ā any pertinent Managers, Directors and Officers using such communication to carry out their activity pertaining to The Ikoku Holdings.
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 Holdings.
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 Holdings.
Customers, Users and Visitors
(d) any pertinent customers, visitors, users, and communities using such communication to carry out their activity pertaining to The Ikoku Holdings.

(3) Provided and Unrevoked Consent — As with all actionable, applicable, approvable,Ā legitimate and official communication from, for, of, in, within or pertaining to The Ikoku Holdings, 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 activityĀ pertaining to The Ikoku Holdings.

(4) Clear Conditions of Consent — As with all actionable, applicable, approvable,Ā legitimate and official communication from, for, of, in, within or pertaining to The Ikoku Holdings, 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 Holdings.
Procedures to Withdraw Consent
(c) the procedures the recipient must use to withdraw consent.

(5) Facsimile, Email, Message Boards andĀ Networks:Ā 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 Holdings.
When Using Clearly Designated Electronic Board or Network
(b)Ā posting on an electronic message board or network which The Ikoku Holdings 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 means of communication, notice, or notification by, from or on behalf of The Ikoku Holdings can, may or shall in itself entail any violation of confidentiality or privacy or any significant risk to the basic, civil and fundamental rights of a natural person — nor shall the performance of any official agreements, contracts, duties or responsibilities of The Ikoku Holdings require such means of communication, notice, or notification. Where the conditions above and in the Codes and Policies have not been met The Ikoku Holdings considers such communication, notice, or notification to have not been authorized or 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 the 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.

Login, October 2021 (Towfiqu Barbhuiya)
Team, September 2017 (Matt Artz)
Team, September 2017 (Matt Artz)
Measure, August 2017 (Matt Artz)
Measure, August 2017 (Matt Artz)
Redundancy, August 2017 (Matt Artz)
Redundancy, August 2017 (Matt Artz)

Policies

Provision

As stated earlier, the governance of The Alvan Ikoku Holdings is, in important part, conducted via the following codes and policies:

Ikoku User Agreement

The Ikoku Holdings User Agreement and Code of Conduct, which

Collectively Governing
consist of several Codes and Policies that collectively govern all activities, affairs, and arrangements by, for, in, of, on behalf of, referring to and otherwise pertaining to The Alvan Ikoku Holdings, including its divisions, series, subsidiaries, and affiliates, and its Products and Services
Collectively Including
collectively include — but are not limited to — the Founding Statement, the Governance Statement, the Founding and Governing Code of Ethics, the Policy on Privacy and Confidentiality, the Terms and Conditions of Use and Service, and the Acceptable Uses Policy along with all Associated Codes and Policies
Available Below
are made available further below

Founding Statement

Statement on Founding of The Ikoku Holdings (HTML)

Governance Statement

Statement on Governance of The Ikoku Holdings (HTML)

Founding Code of Ethics

Founding Code of Ethics (HTML)

Privacy and Confidentiality

Policy on Privacy and Confidentiality (HTML)

Terms and Conditions

Terms and Conditions of Use and Service (HTML)

The Acceptable Uses Policy

Acceptable Use Policy (HTML)

Associated Policies

Accessibility and Disability

Accessibility and Disability (HTML)

Conflicts of Interest

Conflicts of Interest (HTML)

Data and Information

Data and Information (HTML)

Discrimination and Harassment

Discrimination and Harassment (HTML)

Diversity and Inclusion

Diversity and Inclusion (HTML)

Fairness and Justice

Fairness and Justice (HTML)

Financial Transactions

Financial Transactions (HTML)

Forced Labor, Trafficking, Slavery

Forced Labor, Trafficking, Slavery (HTML)

Human Subjects Research and Investigation

Human Subjects Research and InvestigationĀ (HTML)

Intellectual Property

Policy on Intellectual Property (HTML)

Members and Voting

Members and Voting (HTML)

Organizational Independence

Organizational IndependenceĀ (HTML)

Organizational Integrity

Organizational Integrity (HTML)

Private Nature and Public Good

Private Nature and Public Good (HTML)

Reasonable Transparency

Reasonable Transparency (HTML)

Safety and Security

Safety and Security (HTML)

Societal Impact and Sustainability

Societal Impact and Sustainability (HTML)

Updates and Keeping Informed

Once again, by continuing to engage in activity within, on behalf of, and in reference to The Ikoku Holdings, and by continuing to visit and use the Products and Services, you indicate that you understand that The Ikoku Holdings reserves the right to update the 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 the 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 Holdings, or a visitor or user of the Products or Services, it remains your responsibility to keep informed about such posted changes.

Concluding

And as concluding aviso and proviso, you are informed as well as reminded that by conducting any activity at, by, for, in, on behalf of, with or otherwise pertaining to The Ikoku Holdings, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of The Ikoku Holdings, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the divisions, series, subsidiaries, or affiliates of The Ikoku Holdings, as well as any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the Products or Services of The Ikoku Holdings, you accept and agree to the conditions, principles, protections, requirements, standards, statements, and terms described above and in the Codes and Policies, regarding the Founding and Governance of The Ikoku Holdings, in their entirety without modification, including as updated from time to time by the Founder.

Domain, August 2017 (Matt Artz)
Tool, August 2017 (Matt Artz)
Tool, August 2017 (Matt Artz)
Silo, October 2018 (Thomas Stephan)
Silo, October 2018 (Thomas Stephan)
System, February 2020 (Elizabeth Kay)
System, February 2020 (Elizabeth Kay)

Ethics at the Company, in Company

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

I.

A Company of and about Ethics

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

II.

Built with Integrity and Respect in Mind

A company and division who take as their basis the most robust conceptions of humanity, integrity and respect as well as independence and fundamental freedoms, liberties and rights — up to and beyond what the law protects and provides for — as they carry out and embody their founding and core mission and purposes.

III.

Areas of Focus Chosen for Mission and Work

And a company and division whose areas of focus have been expressly chosen to ensure attention to issues of enduring concern to the Founder — and so committed to providing products, services, sites and spaces that remain safe, secure and respectful places to do work, to teach and learn, to form, inform and, where needed, transform local and global communities.

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The Ikoku Holdings

About Us • Governance • Policies