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.

The Ikoku Holdings holds the fullest and most humane understanding of respect for persons to be essential to its formation, development, management, and operations. These Codes and Policies are to constitute a 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:

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— 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, “The Ikoku Holdings” 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:

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.

— 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, “Products” and “Services” refer to — but are not limited to the following:

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.

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

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.

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

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.

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

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.

References to “activity” and “activities” mean and include the following:

References to “applicable law” and “applicable regulation” 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  “applicable law” or “applicable regulation.”

References to “clearly lawful” and equivalents such as “clearly constitutional” and “clearly ethical” 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 “applicable law” or “applicable regulation” 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 “arguably lawful” and equivalents such as “arguably constitutional” and “arguably ethical” 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 “clearly lawful” and equivalents such as “clearly constitutional” and “clearly ethical,” and therefore, would neither meet nor qualify nor satisfy this definition, meaning, legal standard, or equivalent application or interpretation of references to “clearly lawful” and equivalents such as “clearly constitutional” and “clearly ethical.”

References to “confidentiality” and “confidential” 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 “biospecimens,” “confidential data,” “confidential information,” or equivalent mean and include the following:

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

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

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

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

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

References to “DRB approval” mean and include determinations of the DRB that the data or information or their processing has been reviewed and may be processed or conducted at a specific part, product, section, service or site of The Ikoku 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.

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

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

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

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

References to “government review” and “judicial review” and equivalent mean and include adherence to all of the following:

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

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.

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

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

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

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

References to “identifiable biospecimen” and “personal biospecimen” in the context of research or investigation 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.

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

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

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

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.

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

Also, references to “benign behavioral interactions” or “benign interactions” in the context of research or investigation mean and include interactions that are, after rigorous assessment and by written consent and written instrument, confirmed by the human subject, 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.

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

References to “IRB approval” mean and include determinations of the IRB that the research or investigation has been reviewed and may be conducted at a specific at a specific part, product, section, service or site of The Ikoku 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.

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

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

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

Also, references to “benign behavioral interventions” or “benign interventions” in the context of research or investigation mean and include interventions that are, after rigorous assessment and by written consent and written instrument, confirmed by the human subject, 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.

References to “irreversible anonymization” (or “anonymization” 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 “anonymized” 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 Information or the Policy on Human Subjects Research and Investigation.

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

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

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

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

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

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

— (a) served in person;

— (b) sent via electronic mail;

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

— (d) sent by special courier service; or

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

References to “official person” and “official persons” 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, 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.

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

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

References to “privacy” and “private” 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 “biospecimens,” “private data,” “private information,” or equivalent mean and include the following:

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

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

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

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

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

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

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

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

— (d) creating profiles that can be associated with, applied to and tracked with you;

— (e) predicting your behavior based on the assigned, applied or tracked profiles; or

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

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

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

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

Thus, The Ikoku 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 “data processing risks assessment” or a “research and processing risks assessment” then addressing any concerns found; and finally

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

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

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

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

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

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

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

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

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

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

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

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 “seal,” “sealed” and requirements for any instrument to be sealed mean only the use of said approved company seal by causing it to be personally impressed or affixed on an official instrument of The Ikoku 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 “for identification purposes only,” unless such use has been approved by the Founder, President and Chair via express and written instrument signed and sealed.

References to “sensitivity” and “sensitive” 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 “biospecimens,” “sensitive data,” “sensitive information,” or equivalent mean and include the following:

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 “signed,” “signature,” and requirements for any instrument to be signed mean only a personally signed and handwritten mark by the person whose signature is so required and authorized, with stamped, computer generated, facsimile, digital or electronic forms of signature not permitted to serve as substitute.

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. Thus, references to “third party” mean and include a person or entity who is not one of the principals of an activity or relationship (i.e. an agreement, contract, operation, service or transaction) but is involved in that activity or relationship in an official or recognized capacity.

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

All activities, relationships and equivalent arrangements between The Ikoku 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.

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

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

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.

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

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

(2) Approval of Means of Communication — As with all actionable, applicable, approvable, legitimate and official communication from, for, of, in, within or pertaining to The Ikoku 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:

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

(4) Clear Conditions of Consent — As with all actionable, applicable, approvable, legitimate and official communication from, for, of, in, within or pertaining to The Ikoku 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:

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

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.

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.