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Data and Information

Overview

The Ikoku Philanthropies is committed to fostering and conducting protective and respectful processing of data and information, and to achieving this objective in a manner that is ethical, feasible, reasonable and responsive.

Therefore, persons engaged in activity within, for, on behalf of, in reference to and otherwise pertaining to The Ikoku Philanthropies are expected to uphold the following:

Your Agreement

— With respect to the Agreement you enter into with The Ikoku Philanthropies via the Policy on Data and Information, you understand and adhere to the following:

Persons Adhering to Agreement
that the Policy on Data and Information is 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 Philanthropies.
Applicability and Governance of Agreement
that the Policy on Data and Information governs any and all of your access, actions, activity, communication, operations, participation or other use in, with, for, on behalf of, in reference to or otherwise pertaining to The Ikoku Philanthropies, its series, subsidiaries and affiliates, and its Products and Services, including the Sites.
Entry and Continuation of Agreement
that whenever you engage in any access, action, activity, communication, operation, participation or other use in, with, for, on behalf of, in reference to or otherwise pertaining to The Ikoku Philanthropies, its divisions, series, subsidiaries or affiliates, and its Products and Services, including the Sites — directly or indirectly as further described below — you are agreeing to the Policy on Data and Information as well as the associated Codes and Policies that collectively constitute The Ikoku Philanthropies 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 Philanthropies, its divisions, series, subsidiaries or affiliates, and its Products and Services, including the Sites; or through persons and entities working with The Ikoku Philanthropies, its divisions, series, subsidiaries or affiliates, and its Products and Services, including the Sites; or working with such engaged activities and resulting media, materials or otherwise — you are also agreeing to the Policy on Data and Information as well as the associated Codes and Policies that collectively constitute The Ikoku Philanthropies 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 Policy on Data and Information and 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 Policy on Data and Information and Codes and Policies and agree to be legally bound by them (your “Agreement”).
Agreement On Behalf of Organization
that if you are engaging in any of the above described activities, communication or uses for or on behalf of an organization, you are agreeing to this Agreement on behalf of that organization, and represent and warrant that you can do so.
In Case of Non-Agreement or Inability to Honor
that you will not engage in any of the above described activities, communication or uses if you do not agree to all of the Policy on Data and Information or the Codes and Policies or if your jurisdiction will not honor them.

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

Your Consent to The Policy

With respect to your ability to agree and consent to the Policy on Data and Information, 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 Policy on Data and Information, 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 Philanthropies, its series, subsidiaries and affiliates, or its Products and Services, including the Sites with the permission and supervision of an adult parent or guardian.
Reading and Understanding
that you have read and understood the Policy on Data and Information.
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 Policy on Data and Information.

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

Your Abiding by The Policies

You represent, warrant and covenant that, given the above attestation about your consent to the Policy on Data and Information, you have read, understood, consented to and agreed to be legally bound by and abide by the Policy on Data and Information and the Codes and Policies, as they are amended from time to time, and in their entirety without modification.

Your Understanding of Data and Information

You represent, warrant and covenant that, given the above attestation about your consent and adherence to the Policy on Data and Information, you have also read, understood, consented to and agreed to be legally bound by and abide by understandings of data and information as defined in all applicable law and regulation, by The Ikoku Philanthropies in the Codes and Polices, and as further delineated below, to be respected and not harmed or misused, in any way, by you.

Your Understanding of Data Principles and Rights

You represent, warrant and covenant that, given the above attestation about your consent and adherence to the Policy on Data and Information, you have also read, understood, consented to and agreed to be legally bound by and abide by understandings of data and information principles and data and information rights as defined in all applicable law and regulation, by The Ikoku Philanthropies in the Codes and Polices, and as further delineated below, to be respected and not infringed or violated, in any way, by you.

Your Understanding of Data Protections

You represent, warrant and covenant that, given the above attestation about your consent and adherence to the Policy on Data and Information, you have also read, understood, consented to and agreed to be legally bound by and abide by protections for data and information, for data and information principles and for data and information rights, as they are provided for and defined in all applicable law and regulation, by The Ikoku Philanthropies in the Codes and Polices, and as further delineated below, to be fulfilled and respected and not breached or violated, in any way, by you.

Your Commitment to the Understandings

You also represent, warrant and covenant that, given the aforementioned attestation, your commitment to this understanding of data and information, of data and information principles, of data and information rights, and of their protections shall entail the following:

Basis for Your Actions, Activity and Decisions
its basis for any data and information activity you engage in with respect to The Ikoku Philanthropies — including its series, subsidiaries and affiliates, as well as its Products and Services — and that any such actions and decisions you engage in shall be free of any incompatibility with, inconsistency with or violation of this Policy on Data and Information and all applicable laws, protections and regulations.
Commitment to Informed Consent
that this commitment include but not be limited to ensuring and maintaining for every person concerned at The Ikoku Philanthropies reasonably informed consent and informing consent process before, during and after the conduct of activities involving personal data and information.
Commitment to Confidentiality
that this commitment include but not be limited to ensuring and maintaining for every person concerned at The Ikoku Philanthropies protections of confidentiality before, during and after the conduct of activities involving confidential, personal, private and sensitive data and information.
Commitment to Privacy
that this commitment include but not be limited to ensuring and maintaining for every person concerned at The Ikoku Philanthropies protections of privacy before, during and after the conduct of activities involving confidential, personal, private and sensitive data and information.
Commitment to Necessary Limitations
that this commitment include but not be limited to ensuring and maintaining for every person concerned at The Ikoku Philanthropies the limiting of processing of confidential, personal, private and sensitive data and information to what is strictly necessary for the activity, communication, operation, product, service or other use and purposes consented to by the owner of the confidential, personal, private and sensitive data and information.
Commitment to Protections Following From and Ahead of the Law
that you also respectfully assist and in no way interfere with or impede the reasonable efforts taken by The Ikoku Philanthropies to obtain, keep current and comply with required data and information guidelines, law and regulation, as they pertain to applicable local, state, national and international jurisdictions, including but also often beyond what the law provides for and protects with respect to confidentiality and privacy — especially, the California Consumer Privacy Act and European Union General Data Protection Regulation and a number of privacy protections in California, including the constitutional right to privacy provided for in the State Constitution of California, as well as The Ikoku Philanthropies’ Policy on Human Subjects Research and Investigation, itself further informed by the Belmont ReportDeclaration of HelsinkiNuremburg Code, United States Health Insurance Portability and Accountability ActUnited States Policy for Protection of Human Research Subjects, and United Nations Declaration of Bioethics and Human Rights.
Commitment to Respectful and Protective Practices
that you respectfully assist and in no way interfere with or impede the reasonable efforts taken by The Ikoku Philanthropies to translate the above commitments into practices for fulfilling, protecting and respecting data and information, data and information principles, data and information rights, and their protections.

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

Accordance with Ethics

— that The Ikoku Philanthropies ensure following the above principles further remains in accordance with the Codes and Policies and especially the Founding and Governing Code of Ethics.

Further Considerations

Your Knowledge and Agreement

The Ikoku Philanthropies strongly recommends you develop and maintain your knowledge of all the Codes and Policies, and so asks that you read, understand and regularly visit this page and other communications regarding the Policy on Data and Information, as well as the Codes and Policies. The Ikoku Philanthropies takes your continued visiting and use of its Products and Services, including its Sites, as active indication of your knowledge, understanding, legally binding acceptance and agreement.

Your Duty to Company and Division Integrity

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

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

Your Questions and Feedback

Please contact policies@ikokuphilanthropies.com with any feedback, issues or questions — which will be addressed by the President, CEO and Chair, Alvan Azinna Chibuzo Ikoku.

Your Reporting of Violations

If you detect, notice or are informed of a possible breach or violation of this Policy or any of these Codes and Policies, please contact policies@ikokuphilanthropies.com with any details you have — which will be addressed by the President, CEO and Chair, Alvan Azinna Chibuzo Ikoku.

The Definitions

As with all official documents, materials, policies and statements of The Ikoku Philanthropies, definitions for terms used here can be found in the main Codes and Policies page.

The Policy Details

Provision

Along with the above key principles, the Data and Information Policy requires attention to correlative principles, rights and responsibilities delineated below, and strongly recommended steps for enhancing compliance.

A — Basic Principles

The Principles of Processing

There are fifteen (15) overarching principles of processing personal data and information. The Ikoku Philanthropies should fulfill such principles when accessing or otherwise processing data and information attributable to, identifying, or relating to you. The Policy will elaborate in some detail upon each of these principles as you proceed on this page. In the meantime do keep in mind that, as much as feasibly and reasonably possible, The Ikoku Philanthropies endeavors to have processing of personal data and information fulfill all of the following:

Applicability
that any material and activity at The Ikoku Philanthropies that constitutes or involves personal data and information or the processing of personal data and information should be identified and administered as such, and thus made subject to this Policy.
Approval and Certification
that any such personal data and information and processing of personal data and information should be reviewed, then either not approved or certified as approved by a data and information review board (the “DRB”), as described in this Policy.
Benefit
that processing of personal data and information should provide benefit with respect to you — as the natural or legal person concerned.
Harm
that processing of personal data and information should avoid harm with respect to you — as the natural or legal person concerned.
Justice
that processing of personal data and information should be just with respect to you — as the natural or legal person concerned.
Lawfulness
that processing of personal data and information should be lawful with respect to you — as the natural or legal person concerned.
Data, Information and Processing Purpose
that processing of personal data and information should have and adhere to an explicit, legitimate and specific purpose for such processing, clearly explained to you — as the natural or legal person concerned — prior to, during and after the processing.
Respect for Autonomy via Informed Consent
that processing of personal data and information should show and maintain respect for your autonomy, by obtaining and maintaining your informed consent — as the natural or legal person concerned — to an explicit, legitimate and specific purpose for such processing, prior to, during and after processing.
Necessity and Minimization
that processing of personal data and information should be conducted by means that are necessary for the purpose consented to by you — as the natural or legal person concerned.

— and the personal data and information should be the minimum necessary for such processing, its means and its consented purposes.

Non-Identification
that processing of personal data and information should be conducted by means that ensure the non-identification of you — as the natural or legal person concerned — to the most feasible and reasonable extent.
Privacy and Confidentiality
that processing of personal data and information should be conducted by means that maintain and protect your privacy and confidentiality — as the natural or legal person concerned.

— and such processing should be conducted by means that maintain and protect the privacy and confidentiality of the means for their processing

Protection and Security
that processing of personal data and information should be conducted by means that maintain your protection and security — as the natural or legal person concerned.

— and such processing should be conducted by means that maintain the protection and security of the personal data and information and of the means for their processing.

Sensitivity and Sensitive Data and Information
that processing of sensitive personal data and information should be prohibited, except as delineated and described in these Codes and Policies.
Transparency, Informing and Facilitating Rights
that processing of personal data and information should be preceded and accompanied by transparent communication and notification reasonably informing you — as the natural or legal person concerned.

— and that processing of personal data and information should, upon your reasonable request, be accompanied by transparent communication and notification to you — as the natural or legal person concerned — helping you exercise your data and information rights.

Commensurability
that, with the above taking precedence and guaranteed, processing of personal data and information should be accompanied by a process to ensure commensurability is reached in good faith during the review and approval of processing of personal data and information, as well as during the review of cases with apparent inadequacies in the fulfillment of principles, rights and responsibilities of personal data and information.

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

Principle of Applicability

Below are subsequent criteria The Ikoku Philanthropies should follow to determine the applicability of this Policy to an activity or operation. It should be understood that The Ikoku Philanthropies determines such activity or operation to entail or constitute the processing of personal data and information — and therefore to be subject to this Policy — when all of the following apply:

Distinction Between Personal and Non-Personal
the conductors or proposers of the activity or operation make and maintain adequate distinctions between what is personal — meaning, capable of identifying a specific person — and what is non-personal — meaning, incapable of identifying, or being used to identify, a specific person even when an attempt to do so is made.
Determination of Personal Data and Information
the activity or operation involves personal data and information — meaning biospecimens, data, documentation, information or other material that are about, are attributable to, identify, relate to, or can be used to contact or identify a specific person.
Determination of Processing
the activity or operation constitutes processing — meaning an activity or operation or set of activities or operations performed on data and information or on their sets — whether confidential, identifiable, identifying, personal, private, sensitive or not — and whether or not by automated means.
Determination of Person Concerned
the activity or operation involves a natural or legal person concerned — meaning a specific individual or entity who is a subject of, or identifiable by, the data and information, and can be directly or indirectly identified via use of or reference to a single, or a combination of, identifying data and information.
Culmination in Narrow Applicability
and, with the above met, this Policy only applies to actions, activities and operations involving access and other processing of personal data and information attributable to, identifying or otherwise relating to a specific natural or legal person who is among the employees, personnel, partners, third-parties, users, visitors, volunteers and other agents of The Ikoku Philanthropies, narrowly defined, engaging or functioning in an allowed, approved and authorized area, capacity and manner.

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

Principle of Approval

Below are subsequent criteria The Ikoku Philanthropies should follow to review — and either not approve or certify for approval — activities and operations involving personal data and information. It should be understood that The Ikoku Philanthropies determines a processing of data and information to be reviewed, not approved or certified as approved — and thus the principle of approval to be adequately addressed — only if and to the extent that all of the following apply:

Founder and Data Review Board
the Founder, Alvan Azinna Chibuzo Ikoku, as part of the data review board of The Ikoku Philanthropies (the “DRB”) initially then continually or periodically reviews, approves or disapproves all data and information, and processing activities and operations covered by this Policy, before, during and after any processing of data and information.
Requests for Review and Approval
the Founder, Alvan Azinna Chibuzo Ikoku, as part of the DRB, requires submission of projects, proposals and protocols concerning new or proposed data and information and processing of data and information; requires modifications in such materials (to secure approval or compliance); and where applicable, observes the consent process and any appropriate aspects of proposed, ongoing or reported processing of data and information, whether personal or not.
Review for Minimization of Risk
the DRB assesses for and determines risks to you — as the natural or legal person concerned — are minimized.

— and in evaluating risk minimization, the DRB considers and strongly recommends (even restricts approval to) measures and methods that are consistent with sound design and that do not unnecessarily expose you and other persons concerned to risk, and

— whenever appropriate, the DRB considers and strongly recommends (even restricts approval to) measures and methods already being conducted on personal data and information relating to you that are required for the provision of a Product, Service or Site.

Review for Reasonable Benefit-Risk Relation
the DRB assesses for and determines risks to you — as the natural or legal person concerned — are reasonable in relation to anticipated benefits to you.

— in evaluating risks and benefits, the DRB considers only those risks and benefits that may result from the specific data and information and their processing.

— and also, in conducting such evaluation, the DRB does not consider possible long-range effects of knowledge or applications gained from the data and information or their processing as among those benefits and risks that fall within the purview of its responsibility.

Review for Informing and Documented Consent Process
the DRB assesses for and determines the consent process adequately informs you — as the natural or legal person concerned — and informed consent is sought from each prospective person concerned, in accordance with this Policy.

— and in making this determination the DRB confirms appropriate documentation of consent process and informed consent.

Review for Assessment and Monitoring of Data and Information
the DRB assesses for and determines adequate provision for monitoring the data and information that are accessed or otherwise processed to ensure the fulfillment of principles, rights and responsibilities of data and information, especially the confidentiality, privacy, safety, security and sensitivity protections against risks to you — as the natural or legal person.
Review for Assessment and Monitoring of Activities and Methods
the DRB assesses for and determines adequate provision for monitoring the processing activities, measures and methods — including any conducted in relation to data and information — to ensure the fulfillment of principles, rights and responsibilities of data and information to the most feasible and reasonable extent.
Review for Privacy and Confidentiality of Persons Concerned
the DRB assesses for and determines adequate provision to obtain, maintain and protect the privacy and confidentiality of you — as the natural or legal person concerned.
Certification on Approval
all DRB approvals of data and information and their processing covered by this Policy are confirmed then certified by expressly written instrument signed and sealed of the Founder, Alvan Azinna Chibuzo Ikoku.
Periodic Review and Termination
the DRB periodically reviews and has authority to suspend or terminate approval of any data or information or their processing that is not being conducted in accordance with DRB requirements or that has been associated with unexpected serious harm to you or any other natural or legal person concerned.

— and any suspension or termination of approval includes a written statement of the reasons for the DRB action and is reported promptly to The Ikoku Philanthropies and any appropriate regulatory officials.

Possible Further Review
where appropriate, data, information and their processing approved by the DRB may be subject to further review (and approval or disapproval) by authorized officials of The Ikoku Philanthropies — including the possibility of a recommended rejection of DRB decisions on grounds of anticipated or confirmed creation of difficult legal or policy problems — though such officials cannot approve the data, information or their processing if they have not been approved by the DRB.

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

Principle of Benefit

Below are subsequent criteria The Ikoku Philanthropies should follow to determine and ensure commensurate benefit when processing data and information attributable to, identifying or otherwise relating to you. It should be understood that The Ikoku Philanthropies determines processing to be beneficial — and thus the principle of benefit to be adequately addressed — only if and to the extent that all of the following apply:

Processing to Provide Benefit to Person Concerned
the processing of personal data and information is conducted by means that provide product or service benefit to you — as the natural or legal person concerned.
Processing to Provide Benefit to The Ikoku Philanthropies
the processing of personal data and information is conducted by means that provide product and service benefit to The Ikoku Philanthropies — including the Products, Services and Sites.
Processing to Prioritize Person Concerned
the processing of personal data and information is conducted by means that prioritize providing product or service benefit to The Ikoku and to you — as the primary natural or legal persons concerned — and then, where applicable and appropriate, to other persons.
Processing to Avoid Undue Inducement
the processing of personal data and information is conducted by means that avoid the use of benefits as undue inducement to elicit your consent — as the natural or legal person concerned.

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

Principle of Harm

Below are subsequent criteria The Ikoku Philanthropies should follow to determine and minimize harm when processing data and information attributable to, identifying or otherwise relating to you. It should be understood that The Ikoku Philanthropies determines processing to be non-harmful or minimally harmful — and the principle of harm to be adequately addressed — only if and to the extent that all of the following apply:

Processing to Minimize Harm to Persons Concerned
the processing of personal data and information is conducted by means that minimize their harms to you — as the natural or legal person concerned.
Processing to Minimize Harm to The Ikoku Philanthropies
the processing of personal data and information is conducted by means that minimize their harms to The Ikoku Philanthropies — including its personnel, Products, Services and Sites.
Processing to Minimize Harm to Community and Society
the processing of personal data and information is conducted by means that minimize their harms to the community and society where such processing is conducted.
Processing to Minimize Harm to Environment
the processing of personal data and information is conducted by means that minimize their harms to the biosphere and physical and vegetative environments where such processing is conducted.
Processing to Prioritize Person Concerned
the processing of personal  data and information is conducted by means that prioritize reduction of their harms to you and to The Ikoku Philanthropies — as the primary natural and legal persons concerned — and then to the community, environment and society where such processing is conducted.
Processing to Avoid Unnecessary Risk
the processing of personal data and information is conducted by means that avoid incurring excessive, unexpected, unexplained or unnecessary risk to you — as the natural or legal person concerned.

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

Principle of Justice

Below are subsequent criteria The Ikoku Philanthropies should follow to determine and ensure commensurate levels of justice when processing data and information attributable to, identifying or otherwise relating to you. It should be understood that The Ikoku Philanthropies determines processing to be just — and thus the principle of justice to be adequately addressed — only if and to the extent that all of the following apply:

Just Processing as Facilitating Your Rights
all involved understand and reasonably meet their obligation to provide just processing of personal data and information, meaning their duty to facilitate you — as the natural or legal person concerned — in exercising and enjoying a set of rights delineated and described in this Policy and the Codes and Policies.
As Avoiding Discrimination
the processing of personal data and information is conducted by means that avoid discrimination or discriminatory or stigmatizing bias or effects on you — as the natural or legal person concerned.
As Avoiding Civil and Fundamental Rights Infringement
the processing of personal data and information is conducted by means that avoid abrogation or infringements of delineated civil liberties and basic, civil and fundamental rights of you — as the natural or legal person concerned.
As Avoiding Data and Information Rights Infringement
the processing of personal data and information is conducted by means that avoid abrogation or infringements of delineated data and information rights of you  — as the natural or legal person concerned.
As Protecting Against Anticipated Rights Diminishment
the processing of personal data and information is conducted by means that account for and protect against anticipated arguments and rationales for the diminishment of delineated civil, fundamental and data and information rights of you  — as the natural or legal person concerned.
As Protecting Vulnerable Persons
the processing of personal data and information is conducted by means that account for, attend to and protect vulnerable persons.
As Accounting for a History of Vulnerable Populations
the processing of personal data and information is conducted by means that account for a history of vulnerable populations, and so avoid repeating historical patterns of harmful or unethical processing pertinent to vulnerable populations.

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

Principle of Lawfulness

Below are subsequent criteria The Ikoku Philanthropies should follow to determine and ensure the lawfulness of processing data and information attributable to, identifying or otherwise relating to you. It should be understood that The Ikoku Philanthropies determines processing to be lawful — and thus the principle of lawfulness to be adequately addressed — only if and to the extent that all of the following apply:

Person Informed by Transparent Communication
you — as the natural or legal person concerned — are provided transparent communication and notification reasonably informing you about the personal data and information and their processing.
Informed and Unrevoked Consent of Person Concerned
you — as the natural or legal person concerned — have also given and not revoked informed consent to the processing of the personal data and information for its explained, explicit, legitimate and specific purpose.
Necessity for Consented or Assented Purpose
the processing of personal data and information is also conducted by means that are necessary to fulfill the explained, explicit, legitimate and specific purpose consented (or assented) to by you — as the natural or legal person concerned.
Proportionate to Consented or Assented Purpose
the processing of personal data and information is also conducted by means that are proportionate — or appropriate, effective and commensurate with fulfilling the explained, explicit, legitimate and specific purpose consented (or assented) to by you — as the natural or legal person concerned.
Accordance with Rights
the processing of personal data and information is conducted by means that are in accordance with and do not abrogate or diminish the civil liberties or basic, civil or fundamental rights of you — as the human subject under study.
Accordance with Law
the processing of personal data and information is conducted by means that are in accordance with and do not violate applicable guidelines, law or regulations.
Accordance with Ethics
the processing of personal data and information is conducted by means that are in accordance with and do not violate ethics codes, policies and regulations, especially the approval and review process of the DRB, these Codes and Policies, and the Founding Code of Ethics.

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

Principle of Purpose

Below are subsequent criteria The Ikoku Philanthropies should follow to determine and ensure the appropriate nature of the purpose for processing data and information attributable to, identifying or otherwise relating to you. It should be understood that The Ikoku Philanthropies determines a purpose for processing to be appropriate, effective and respectful — and thus the principle of purpose to be adequately addressed — only if and to the extent that all of the following apply:

Purpose Should be Explicit
the purpose for the processing of personal data and information is explicit, or clearly explained to you — as the natural or legal person concerned — before, during and after the processing of such data and information.
Purpose Should be Specific
the purpose for the processing of personal data and information is specific, or clearly defined, delineated and specified to you — as the natural or legal person concerned — before, during and after the processing of such data and information.
Purpose Should be Legitimate
the purpose for the processing of personal data and information is legitimate, or has a reasonable basis that is clear, expected and understandable to you — as the natural or legal person concerned — before, during and after the processing of such data and information.
Purpose Should be Consented
the purpose for the processing of personal data and information is consented to by you — as the natural or legal person concerned — before, during and after the processing of such data and information.

— or, with the above given precedence and good faith opportunity, but where consent cannot be freely given or meaningful, only if the processing of personal data and information has been assented to by you — as described in these Codes and Policies — before, during and after the processing of such data and information.

Where Added or Changed, then Limited, Compatible and Reviewed for Consent
and, where the purpose has been changed from or added to the original purpose for processing personal data and information, only if such changed or new purpose is also limited and compatible — or has an association to the original purpose that you would consider to be close, compatible and in keeping with your consent, and so you would reasonably expect the addition or change.

— and, if so, the expectation is also confirmed as soon as reasonably possible, by having the changed or new purpose reviewed and consented to by you — as the natural or legal person concerned — or otherwise assented.

Furthermore, The Ikoku Philanthropies determines a purpose to be legitimate only if and to the extent that the above and all of the following apply:

Reasonably Expected by Persons Given Activities and Relations
the nature of the purpose is reasonably expected by you — as the natural or legal person concerned — given your relationship to The Ikoku Philanthropies and understanding of activities and services being offered to you.
Reasonably Expected by Persons Given Proportionality
the scope of the purpose is reasonably expected by you, given your understanding that such purposes be proportionate — or appropriate, effective and commensurate with your relationship to The Ikoku Philanthropies and activities and services being offered to you.
Reasonably Expected by Persons Given Rights and Policies
the purpose is reasonably expected by you — as the natural or legal person concerned — given your understanding that such purposes be in keeping with the protection of your civil liberties and basic, civil and fundamental rights, and the fulfillment of the principles, rights and responsibilities of personal data and information.
Legal and Law-Abiding
the purpose is legal and law-abiding with respect to you — as the natural or legal person concerned — but also with respect to applicable local, regional, national and international law.
Reasonably Expected by Field Given Prior Research
the purpose is acceptable, sound and reasonably expected by the field of knowledge, practice or service in which the processing is conducted — given standards informed by prior knowledge, practice or service.
Ethical and Not Harmful
and the purpose is ethical, unharmful and not exceedingly risky with respect to you — as the natural or legal person concerned — but also with respect to standards set out in applicable guidelines, protocols and regulations, the Founding Codes of Ethics, this Policy and these Codes and Policies.

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

Principle of Informed Consent

Below are subsequent criteria The Ikoku Philanthropies should follow in determining and ensuring respect for autonomy and informed consent when processing data and information attributable to, identifying or otherwise relating to you. It should be understood that The Ikoku Philanthropies determines your autonomy and consent to be respected — and thus the principle of informed consent to be adequately addressed — via a five-part evaluation.

The first part consists of a statement of community standards The Ikoku Philanthropies upholds with respect to consent and their subsequent ethics requirements:

Consent as Fundamental Basis
your consent is a fundamental basis for actions you conduct within and in relation to communities and societies, and it is also a fundamental basis of your presence within and in relation to those communities and societies.
Personal Data and Information as Subject to Consent
data and information attributable to, identifying or otherwise relating to you are important aspects of your conduct and presence within and in relation to communities and societies — and so personal data and information, including its processing, should be subject to your consent.
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 — which requires The Ikoku Philanthropies to acknowledge their personhood by providing ample opportunities for their informed consent to processing personal data and information.
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 — which requires The Ikoku Philanthropies to acknowledge their personhood and situation by providing ample opportunities for their informed assent, as well as safeguards and at times non-approval of personal data and information processing.

The second part consists of the standard The Ikoku Philanthropies should follow in asking for and maintaining consent before, during and after processing data and information attributable to, identifying or otherwise relating to you. It should therefore be understood that The Ikoku Philanthropies determines consent to be given and maintained only if and to the extent that the following standard has been met:

Consent Warranting Respect
your consent should not be a matter for coercion, confusion, deception, force or trickery — it should be a matter for respect, when asked, given, or withdrawn.
Consent, Valid and Legally Binding Standard
so consent with respect to personal data and information should be affirmative, clear, freely given, reasonably informed, meaningful, revocable, unambiguous and written by you — as the natural or legal person concerned — and furthermore expressly indicated for an explicit, legitimate and specific purpose for processing personal data and information attributable to, identifying or otherwise relating to you — as this purpose is delineated and explained in an accessible, clear, easily legible and understandable, informing and written form, page or request.

As you may already be able to tell from the paragraph above, consent is a high-quality standard, and an important basis for the work The Ikoku Philanthropies does regarding personal data and information. The Ikoku Philanthropies wishes for you to be educated as well as informed during your decisions to give or withdraw consent. And to do that the Policy will start here to break consent into its essential components and explain each one.

So the third part of this policy evaluation concerns making sure you are in a situation where your consent is freely given and meaningful.

Where Consent Can Be Freely Given and Meaningful
for consent pertaining to personal data and information to be freely given and meaningful, the consent process should involve your free or genuine choice and your ability to refuse or withdraw such consent without unfair detriment, non-enjoyment of or non-participation in authorized parts of The Ikoku Philanthropies.
Where Consent Cannot Be Freely Given or Meaningful
meanwhile, consent cannot be presumed to be freely given or meaningful if the asker or requester for your consent is in a position to compel consent from you; where you have no reasonable option but to give consent; where you were made to understand that you needed to consent when you did not; or where you are not able to proceed with a basic standard of living without engaging in an activity that presumes your consent.
Classic Situations of Consent Not Freely Given or Meaningful
therefore consent pertaining to personal data and information cannot be presumed to be freely given or meaningful — and it is unlikely to provide a valid legal ground for processing your personal data and information — if the asker or requester is a public authority, public office or government official or a judiciary representative with a subpoena or warrant; or if you are a child and need your next of kin to take your wishes into account in providing assent to the processing of personal data and information; or if the asker or requester presents consent pertaining to personal data and information as necessary or required where it is not (e.g. asking consent to collect and track certain personal data as though necessary for the performance of an agreement or contract, or the provision of a product or service, when such processing is not necessary for such performance or such provision).
The Goal is Freely Given and Meaningful, Of Course
the goal, when The Ikoku Philanthropies asks for your consent, is to have any positive decision on your part be freely given and meaningful — again without coercion, confusion, deception, force or trickery — and where this is not possible the equally important goal is to reasonably inform you of that situation, so that you are reasonably aware of the quality of any consent — or assent — given, or any alternative grounds upon which the processing of your personal data and information is being conducted.

The next part of the policy evaluation has to do with making sure the consent process has reasonably informed you — as the natural or legal person concerned. That typically occurs where the form, page, part or request for consent informs you of the following:

Reasonably Informing, Ethical Standard
such communication and notification provide to you — as the natural or legal person concerned — all the key information, in sufficient detail, that a reasonable person would want to have in order to make an informed decision about whether to permit the processing of personal data and information.

— and so the informing process does not merely provide lists of isolated facts, but is instead organized in a manner most likely to assist you — as the natural or legal person concerned — in understanding the reasons why you might or might not want to permit such processing.

Informing, Confirmation of Processing
such communication and notification provide to you — as the natural or legal person concerned — confirmation as to whether data and information attributable to, identifying or otherwise relating to you will be accessed or otherwise processed.
Informing, Purposes of Processing
such communication and notification clearly explain to you — as the natural or legal person concerned — the explicit, legitimate and specific purpose for which data and information attributable to, identifying or otherwise relating to you will be accessed or otherwise processed.
Informing, Duration of Processing
such communication and notification clearly explain to you — as the natural or legal person concerned — the period of time during which data and information attributable to, identifying or otherwise relating to you will be accessed or otherwise processed.
Informing, Methods of Processing
such communication and notification clearly explain to you — as the natural or legal person concerned — the means, measures and methods by which, as well as the extent to which, data and information attributable to, identifying or otherwise relating to you will be accessed or otherwise processed.
Informing, Recipients of Processing
such communication and notification clearly explain to you — as the natural or legal person concerned — what recipients and categories of recipients will receive data and information attributable to, identifying or otherwise relating to you — including any transfers to any third party, third country, governmental office or international organization.
Informing, Content of Processing
such communication and notification clearly explain to you — as the natural or legal person concerned — what categories, content and nature of data and information attributable to, identifying or otherwise relating to you will be accessed or otherwise processed.
Informing, Processes of Non-Identification
such communication and notification clearly explain to you — as the natural or legal person concerned — whether and how identifiers will be removed from data and information attributable to, identifying or otherwise relating to you.

— and clearly confirm and explain, whether or not other processes of non-identification are to be employed, including periodic re-identification, and if so under what circumstances and to what extent.

Informing, Future Processing of Content
such communication and notification clearly confirm to you — as the natural or legal person concerned — that whether or not such processes of non-identification are conducted, the personal data and information shall not be used for future processing, unless with additional informed consent from you.

— or such communication and notification clearly provide you — as the natural or legal person concerned — an opportunity to consent to have the personal data and information become and remain non-personal via a combination of irreversible anonymization and further transformation (such as data aggregation), after which such data and information can be used for future processing without additional informed consent from you.

Informing, Processing and Sensitivity
such communication and notification clearly confirm to you — as the natural or legal person concerned — whether sensitive data and information attributable to, identifying or otherwise relating to you (especially biospecimens) will be accessed or otherwise processed about or from you.

— and if so, such communication also confirms and explains the consent process, protections and safeguards provided to you specifically for the sensitive data and information, and especially biospecimens.

Informing, Costs of Processing
such communication and notification clearly explain to you — as the natural or legal person concerned — any additional costs to you that may reasonably be expected from the provision or processing of data and information attributable to, identifying or otherwise relating to you.
Informing, Benefits of Processing
such communication and notification clearly explain to you — as the natural or legal person concerned — any benefits to you or to others that may reasonably be expected from the provision or processing of data and information attributable to, identifying or otherwise relating to you.
Informing, Risks of Processing
such communication and notification clearly explain to you — as the natural or legal person concerned — any risks to you or to others that may reasonably be expected from the provision or processing of data and information attributable to, identifying or otherwise relating to you.
Informing, Protections and Safeguards
such communication and notification clearly explain to you — as the natural or legal person concerned — policies, principles and standards for processing the personal data and information attributable to, identifying or otherwise relating to you, as well as the protections and safeguards in relation to the processing of the personal data and information.
Informing, Rights
such communication and notification clearly explain to you — as the natural or legal person concerned — your rights with respect to data and information attributable to, identifying or otherwise relating to you, and with respect to their processing, as well as the means and procedures for exercising your rights in relation to the personal data and information and to their processing.
Informing, Ideally Voluntary Nature of Processing
such communication and notification clearly explain to you — as the natural or legal person concerned — that the provision of data and information attributable to, identifying or otherwise relating to you, as well as their processing, should be voluntary; that refusal should involve no penalty or loss of benefits to which you are otherwise entitled; and that you should be able to discontinue your participation at any time without penalty or loss of benefits to which you are otherwise entitled.
Informing, Any Compulsory Nature of Processing
nevertheless, such communication and notification clearly confirm to you — as the natural or legal person concerned — whether the provision of data and information attributable to, identifying or otherwise relating to you, including their processing, is a contractual or statutory requirement, or a requirement necessary to enter into an agreement or contract, as well as whether you are obliged to provide the personal data and information, and the possible consequences of failure to provide the personal data and information.
No Exculpatory Language
such communication and notification contain no exculpatory language through which you — as the natural or legal person concerned — are made to waive or appear to waive any of your legal rights, or release or appear to release The Ikoku Philanthropies, or other processor of the personal data and information, from liability for negligence.
Informing, Communication about Processing
such communication and notification clearly explain to you — as the natural or legal person concerned — the procedures for obtaining confirmation and communication with respect to data and information attributable to, identifying or otherwise relating to you, as well as to their processing.
Informing, Responsible Entity, Offices or Persons
such communication and notification provide to you — as the natural or legal person concerned — the identity and contact information of the entity, office or persons responsible for the data and information attributable to, identifying or otherwise relating to you, and for their processing, including whom you are to contact for answers to pertinent questions.
Given No Adverse Effects on Rights of Others
provided that such communication and notification to you — as the natural or legal person concerned — whether pertaining to data and information or their processing, do not adversely affect the civil liberties and basic, civil and fundamental rights of others — particularly those of other natural or legal persons concerned, including The Ikoku Philanthropies and its Founder, Alvan Azinna Chibuzo Ikoku.
Given Necessity, Non-Identification and Minimization
provided too that such communication and notification to you — as the natural or legal persons concerned — whether pertaining to the data and information or their processing, adhere to and fulfill the principles of necessity, non-identification and data-minimization.
Given Adherence to Founding Mission and Code of Ethics
and provided that such communication and notification adhere to and not be incompatible with the founding of The Ikoku Philanthropies, originating mission and purposes, and Founding and Governing Code of Ethics, most especially our concern and protections for confidentiality and privacy.

The fifth and final component has to do with establishing clarity, identity and understanding during the consent process itself. It is best to explain this component as the Policy places all five parts together. It should thus be clearer, now, when the Policy states that The Ikoku Philanthropies endeavors to achieve and maintain a quality of informed consent meeting the above standard, by having all of the following apply:

Authorized and Identified Parties to Consent
the consent process is between an accurately, appropriately, clearly, correctly and securely authorized and identified employee or part of The Ikoku Philanthropies and an accurately, appropriately, clearly, correctly and securely identified natural or legal person who is a subject of, or identifiable by, the personal data and information.
Written and Documentable Consent Process
the form, page, part or request for consent is in writing, written communication or a written instrument.

— and such written communication or instrument is documentable or preservable as part of the records of The Ikoku Philanthropies, to be later reproducible in legible, physical and written form wherever there is need to demonstrate the actions and decisions of the consent process.

Accessible and Understandable Consent Process
the form, page, part or request for consent is easily accessible and easy to understand for you — as the natural or legal person concerned — and clear and plain language be used in such writing, written communication or written instrument.
Explicit, Legitimate and Specific Purposes
the form, page, part or request for consent clearly delineates, describes and explains to you — as the natural or legal person concerned — one or more explicit, legitimate and specific purposes for which your consent is being ascertained.
Lawful Processing
the form, page, part or request for consent clearly delineates, describes and explains to you — as the natural or legal person concerned — the expectations and safeguards for lawful processing of personal data and information.
Reasonably Informing Consent Process
the form, page, part or request for consent, and the consent process itself, reasonably informs you — as the natural or legal person concerned.
Freely Given and Meaningful Full, Partial or No Consent
the form, page, part or request for consent clearly indicates, where appropriate, fair, and non-disruptive, how you — as the natural or legal person concerned — could freely and meaningfully give full, partial or no consent to different purposes and processes — and also explains the effect of such consent on your enjoyment of or participation in an agreement, contract, product, service, site or authorized part of The Ikoku Philanthropies.
Good Faith Opportunity Where Consent Cannot be Freely Given or Meaningful
the form, page, part or request for consent clearly discloses and explains to you — as the natural or legal person concerned — both where consent cannot be freely given or meaningful and the reasons for such a determination — then also provides a good faith opportunity for you to (a) confirm your own understanding of the nature of the consent and the determination; (b) decide whether to proceed with the informing consent process and, perhaps eventually, the processing of personal data and information in question; (c) decide not to proceed at all; or (d) opt for any alternative processing of personal data and information that may fulfill the same or equivalent purposes and where consent can be freely given and meaningful.
Procedures for Withdrawal
the form, page, part or request for consent includes a clear written statement informing you — as the natural or legal person concerned — of your right to revoke or withdraw consent at any time; the easily accessible, comprehensible and implementable procedures for revoking or withdrawing consent; and the effect of revoking or withdrawing consent on the lawfulness of processing conducted on your personal data and information during the period in which your consent was given.
Attestation and Confirmation of Identity
the form, page, part or request for consent includes a means by which you — as the natural or legal person concerned — can accurately, clearly and unambiguously attest to and confirm your identity, appropriateness and authorization for giving, revoking or withdrawing consent.
Attestation and Confirmation of Understanding
the form, page, part or request for consent includes a means by which you — as the natural or legal person concerned — can accurately, clearly and unambiguously attest to and confirm your understanding and your being reasonably informed of the consent process and the terms of giving, revoking or withdrawing consent.
Affirmative, Clear and Unambiguous
the form, page, part or request for consent includes a means by which you — as the natural or legal person concerned — can provide an affirmative, clear and unambiguous indication of your consent decisions pertaining to the personal data and information.

— note such means could include, for example, clicking a button or ticking a box when visiting an internet website, choosing privacy and technical settings for products and services, or other conduct or statements that are defined or described to clearly indicate in this context the acceptance of proposed purposes and processing for the personal data and information.

— therefore The Ikoku Philanthropies understands inactivity, inference, pre-ticked boxes, presumption, silence, ambiguous, unclear or unintended language or sound and their equivalent to not constitute consent.

Freely Given, Meaningful and Revocable
the form, page, part or request for consent includes a means by which you — as the natural or legal person concerned — can accurately, clearly and unambiguously attest to and confirm the fact that any consent you provide is freely given, meaningful and revocable.

Addendum — What About Assent?: Then there are situations — as this Policy alluded to earlier — where the consent you give cannot be considered freely given and meaningful, or you may not be able to properly give consent at all. Here, The Ikoku Philanthropies still insists on treating you as a deciding human being and individual as much as possible, and so after carrying out the informing consent process in good faith, the policy evaluation proceeds through the order below and determines your assent to have been fulfilled when one of the following applies:

Assent Where Necessary for Protection of Vital Interests
that with the above given precedence and good faith opportunity, but where consent cannot be freely given or meaningful, The Ikoku Philanthropies ascertains your likely assent with substantial protections for you only if the processing of personal data and information is still necessary to protect vital interests that are imminently essential to your life — as the natural person concerned — with the standard being a medically-proven and imminently life-saving procedure or treatment.

— in such contexts (especially where children are involved) the informed permission is frequently also required of another natural or legal person (for instance, a parent, guardian, advocate or legal representative). All persons asked and giving consent, assent or permission are to be provided the complete informing consent process to the fullest extent possible, and the standards for both affirmative indication (or withdrawal) and documentation remain the same as they are for informed consent.

Assent Where Necessary for Protection of Rights and Associated Interests
or, with the above given precedence and good faith opportunity, but where consent cannot be freely given or meaningful, The Ikoku Philanthropies ascertains your likely assent with substantial protections for you only if the processing of personal data and information is still necessary to protect the legal rights and associated interests of you — as the natural or legal person concerned.
Assent Where Necessary for Agreement or Contract
or, with the above given precedence and good faith opportunity, but where consent cannot be freely given or meaningful, The Ikoku Philanthropies ascertains your likely assent with substantial protections for you only if the processing of personal data and information is still necessary for the performance of an agreement or contract of The Ikoku Philanthropies to which you — as the natural or legal person concerned — are a consented party.

— or, instead, with the above given precedence and good faith opportunity, but where consent cannot be freely given or meaningful, The Ikoku Philanthropies ascertains your likely assent with substantial protections for you only if the processing of personal data and information is still necessary to take steps — at your request and consent, as the natural person concerned — prior to and with the intention of entering into an agreement or contract of The Ikoku Philanthropies to which you will be a consented party.

Assent Where Necessary for Compliance
or, with the above given precedence and good faith opportunity, but where consent cannot be freely given or meaningful, The Ikoku Philanthropies ascertains your likely assent with substantial protections for you only if the processing of personal data and information is still necessary for compliance with legal obligations to which The Ikoku Philanthropies is subject, as those obligations are described in the Codes and Policies and our other official governance documents.
Assent Where Necessary for Company Duties and Functions
or, with the above given precedence and good faith opportunity, but where consent cannot be freely given or meaningful, The Ikoku Philanthropies ascertains your likely assent with substantial protections for you only if the processing of personal data and information is still necessary for the performance of a task carried out in the exercise of company authority, duties and functions vested in The Ikoku Philanthropies, as such authority, duties and functions are described in the Codes and Policies and our other official governance documents.*
Given Complete Informing Consent Process
provided that you — as the natural or legal person concerned — undergo the complete informed consent process.
Given High Evidentiary Basis for Activity, Method and Measure
provided also that there is rigorous assessment and confirmation (from the DRB and processor) that establishes a high evidentiary basis for the rationale for recourse to assent and a high evidentiary basis for each activity, measure, method and operation conducted pursuant to assent — with the standard being that developed for evidence-based medicine.
Given Highly Favorable and Protective Benefit-Risk Assessment
provided also that there is rigorous assessment and confirmation (from the DRB and processor) that establishes that the relation between benefit and risk to you — as the natural or legal person concerned — of the processing of personal data and information is highly favorable and highly protective.
Given Strict Elimination of Risk of Adverse Effect or Impact on Disclosure
provided too that there is rigorous assessment and confirmation (from the DRB and processor) that the processing of data and information is conducted in a manner that eliminates any disclosure that would place you — as the natural or legal person concerned — at risk of criminal or civil liability or be damaging to your educational advancement, employability, financial standing or reputation.
Given Rigorous Non-Identification of Data and Information
provided as well that all data and information obtained are accessed or otherwise processed in such a manner that rigorously fulfills the principle of non-identification and your identity — as the natural or legal person concerned — cannot be ascertained, directly or indirectly through identifiers linked to you.*
Given Rigorous Re-Identification of Data and Information
and provided that whenever data and information obtained are accessed and otherwise processed in such a manner that the identity of you — as the natural or legal person concerned — can be ascertained, directly or indirectly through identifiers linked to you, the processing rigorously adheres to protective protocols reviewed by the DRB specifically for the processing prior to its approval.

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

*As a clarifying indication of how highly protective measures should be under conditions of informed assent (or consent): note that applying the principles of necessity, non-identification, minimization and sensitivity insists that mechanisms for performance and security-related review or testing at The Ikoku Philanthropies should still normally be developed and conducted without resorting to personal profiling, surveillance or tracking.

Principles of Necessity and Minimization

Below are subsequent criteria The Ikoku Philanthropies should follow to determine and ensure necessity and minimization when processing data and information attributable to, identifying or otherwise relating to you. It should be understood that The Ikoku Philanthropies determines processing to be necessary and minimal — and thus the principles of necessity and minimization to be adequately addressed — only if and to the extent that all of the following apply:

Necessary Data and Information for Consented or Assented Purpose
the personal data and information accessed or otherwise processed are appropriate, expected and necessary to fulfill the explained, explicit, legitimate and specific purpose consented (or assented) to by you  — as the natural or legal person concerned.
Necessary Processing for Consented or Assented Purpose
the processing of personal data and information is conducted by means that are appropriate, expected and necessary to fulfill the explained, explicit, legitimate and specific purpose consented (or assented) to by you  — as the natural or legal person concerned.
Minimal Data and Information for Consented or Assented Purpose
the personal data and information accessed or otherwise processed are in amounts and ranges that are minimally necessary to fulfill the explained, explicit, legitimate and specific purpose consented (or assented) to by you  — as the natural or legal person concerned.
Minimal Processing for Consented or Assented Purposes
the processing of data and information is conducted at frequencies and to the extent minimally necessary to fulfill the explained, explicit, legitimate and specific purpose consented (or assented) to by you  — as the natural or legal person concerned.
Minimal Risk and Prior Assessment
where possible and appropriate, prior processing — equivalent in data and information, means and persons concerned — is consulted to assess anticipated risks to you, and to ascertain measures that would ensure “minimal risk” for you — the natural or legal person concerned.
Least Risk Necessary for Consented or Assented Purpose
the personal data and information attributable to, identifying or otherwise relating to you carry the least risk necessary to fulfill the explained, explicit, legitimate and specific purpose consented (or assented) to by you — as the natural or legal person concerned.

— and the processing of the personal data and information is conducted by means that carry the least risk necessary to fulfill the explained, explicit, legitimate and specific purpose consented (or assented) to by you — as the natural or legal person concerned.

No Reasonable Alternative Data and Information
there is a review of data and information to ensure that the explained, explicit, legitimate and specific purpose consented (or assented) to by you — as the natural or legal person concerned — cannot reasonably be fulfilled by any other data and information.
No Reasonable Alternative Processing
there is a review of the processing of data and information to ensure that the explained, explicit, legitimate and specific purpose consented (or assented) to by you — as the natural or legal person concerned — cannot reasonably be fulfilled by any other means of processing.
No Further Processing
there is also monitoring of the processing of data and information to ensure such data and information are not further processed for purposes other than the explicit, legitimate and specific purpose consented (or assented) to by you — as the natural or legal person concerned — and by means other than those necessary to fulfill such purposes.*
Adequacy, Relevance and Limitation
there is monitoring of the personal data and information to ensure that such data and information are adequate, relevant and limited to what is necessary for the means and purposes consented (or assented) to by you — as the natural or legal person concerned.
Accuracy, Correction and Rectification
there is monitoring of the processing of personal data and information to ensure that such data and information are and remain accurate, and that inaccurate personal data and information are corrected or rectified.
Strict Minimum Period
there is monitoring of the processing of data and information to ensure that the period for which the data and information are accessed, gathered, stored or otherwise processed is limited to a strict minimum.
Time Limits for Periodic Review
there is monitoring of the processing of data and information to ensure that time limits are established for periodic review and then for any appropriate, respectful decision as to their continued processing, including correction or rectification, deletion or erasure, maintenance or storage.

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

Principle of Non-Identification

Below are subsequent criteria The Ikoku Philanthropies should follow to determine and maintain non-identification when processing data and information attributable to, identifying or otherwise relating to you. It should be understood that The Ikoku Philanthropies determines processing to be non-identifying — and thus the principle of non-identification to be adequately addressed — via a two-part evaluation.

The first consists of a statement of The Ikoku Philanthropies’s preferred (or normative) approach to design when it comes to handling personal data and information attributable to, identifying or otherwise relating to you:

Statement of Preferred or Normative Non-Identifying Design
where appropriate, possible and reasonable — and certainly where necessary or required — any access or other processing of personal data and information should be done by means that do not permit or require the identification of you or any other natural or legal person.
Non-Identifying Nature of Data and Information
note that adhering to the above statement should at the very least lead The Ikoku Philanthropies toward measures and methods that — by design — generate data and information that are non-identifying in nature. Such preferred processing methods typically entail taking personal data and information through steps known as de-identification, pseudonymization, pseudo-anonymization, anonymization and irreversible anonymization.

— But they may also include initial access or other processing methods that result in non-personal data and information from the outset or very soon after, with little or no ability or possibility of attributing to, identifying or otherwise relating to a natural or legal person. For instance, protocols designed and set to detect only resolutely anonymous data and information (still, though, with your consent).

Non-Identifying Processing of Data and Information
note, too, that adhering to the above statement should also lead The Ikoku Philanthropies to implement non-identifying processing measures and methods that — by design — do not need to identify you to be conducted. The goal of these design choices is to greatly reduce our need for identification of natural or legal persons to carry out a task or service.

— An example: storage-and-use decentralization protocols designed and set to avoid gathering and processing your personal or non-personal data and information at central servers and to instead keep such data and information — and any task-specific processing — only on your device, and thus subject solely or primarily to your immediate use and specific consenting decisions.

Critical for Achieving Protection by Design
and note that the above approach, preferences and methods are critical for attaining and maintaining standards for data and information protection by design — one of two key principles for protection of you and other natural and legal persons concerned.*

The second part of the evaluation for non-identification is a statement of our default (or normative) position when handling personal data and information that is no longer identifying:

Default and Normative Position to Maintain Non-Identifying State
where any processing of personal data and information does not permit or require, or no longer permits or requires, the identification of you or another natural or legal person, The Ikoku Philanthropies should not be obliged to acquire, maintain or process additional information in order to identify you or another natural or legal person concerned.
Notion of You as Supposedly a Person Concerned
note, at the end of that above statement, the description of you as effectively unidentified, and the attendant notion that you are now among persons who were earlier (supposedly) identifiable by the personal data and information.
Exception to Default Position Only on Your Request
the above notion is important, because the policy evaluation will maintain the default position, unless The Ikoku Philanthropies receives a consented request from you — as a (supposed) natural or legal person concerned — that also meets all of the following three requirements:
Request to Exercise Personal Data Rights
there is a request by you — as a (supposed) natural or legal person concerned — to exercise any of your data and information rights with respect to the non-identifying personal data and information in question.
Offer to Provide Additional Identifying Information
and, as part of the request to exercise your data and information rights, you — as a (supposed) natural or legal person concerned — offer to provide additional information identifying you and connecting you to the non-identifying personal data and information.

— and where provided, The Ikoku Philanthropies should accept and process such information in order to support the exercise of your rights.

Nature of Additional Information
such additional information provided by you also includes authenticating and matching credentials for digital or electronic identification and security mechanisms, for example, log-in credentials, answers to identity or security questions, one-time codes for multi-factor or two-factor authentication.
Given No Adverse Effects on Rights to Be Informed and to Consent
provided that such fulfillment of principles for non-identification — whether pertaining to the research, investigation, biospecimens, data and information or their processing — does not adversely affect the rights to being informed and to consent of others concerned — particularly those of other human subjects under study and natural or legal persons concerned, including The Ikoku Philanthropies and its Founder, Alvan Azinna Chibuzo Ikoku.
Given No Adverse Effects on Rights of Others
provided that such fulfillment of principles for non-identification does not adversely affect the civil liberties and basic, civil and fundamental rights of other natural or legal persons concerned, including The Ikoku Philanthropies and its Founder, Alvan Azinna Chibuzo Ikoku.
Given Adherence to Founding Mission and Code of Ethics
and provided that such fulfillment of principles for non-identification adheres to and is not incompatible with the founding of The Ikoku Philanthropies, originating mission and purposes, and Founding and Governing Code of Ethics, most especially our concern and protections for confidentiality and privacy.
Critical for Achieving Protection by Default
the above position and strict requirements for exception are critical for attaining and maintaining standards for data and information protection by default — also understood as one of our key principles for protection of you and other natural and legal persons concerned.*

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

*you may learn more about the principles of protection and security by design and by default on this Policy page under Principles of Protection and Security; similarly, you may learn more about the principles of confidentiality and privacy by design and by default on this Policy page under Principles of Confidentiality and Privacy.

Principles of Privacy and Confidentiality

Below are subsequent criteria The Ikoku Philanthropies should follow to maintain privacy and confidentiality when processing data and information attributable to, identifying or otherwise relating to you. It should be understood that The Ikoku Philanthropies determines processing to be private and confidential — and thus the principles of privacy and confidentiality to be adequately addressed — only if and to the extent that all of the following apply:

Privacy and Confidentiality as Absolute Rights of Persons
all involved understand the rights to privacy and to confidentiality as themselves fundamental and absolute rights of you — as the natural or legal person concerned.
Processing that Respects Privacy and Confidentiality of Persons
the processing of personal data and information protects and respects the privacy and confidentiality of you — as the natural or legal person concerned.
Privacy and Confidentiality as Effect via Technology Neutrality
the processing of personal data and information confers, as an effect, privacy and confidentiality with respect to you — as the natural or legal person concerned — that is technology neutral, sought and ensured to the same and equivalent extent, regardless of the means, measures and methods involved.
Privacy and Confidentiality as Effect via Purpose Neutrality
the processing of personal data and information confers, as an effect, privacy and confidentiality with respect to you — as the natural or legal person concerned — that is purpose neutral, sought and ensured to the same and equivalent extent, regardless of the purposes.
Protection from Risks to Privacy and Confidentiality of Persons
the processing of personal data and information is conducted by means that account for, protect and secure against risks to the privacy and confidentiality of you — as the natural or legal person concerned.
Privacy and Confidentiality as Limitation and Safeguard on Purposes and Means
therefore, the processing of personal data and information is conducted only for purposes that also respect and protect the privacy and confidentiality of you — as the natural or legal person concerned.

— and the processing of personal data and information is conducted only by means and measures that account for risks to and accordingly protect the privacy and confidentiality of you — as the natural or legal person concerned.

Privacy and Confidentiality by Design
and the processing of personal data and information defined or described as confidential, private or sensitive is conducted only by means that, by design, strictly adhere to and fulfill principles of necessity, non-identification, minimization and sensitivity with respect to you — as the natural or legal person concerned.
Privacy and Confidentiality by Default
and the processing of personal data and information defined or described as confidential, private or sensitive is conducted only by means that, by default, strictly ensure such data and information are not made accessible to any number of natural or legal persons without the consent (if permitted) and request of you — as the natural or legal person concerned.
Harmonization of Confidentiality and Privacy Expectations and Standards
the processing of personal data and information is conducted across areas, systems and technologies where the harmonization of expectations and standards for privacy and confidentiality is developed to the most feasible and reasonable extent, as described in these Codes and Policies.

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

Principles of Protection and Security

Below are subsequent criteria The Ikoku Philanthropies should follow to determine and ensure adequate levels of protection and security when processing data and information attributable to, identifying or otherwise relating to you. It should be understood that The Ikoku Philanthropies determines processing to be protective and secure — and thus the principles of protection and security to be adequately addressed — only if and to the extent that all of the following apply:

Protection as Basic Right of Persons
all involved understand data and information protection as itself a basic right with respect to you — as the natural or legal person concerned.
Protection of Rights of Persons
the processing of personal data and information protects and respects the rights of you — as the natural or legal person concerned.
Protection as Effect via Technology Neutrality
the processing of personal data and information confers, as an effect, the protection of the rights of you — as the natural or legal person concerned — that is technology neutral, sought and ensured to the same and equivalent extent, regardless of the means, measures and methods involved.
Protection as Effect via Purpose Neutrality
the processing of personal data and information confers, as an effect, the protection of the rights of you — as the natural or legal person concerned — that is purpose neutral, sought and ensured to the same and equivalent extent, regardless of the purposes involved.
Protection from Risks to Rights of Persons
the processing of personal data and information is conducted by means that account for, protect and secure against risks to the rights of you — as the natural or legal person concerned.
Protection as Limitation and Safeguard on Means and Purposes
therefore, the processing of personal data and information is conducted only for purposes that respect and protect the rights of you — as the natural or legal person concerned.

— and the processing of personal data and information is conducted only by means and measures that account for the risks to and accordingly protect the rights of you — as the natural or legal person concerned.

Protection by Design
and the processing of personal data and information is conducted only by means that, by design, adhere to and fulfill principles of necessity, non-identification, minimization and sensitivity with respect to you — as the natural or legal person concerned.*
Protection by Default
and the processing of personal data and information is conducted only by means that, by default, require that personal data and information are not made accessible to an indefinite number of natural or legal persons, unless with the request and consent of you — as the natural or legal person concerned.
Security and Protection of Data and Information
the processing of personal data and information is conducted on data and information sets that are themselves protected and secured, and enjoy the above protections, via adequate and effective measures and safeguards.
Security and Protection of Means and Methods
the processing of personal data and information is conducted by means that are themselves protected and secured, and enjoy the above protections, via adequate and effective measures and safeguards.
Assessment of Protection and Security Measures
the measures developed and implemented to ensure the above protection and security are assessed for their adequacy and effectiveness.
Harmonization of Protections and Security
the processing of personal data and information is conducted across areas, systems and technologies where the harmonization of protections and security is developed to the most feasible and reasonable extent, as described in these Codes and Policies.

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

*As a clarifying indication of how highly protective measures should be, even under conditions of informed consent (or assent): note that applying the principles of necessity, non-identification, minimization and sensitivity insists that mechanisms for performance and security-related review or testing at The Ikoku Philanthropies should still normally be developed and conducted without resorting to personal profiling, surveillance or tracking.

Principle of Sensitivity

Below are subsequent criteria The Ikoku Philanthropies should follow to determine and ensure stricter protections for sensitivity when processing sensitive personal data and information attributable to, identifying or otherwise relating to you. It should be understood that The Ikoku Philanthropies determines processing to be sensitive — and thus the principle of sensitivity to be adequately addressed — via a four-part evaluation.

The first consists of a definition of sensitivity — which helps The Ikoku Philanthropies determine or decide whether and what to treat as sensitive personal data and information:

Determination of Sensitivity via Risks to Civil and Fundamental Rights of Persons
“sensitive data and information” include personal data and information where a breach in protection or security of the data and information — or of their processing — produces an especially high risk to the civil liberties and basic, civil and fundamental rights of the natural or legal person concerned.

— note that this determination is often legal and situational in nature, since it derives from political contexts and various societies’ laws to protect people from discriminatory effects.

Determination of Sensitivity via Risks for Identity Theft
“sensitive data and information” include personal data and information where a breach in protection or security of the data and information — and of their processing — produces an especially high risk and capacity for harm to the natural or legal person concerned in the case of identity theft.

— note that this determination is often focused on authentication, financial and government-issued credential data and information, for reasons of the likely impact of identity theft using such materials.

Determination of Sensitivity via Risks of Private and Confidential Access
“sensitive data and information” include personal data and information derived 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.

— note that this determination is often focused on means of access and other processing that either by definition cannot, or are highly unlikely to, avoid violating our strict protections for privacy and confidentiality. Please see our discussion of its implications for The Ikoku Philanthropies under the Policy on Corporate Responsibility.

Determination of Sensitivity via Demarcation
The Ikoku Philanthropies also confers a determination of sensitivity for personal data and information demarcated, described or discussed as “confidential,” “private” or “sensitive” — as defined under Confidentiality and Privacy on the main Policies page.
Working List of Sensitive Data
and for a working list of data and information The Ikoku Philanthropies has determined to be sensitive see those delineated under Sensitive Data and Information on the main Policies page.

The second part of the evaluation for sensitivity and for the protection of sensitive personal data and information is a statement of the Policy’s default (or normative) position — which is to prohibit the processing of sensitive personal data and information attributable to, identifying or otherwise relating to you:

Default Prohibition of Processing Sensitive Data and Information
any access or other processing of “sensitive data” and “sensitive information” — as they are defined and delineated in these Codes and Policies — is prohibited.
Critical for Confidentiality, Privacy and Protection by Default
note that the above prohibition, as well as the very narrow exception this Policy will later describe, are critical for attaining and maintaining our standards for data and information protection, confidentiality and privacy by default — part of two key principles for ensuring adequate protections of you and other natural and legal persons concerned.*

The third part of the evaluation for sensitivity and for the protection of sensitive personal data and information is a statement of the narrow exception The Ikoku Philanthropies shall be expected to consider and possibly allow, as well as the conditions for such review:

Exception to Prohibition of Processing Sensitive Data and Information
The Ikoku Philanthropies shall be expected to consider and allow the processing of sensitive personal data and information only if and where all of the following requirements are met:
Where Data and Information Principles, Rights and Responsibilities Fulfilled
where all of the principles, rights and responsibilities of personal data and information are and will remain fulfilled.
Where Your Giving Consent is Permitted
and where there is no applicable guideline, law or regulation prohibiting you — as the natural or legal person concerned — from giving your consent to the processing of the sensitive personal data and information, for the explicit, legitimate, specific purpose for which your consent is being asked or renewed.
Rigorous Risks Assessment and Protections
where there is, especially, rigorous assessment of anticipated risks, then protections implemented to ensure, as much as possible, minimal risk to you — the natural or legal person concerned.
Protections Against Undue Coercion or Inducement
where there is also rigorous assessment of anticipated risks of undue coercion or inducement, then protections implemented to eliminate or minimize the prospect of offering direct or indirect benefits of such a magnitude as to impair your ability to weigh the risks of the processing of the personal data and information against the value of your participation — as the natural or legal person concerned.
Protections Against Risks on Disclosure
where there is, too, rigorous assessment of anticipated risks, then protections implemented to minimize any harms upon breach or disclosure, including those which place you — as the natural or legal person concerned — at risk of civil or criminal liability, of stigmatization and ostracization, or of damage to your educational advancement, employability, financial standing or reputation.
Rigorous Non-Identification of Data and Information
where all data and information obtained are accessed and otherwise processed by means that rigorously fulfill the principle of non-identification — with irreversible anonymization and aggregation preferred — so your identity cannot be ascertained, directly or indirectly through identifiers linked to you.
Rigorous Re-Identification of Data and Information
provided that whenever data and information are accessed and otherwise processed in such a manner that your identity can be ascertained, directly or indirectly through identifiers linked to you, The Ikoku Philanthropies, or any other processor, rigorously adheres to protective protocols reviewed by the DRB specifically for the processing prior to its approval.
Then For Your Own Purposes as Delineated, Restricted and Consented
and also where the sensitive personal data and information are expressly and manifestly made accessible or public by you — as the natural or legal person concerned — for your own consented, explicit and sole purposes of communication, banking or other financial servicing, crediting or acknowledgement, publicity, storage or access, and where necessary your own use as part of application, authentication, login or security procedures you conduct or participate in on an authorized part, product, service or site of The Ikoku Philanthropies.
A High and Protective Bar
note the comparatively high and protective bar being set — to first make certain that we can fulfill all principles, rights, responsibilities; to then make sure you are even permitted to consent; and then to — initially — restrict the purposes for which you can consent to processing the sensitive personal data and information.

The fourth part of the evaluation for sensitivity and for the protection of sensitive personal data and information consists of a set of request situations The Ikoku Philanthropies expects to receive, asking to be added to the above narrow exception, and this Policy’s further expectation that The Ikoku Philanthropies shall typically decide to either (a) insist on review and consent via the conditions delineated above or (b) insist on review and consent via the conditions delineated above and additional regulation:

Where Academia is Overriding or Primary
where an academic argument, interest, need or purpose is the overriding or primary purpose for the processing, The Ikoku Philanthropies shall determine that such argumentation, interests, needs and purposes cannot themselves be considered lawful or legitimate and so cannot override the consent decisions, interests or protections of you — as the natural or legal person who is a subject of, or identifiable by, the sensitive personal data and information. The Ikoku Philanthropies therefore strictly prohibits any processing of sensitive personal data and information — as well as funding or supporting such processing — for solely such purposes.
Where News or Journalism is Overriding or Primary
where a news or journalism or broad or specific public argument, interest, need or purpose is the overriding or primary purpose for the processing, The Ikoku Philanthropies shall determine that such argumentation, interests, needs and purposes cannot themselves be considered lawful or legitimate and so cannot override the consent decisions, interests or protections of you — as the natural or legal person who is a subject of, or identifiable by, the sensitive personal data and information. The Ikoku Philanthropies therefore strictly prohibits any processing of sensitive personal data and information — as well as funding or supporting such processing — for solely such purposes.
Where Public Benefit is Overriding or Primary
where a broad or specific public benefit argument, interest, need or purpose is the overriding or primary purpose for the processing, The Ikoku Philanthropies shall determine that such argumentation, interests, needs and purposes cannot themselves be considered lawful or legitimate and so cannot override the consent decisions, interests or protections of you — as the natural or legal person who is a subject of, or identifiable by, the sensitive personal data and information. The Ikoku Philanthropies therefore strictly prohibits any processing of sensitive personal data and information — as well as funding or supporting such processing — for solely such purposes.
Where Public Health is Overriding or Primary
where a public health argument, benefit, interest, need or purpose is the overriding or primary purpose for the processing, The Ikoku Philanthropies shall determine that such argumentation, benefit, interests, needs and purposes cannot themselves be considered lawful or legitimate and so cannot override the consent decisions, interests or protections of you — as the natural or legal person who is a subject of, or identifiable by, the sensitive personal data and information. The Ikoku Philanthropies therefore strictly prohibits any processing of sensitive personal data and information — as well as funding or supporting such processing — for solely such purposes. The Ikoku Philanthropies further strongly urges — on successful review and consent under the above narrow exception conditions — that every possible measure be taken to conduct and apply for and receive funding for such public health work without recourse to accessing or otherwise processing sensitive personal data and information, and where such access or other processing proves necessary, to meet additional requirements via internal review board policies, processes and practices that the Founder, Alvan Azinna Ikoku, and The Ikoku Philanthropies shall develop, authorize and provide.
Where Health, Medical or Scientific Research is Overriding or Primary
where health, medical or scientific research is the overriding or primary purpose for the processing, The Ikoku Philanthropies shall determine that such argumentation, benefit, interests, needs and purposes cannot themselves be considered lawful or legitimate and so cannot override the consent decisions, interests or protections of you — as the natural or legal person who is a subject of, or identifiable by, the sensitive personal data and information. The Ikoku Philanthropies therefore strictly prohibits any processing of sensitive personal data and information — as well as funding or supporting such processing — for solely such purposes. The Ikoku Philanthropies further strongly urges — on successful review and consent under the above narrow exception conditions — that every possible measure be taken to conduct and apply for and receive funding for such health, medical and scientific research without recourse to accessing or otherwise processing sensitive personal data and information, and where such access or other processing proves necessary, to meet additional requirements via internal review board policies, processes and practices that the Founder, Alvan Azinna Ikoku, and The Ikoku Philanthropies shall develop, authorize and provide.
Where Health or Medical Care or Service is Overriding or Primary
where health or medical care or services is the overriding or primary purpose for the processing, The Ikoku Philanthropies shall determine that such argumentation, benefit, interests, needs and purposes cannot themselves be considered lawful or legitimate and so cannot override the consent decisions, interests or protections of you and the assent processes for you — as the natural or legal person who is a subject of, or identifiable by, the sensitive personal data and information. The Ikoku Philanthropies therefore strictly prohibits any processing of sensitive personal data and information — as well as funding or supporting such processing — for solely such purposes. The Ikoku Philanthropies further strongly urges — on successful review and consent under the above narrow exception conditions — that every possible measure be taken to conduct and apply for and receive funding for such health and medical care and services without recourse to accessing or otherwise processing sensitive personal data and information, and where such access or other processing proves necessary, to meet additional requirements via internal review board policies, processes and practices that the Founder, Alvan Azinna Ikoku, and The Ikoku Philanthropies shall develop, authorize and provide.
Where Legal or Social Work or Service is Overriding or Primary
where legal or social work or service is the overriding or primary purpose for the processing, The Ikoku Philanthropies shall determine that such argumentation, benefit, interests, needs and purposes cannot themselves be considered lawful or legitimate and so cannot override the consent decisions, interests or protections of you — as the natural or legal person who is a subject of, or identifiable by, the sensitive personal data and information. The Ikoku Philanthropies therefore strictly prohibits any processing of sensitive personal data and information — as well as funding or supporting such processing — for solely such purposes. The Ikoku Philanthropies further strongly urges — on successful review and consent under the above narrow exception conditions — that every possible measure be taken to conduct and apply for and receive funding for such legal and social work and service without recourse to accessing or otherwise processing sensitive personal data and information, and where such access or other processing proves necessary, to meet additional requirements via internal review board policies, processes and practices that the Founder, Alvan Azinna Ikoku, and The Ikoku Philanthropies shall develop, authorize and provide.
Where NonProfit Civic Liberties and Rights Service is Overriding or Primary
where nonprofit civic liberties and rights service is the overriding or primary purpose for the processing, The Ikoku Philanthropies shall determine that such argumentation, benefit, interests, needs and purposes cannot themselves be considered lawful or legitimate and so cannot override the consent decisions, interests or protections of you — as the natural or legal person who is a subject of, or identifiable by, the sensitive personal data and information. The Ikoku Philanthropies therefore strictly prohibits any processing of sensitive personal data and information — as well as funding or supporting such processing — for solely such purposes. The Ikoku Philanthropies further strongly urges — on successful review and consent under the above narrow exception conditions — that every possible measure be taken to conduct and apply for and receive funding for such nonprofit civic liberties and rights service without recourse to accessing or otherwise processing sensitive personal data and information, and where such access or other processing proves necessary, to meet additional requirements via internal review board policies, processes and practices that the Founder, Alvan Azinna Ikoku, and The Ikoku Philanthropies shall develop, authorize and provide.
Where an Agreement, Contract, Employment, Independent Contractorship, Third Party Arrangement or Volunteering is Expected or Requested
where there is an expectation or request for an agreement, contract, employment, independent contractorship, third party arrangement or volunteering to be considered or made, The Ikoku Philanthropies shall determine that any attendant argumentation, benefit, interests, needs and purposes cannot themselves be considered lawful or legitimate and so cannot override the consent decisions, interests or protections of you and assent processes by you — as the natural or legal person who is a subject of, or identifiable by, the sensitive personal data and information. The Ikoku Philanthropies therefore strictly prohibits any processing of sensitive personal data and information — as well as funding or supporting such processing — for solely such purposes. The Ikoku Philanthropies further strongly urges — on successful review and consent under the above narrow exception conditions — that every possible measure be taken to make and request such agreement, contract, employment, independent contractorship, third party arrangement or volunteering considerations without recourse to accessing or otherwise processing sensitive personal data and information, and where such access or other processing proves necessary, to meet additional and more restrictive requirements via federally-mandated ethical or internal review board policies, processes and practices that the Founder, Alvan Azinna Ikoku, and The Ikoku Philanthropies shall develop, authorize and provide.*
An Even Higher and More Protective Bar
note, now, two aspects of our response to the above situations — that almost all requests to avoid asking for and respecting your informed consent decisions are denied; and further that a special set of request situations concern purposes (health, science, human research) that compel additional regulation, even stricter protections of you as they ask for and respect your consent decisions. The Policy approach here — and the even higher and more protective bar it sets — is in keeping with many long-standing discussions and concerns about how best to continue to maintain the same level of protection in effect from anticipated risks to you and your rights, even when sensitive personal data and information is at issue.*
Critical for Confidentiality, Privacy and Protection by Default
this Policy approach to handling these request situations, as well as the insistence on the very narrow exception, are all the more critical for attaining and maintaining standards for data and information protection, confidentiality and privacy by default — part of two key principles for ensuring adequate protections of you and other natural and legal persons concerned.*
Also Critical for Confidentiality, Privacy and Protection by Design
also important is that this Policy approach — and response in certain of the above request situations — leads to additional regulation and pressures on the means, measures and methods of processing, all the more critical for attaining and maintaining standards for data and information protection, confidentiality and privacy by design — also part of two key principles for ensuring adequate protections of you and other natural and legal persons concerned.*

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

*you may learn more about the principles of protection and security by design and by default on this Policy page under Principles of Protection and Security; similarly, you may learn more about the principles of confidentiality and privacy by design and by default on this Policy page under Principles of Confidentiality and Privacy.

Principle of Reasonable Transparency

Below are the subsequent criteria The Ikoku Philanthropies should follow when addressing any communication or notification to the public or to you. It should be understood that The Ikoku Philanthropies determines such communication and notification to be reasonably transparent — and thus the principle of reasonable transparency to be adequately addressed — only if and to the extent that all of the following apply:

Easy Accessibility
such communication and notification are easily accessible for you — as the natural or legal person concerned.
Easy Understanding
such communication and notification are as concise and easy to understand as possible for you — as the natural or legal person concerned.
Clear and Plain Language and Visuals
such communication and notification use clear and plain language and, additionally, where appropriate, clear visualization.
In Writing, Electronic Form
such communication and notification are provided in writing, including where appropriate in electronic form (such as a public website).
Given Feasibility and Reasonableness
provided that — and as part of the commitment to reasonable transparency — your requests and the responses of The Ikoku Philanthropies are both feasible and reasonable with respect to cost, frequency, number, proportionate effort, technical limits and concerns for the rights of other persons concerned, including The Ikoku Philanthropies.
Given No Adverse Effects on Rights of Others
provided also that such communication and notification to you do not adversely affect the civil liberties civil rights and fundamental rights of others — particularly those of other natural or legal persons concerned, including The Ikoku Philanthropies and its Founder, Alvan Azinna Chibuzo Ikoku.
Given Necessity, Non-Identification and Minimization
provided too that such communication and notification to you adhere to and fulfill the principles of necessity, non-identification and minimization.
Given Adherence to Founding Mission and Code of Ethics
and provided that such communication and notification adhere to and not be incompatible with the founding of The Ikoku Philanthropies, originating mission and purposes, and Founding and Governing Code of Ethics, most especially the concern and protections for privacy and confidentiality.

Furthermore, where any such communication and notification is addressed to you — specifically regarding any personal data and information attributable to, identifying or otherwise relating to you — The Ikoku Philanthropies determines such communication and notification to be reasonably transparent only if and to the extent that all of the following also apply:

Reasonably Informing, Ethical Standard
such communication and notification provide to you — as the natural or legal person concerned — all the key information, in sufficient detail, that a reasonable person would want to have in order to make an informed decision about whether to permit the processing of personal data and information.

— and so the informing process does not merely provide lists of isolated facts, but instead is organized in a manner most likely to assist you — as the natural or legal person concerned — in understanding the reasons why you might or might not want to permit such processing.

Informing, Confirmation of Processing
such communication and notification provide to you — as the natural or legal person concerned — confirmation as to whether data and information attributable to, identifying or otherwise relating to you have been, are or will be accessed or otherwise processed.
Informing, Purposes of Processing
such communication and notification clearly explain to you — as the natural or legal person concerned — the explicit, legitimate and specific purpose for which data and information attributable to, identifying or otherwise relating to you have been, are or will be accessed or otherwise processed.
Informing, Duration of Processing
such communication and notification clearly explain to you — as the natural or legal person concerned — the period of time during which data and information attributable to, identifying or otherwise relating to you have been, are or will be accessed or otherwise processed.
Informing, Methods of Processing
such communication and notification clearly explain to you — as the natural or legal person concerned — the means, measures and methods by which, as well as the extent to which, data and information attributable to, identifying or otherwise relating to you have been, are or will be accessed or otherwise processed.
Informing, Recipients of Processing
such communication and notification clearly explain to you — as the natural or legal person concerned — what recipients and categories of recipients did or will receive data and information attributable to, identifying or otherwise relating to you — including any transfers to any third party, third country, governmental office or international organization.
Informing, Content of Processing
such communication and notification clearly explain to you — as the natural or legal person concerned — what categories, content and nature of data and information attributable to, identifying or otherwise relating to you have been, are or will be accessed or otherwise processed.
Informing, Processes of Non-Identification
such communication and notification clearly explain to you — as the natural or legal person concerned — whether and how identifiers have been, are or will be removed from data and information attributable to, identifying or otherwise relating to you.

— and clearly confirm and explain, whether or not other processes of non-identification have been, are or will be employed, including periodic re-identification, and if so under what circumstances and to what extent.

Informing, Future Processing of Content
such communication and notification clearly confirm to you — as the natural or legal person concerned — that whether or not such processes of non-identification are conducted, the personal data and information shall not be used for future processing, unless with additional informed consent from you.

— or such communication and notification clearly provide you — as the natural or legal person concerned — an opportunity to consent to have the personal data and information become and remain non-personal via a combination of irreversible anonymization and further transformation (such as data aggregation), after which such data and information can be used for future processing without additional informed consent from you.

Informing, Processing and Sensitivity
such communication and notification clearly confirm to you — as the natural or legal person concerned — whether sensitive data and information attributable to, identifying or otherwise relating to you (especially biospecimens) have been, are or will be accessed or otherwise processed about or from you.

— and if so, such communication also confirms and explains the consent process, protections and safeguards provided to you specifically for the sensitive data and information, and especially biospecimens.

Informing, Costs of Processing
such communication and notification clearly explain to you — as the natural or legal person concerned — any additional costs to you that may reasonably be expected from the provision or processing of data and information attributable to, identifying or otherwise relating to you.
Informing, Benefits of Processing
such communication and notification clearly explain to you — as the natural or legal person concerned — any benefits to you or to others that may reasonably be expected from the provision or processing of data and information attributable to, identifying or otherwise relating to you.
Informing, Risks of Processing
such communication and notification clearly explain to you — as the natural or legal person concerned — any risks to you or to others that may reasonably be expected from the provision or processing of data and information attributable to, identifying or otherwise relating to you.
Informing, Protections and Safeguards
such communication and notification clearly explain to you — as the natural or legal person concerned — policies, principles and standards for processing the personal data and information attributable to, identifying or otherwise relating to you, as well as the protections and safeguards in relation to the processing of the personal data and information.
Informing, Rights
such communication and notification clearly explain to you — as the natural or legal person concerned — your rights with respect to data and information attributable to, identifying or otherwise relating to you, and with respect to their processing, as well as the means and procedures for exercising your rights in relation to the personal data and information and to their processing.
Informing, Ideally Voluntary Nature of Processing
such communication and notification clearly explain to you — as the natural or legal person concerned — that the provision of data and information attributable to, identifying or otherwise relating to you, as well as their processing, should be voluntary; that refusal should involve no penalty or loss of benefits to which you are otherwise entitled; and that you should be able to discontinue your participation at any time without penalty or loss of benefits to which you are otherwise entitled.
Informing, Any Compulsory Nature of Processing
nevertheless, such communication and notification clearly confirm to you — as the natural or legal person concerned — whether the provision of data and information attributable to, identifying or otherwise relating to you, including their processing, is a contractual or statutory requirement, or a requirement necessary to enter into an agreement or contract, as well as whether you are obliged to provide the personal data and information, and the possible consequences of failure to provide the personal data and information.
No Exculpatory Language
such communication and notification contain no exculpatory language through which you — as the natural or legal person concerned — are made to waive or appear to waive any of your legal rights, or release or appear to release The Ikoku Philanthropies, or other processor of the personal data and information, from liability for negligence.
Informing, Communication about Processing
such communication and notification clearly explain to you — as the natural or legal person concerned — the procedures for obtaining confirmation and communication with respect to data and information attributable to, identifying or otherwise relating to you, as well as to their processing.
Informing, Responsible Entity, Offices or Persons
such communication and notification provide to you — as the natural or legal person concerned — the identity and contact information of the entity, office or persons responsible for the data and information attributable to, identifying or otherwise relating to you, and for their processing, including whom you are to contact for answers to pertinent questions.
Given Feasibility and Reasonableness
provided that — and as part of the commitment to reasonable transparency — your requests and the responses of The Ikoku Philanthropies are both feasible and reasonable with respect to cost, frequency, number, proportionate effort, technical limits and concerns for the rights of other persons concerned, including The Ikoku Philanthropies.
Given No Adverse Effects on Rights of Others
provided also that such communication and notification to you — as the natural or legal person concerned — whether pertaining to data and information or their processing, do not adversely affect the civil liberties and basic, civil and fundamental rights of others — particularly those of other natural or legal persons concerned, including The Ikoku Philanthropies and its Founder, Alvan Azinna Chibuzo Ikoku.
Given Necessity, Non-Identification and Minimization
provided too that such communication and notification to you — as the natural or legal persons concerned — whether pertaining to the data and information or their processing, adhere to and fulfill the principles of necessity, non-identification and minimization.
Given Adherence to Founding Mission and Code of Ethics
and provided that such communication and notification adhere to and is not incompatible with the founding of The Ikoku Philanthropies, originating mission and purposes, and Founding and Governing Code of Ethics, most especially the concern and protections for confidentiality and privacy.

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

Principle of Commensurability

The principle of commensurability and its criteria delineated below are followed by The Ikoku Philanthropies in recognition of the likelihood that contexts will arise where it seems that two or more interests, persons, principles, rights or responsibilities render the fulfillment of data and information policies incommensurable, when they do not. The Ikoku Philanthropies feels that where it is asserted that there is no common basis for the comparison of policy claims or injunctions, other much less fair or ideal approaches take the place vacated by prior information and notice, managed expectations, analysis and deliberation, consideration, discernment, judgment and respect. It is better, therefore, to assert the existence of, and clarify a rubric for, just such a common basis at The Ikoku Philanthropies. It consists of the following:

Prior User Agreement as Starting Point
on the part of every natural and legal person involved, there is a prior Agreement — as delineated and described in these Codes and Policies — to use or visit, partake of, participate in, benefit from, be supported by or work for any part or section of The Ikoku Philanthropies, and such Agreement is the starting point of any activity under review.
Prior Agreement to Not Violate Protections of The Ikoku Philanthropies or its Founder
and on the part of every natural and legal person involved, there is an attendant prior Agreement — also delineated and described in these Codes and Policies — to not violate the rights and protections of The Ikoku Philanthropies or its Founder, Alvan Azinna Chibuzo Ikoku in any activity, operation or decision during review, and where so, have remedying such violations be critically important, prioritized and conducted to the most feasible and reasonable extent.
Prior Approval and Authorization of Proceedings
and on the part of every natural and legal person involved, there is an attendant prior Agreement — also delineated and described in these Codes and Policies — that any action, activity, operation, or proceeding pertaining to commensurability or equivalent resolution have prior written approval and authorization of the Founder of The Ikoku Philanthropies, Alvan Azinna Chibuzo Ikoku, and that no such action, activity, operation, or proceeding may be begun, conducted, supervised or otherwise administered by an external or independent entity.
Prior Limitation of Scope
and on the part of every natural and legal person involved, there is an attendant prior Agreement — also delineated and described in these Codes and Policies — to limit the scope of any action, activity, operation, or proceeding pertaining to commensurability or equivalent resolution only to questions of data and information handling, narrowly defined — namely, issues involving access and other processing of personal data and information attributable to, identifying or otherwise relating to a specific natural or legal person who is among the employees, personnel, partners, third-parties, users, visitors, volunteers and other agents of The Ikoku Philanthropies, narrowly defined, engaging or functioning in an allowed, approved and authorized area, capacity and manner — and to not have the scope of such proceedings entail other issues, matters, questions, remedies or rights.
Reasonable Transparency and Being Informed
with all of the above sufficiently met, The Ikoku Philanthropies proceeds by determining that communication and notification regarding the activities and operations of processing — including the access and your provision of personal data and information — are themselves reasonably transparent and informing before, during and after such processing or provision, and thus fulfill the principles of transparency and your rights to being informed, permitting, among other things, opportunities for informed consent and for later reviewing consent decisions by you — as the natural or legal person concerned.
Broad Prohibition for Improperly Consented Activity
The Ikoku Philanthropies also proceeds by ensuring there is a broad prohibition of improperly — or not reasonably informed — consented activity before, during and after the processing of personal data and information, and where so, has remedying such situations be prioritized and conducted to the most feasible and reasonable extent.
Broad Prohibition and Narrow Exceptions for Unconsented Activity
The Ikoku Philanthropies follows the above principle of broad prohibition, with very narrow and strict exceptions for the conduct of processing personal data and information without consent — and so The Ikoku Philanthropies subjects all such processing activities and operations involving or otherwise relating to persons concerned to reasonably informing consent and assent processes — and where there is any inadequacy in this regard, has remedying such situations be prioritized and conducted to the most feasible and reasonable extent.
Broad Prohibition of Unjust and Unlawful Processing
The Ikoku Philanthropies also proceeds by ensuring the activities and operations of processing — including the access and your provision of personal data and information — are themselves just and lawful before, during and after your participation, and thus fulfill the principles, rights and responsibilities of data and information, especially those pertaining to lawfulness and justice — and where there is any inadequacy in this regard, has remedying such situations be prioritized and conducted to the most feasible and reasonable extent.
Broad Prohibition for Diminishment of Protections
The Ikoku Philanthropies also proceeds by ensuring the activities and operations of processing — including the access and your provision of personal data and information — are themselves protective before, during and after your participation, and thus fulfill the protective principles, rights and responsibilities of data and information, especially those pertaining to harm, non-identification, minimization, necessity, protection and sensitivity — and where there is any inadequacy in this regard, has remedying such situations be prioritized and conducted to the most feasible and reasonable extent.
Prohibition of Violations of Basic and Fundamental Rights
The Ikoku Philanthropies ascertains that there are no violations of civil liberties or basic or fundamental rights of natural or legal persons concerned — especially the principle for sensitivity — in any activities or operations of processing, including the access and your provision of personal data and information — and where so, has remedying such violations be prioritized and conducted to the most feasible and reasonable extent.
Prohibition of Violations of Confidentiality and Privacy Rights
The Ikoku Philanthropies ascertains that there are no violations of confidentiality or privacy rights of natural or legal persons concerned in any activities or operations of processing, including the access and your provision of personal data and information — and where so, has remedying such violations be prioritized and conducted to the most feasible and reasonable extent.
Prohibition of Violations of Property and Proprietary Rights
The Ikoku Philanthropies ascertains that there are no violations of property and proprietary rights of natural or legal persons concerned in any activities or operations of processing, including your own access to and provision of personal data and information — and where so, has remedying such violations be prioritized and conducted to the most feasible and reasonable extent.
Limitation and Minimization Where Harm is Established or Imminent
throughout any review, The Ikoku Philanthropies ascertains that no harm to any natural or legal person is established or imminent in any activities or operations of processing, including the access and your provision of personal data and information — and where so, has eliminating and remedying such harm and its imminence be critically important, prioritized and conducted to the most feasible and reasonable extent.
Errors, Violations and Fruits of the Poisonous Tree
where errors or violations are determined, remedying them involves prioritized attention to historical order of error, offense or violation and then  — to the extent appropriate and feasible — application of the “fruit of the poisonous tree” concept, entailing a depositing of processing materials, including personal data and information with The Ikoku Philanthropies to provide opportunities for The Ikoku Philanthropies and the natural or legal person concerned to make consented decisions and exercise their data and information rights; the depositing, too, with The Ikoku Philanthropies of any benefits accrued via the erroneous or violating activity or operation of processing, including the personal data and information themselves; and where the violation is intentional, a relinquishing by the violator of any role in the remedying process.
Where Non-Identification is Resolving
with the above taking precedence and guaranteed, but where review of cases with supposed incommensurability is still needed, The Ikoku Philanthropies also ascertains whether and how commensurability can be had via processes of necessity, minimization and non-identification — and where so, has the processes of further minimization and non-identification (ideally up to irreversible anonymization and aggregation) be conducted to the most feasible and reasonable extent with the written agreement and consent of all the primary natural or legal persons concerned.
Given Adherence to Founding Mission and Code of Ethics
provided that any actions, decisions, determinations and processing pertaining to activities or operations of processing or personal data and information, including during review for commensurability, adhere to and not be incompatible with the founding of The Ikoku Philanthropies, originating mission and purposes, and Founding and Governing Code of Ethics, and these Codes and Policies.
Incentives Toward Ethical, Respectful and Non-Identifying Processing
and provided that the remedying of such cases result in incentives and disincentives toward the enjoyment of respect for persons — as described in these Codes and Policies — which includes, where appropriate, adopting respectful minimization and non-identification methods that (a) are and were never personal; (b) are encrypted; (c) have undergone immediate or soon-after irreversible anonymization and aggregation; (d) are under secured pseudonymization; or (d) are under secured de-identification.

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

B — Basic Rights

The Rights of Personal Data and Information

The above principles of processing also provide you — as the natural or legal person concerned — fifteen (15) overarching rights of personal data and information. The Ikoku Philanthropies should fulfill, respect and help you exercise such rights when accessing or otherwise processing personal data and information attributable to, identifying, or otherwise relating to you. The Policy will elaborate in some detail upon each of these rights as you proceed on this page. In the meantime do keep in mind two opening points to be made here.

First, that the exercising of any freedoms, liberties or rights — and the fulfillment of any principles and responsibilities — shall not confer or entail any right of access to The Ikoku Philanthropies or The Ikoku Philanthropies Administration (or any correlative rights, duties and obligations concerning any equivalent access, level of openness or transparency) to any natural or legal person other than the Founder, Alvan Azinna Chibuzo Ikoku.

And second, that, given the aforementioned, and as much as feasibly and reasonably possible, The Ikoku Philanthropies endeavors to have processing of personal data and information fulfill all of your following rights:

Rights to Be Informed
rights to be reasonably informed of data and information attributable to, identifying or otherwise relating to you.
Rights Concerning Data and Information from and about Persons
rights to be reasonably informed of personal data and information that have been, are or will be processed from, about or otherwise relating to you.
Rights Concerning Data and Information via Automation
rights to not be subject to and also to be reasonably informed of personal data and information that have been, are or will be processed via automation and automated methods, including automated individual decision-making and profiling.
Rights to Consent
rights to consent and to the reasonably informing consent process.
Rights to Confidentiality
rights to confidentiality, to the confidentiality of confidential, personal and sensitive data and information, and rights to confidential conversation.
Rights to Privacy
rights to privacy, to the privacy of private, personal and sensitive data and information, and absolute rights to private conversation and to private thoughts.
Rights to Protection, Safety and Security
rights to have personal data and information attributable to, identifying or otherwise relating to you processed by means that ensure adequate protection, safety and security.
Rights to Ensure and Verify
rights to reasonably ensure and verify the fulfillment of principles, rights and responsibilities with respect to personal data and information attributable to, identifying or otherwise relating to you.
Rights of Access
rights to reasonable access to personal data and information attributable to, identifying or otherwise relating to you.
Rights to Portability
rights to reasonable portability of personal data and information attributable to, identifying or otherwise relating to you.
Rights to Correction and Rectification
rights to reasonable correction of personal data and information attributable to, identifying or otherwise relating to you.
Rights to Erasure
rights to reasonable erasure of personal data and information attributable to, identifying or otherwise relating to you.
Rights to Object
rights to reasonable objections and stoppage with respect to personal data and information attributable to, identifying or otherwise relating to you.
Rights to Restrict Processing
rights to reasonable restriction of processing of personal data and information attributable to, identifying or otherwise relating to you.
Rights to Notification
rights to reasonable notification of other persons upon decisions to correct, erase or restrict processing of personal data and information attributable to, identifying or otherwise relating to you.

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

Rights to Be Informed

As the natural or legal person concerned, you shall have the rights to be reasonably informed — solely by The Ikoku Philanthropies — regarding the processing and other aspects of data and information attributable to, identifying or otherwise relating to you. Such rights include all of the following:

Processing Data and Information from Persons
your right to receive transparent communication that reasonably informs you — as the natural or legal person concerned — regarding data and information that have been, are or will be processed directly from you.
Processing Data and Information about Persons
your right to receive transparent communication that reasonably informs you — as the natural or legal person concerned — regarding data and information that have been, are or will be processed about or relating to you.
Processing Data and Information via Automation
your right to receive transparent communication that reasonably informs you — as the natural or legal person concerned — regarding data and information that have been, are or will be processed from or about you by means of automation and automated methods, including but not limited to automated individual decision-making and profiling.
Data and Information Rights of Persons
your right to receive transparent communication that reasonably informs you — as the natural or legal person concerned — regarding all your personal data and information rights, and the means and procedures for exercising those rights.
Facilitating the Exercising of Data and Information Rights
your right to receive transparent communication that helps you — as the natural or legal person concerned — exercise your personal data and information rights.
Where Non-Identification is Confirmed
your right to receive such reasonably informing communication unless The Ikoku Philanthropies demonstrates that it is not in the position to identify you or to connect you to the personal data and information in question.

— where non-identification is confirmed, your right to receive notification of the situation — as the potential or supposed natural or legal person concerned.

— upon receiving the above notification, your right to be given an opportunity to provide additional information that identifies you and connects you to the personal data and information in question; and where so, your right to have The Ikoku Philanthropies proceed as described under the section Principle of Non-Identification.

Progress in the Exercising of Data and Information Rights
your right to receive transparent communication that updates you — as the natural or legal person concerned — without unreasonable delay, regarding progress in exercising your personal data and information rights.
Decisions in the Exercising of Data and Information Rights
your right to receive transparent communication that reasonably informs you — as the natural or legal person concerned — regarding decisions as to (a) whether any action is being taken upon your request to exercise a personal data and information right; (b) if so, the action taken and the reasons or rationale; (c) if not, the action not taken and the reason or rationale; and (d) in either case, possibilities for acceptance and closure, appeal, complaint, further review or otherwise seeking remedy.
Frequency and Period of Informing Process
your right to have this reasonably informing process available to you — as the natural or legal person concerned — without cost twice every twelve (12) months, and to have such reasonably informing communication cover clearly demarcated periods of data and information processing that include the twelve (12) preceding months.

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

Rights of Data and Information from and about Persons

As the natural or legal person concerned, you shall have the rights to be reasonably informed — solely by The Ikoku Philanthropies — regarding the processing and other aspects of data and information attributable to, identifying or otherwise relating to you. You shall have the rights to be thusly informed where such data and information are provided by you and processed from, about or relating to you. Such rights therefore include all of the following:

Reasonably Informing, Confirmation of Processing
to receive transparent communication that confirms to you — as the natural or legal person concerned — that data and information attributable to, identifying or otherwise relating to you have been, are or will be processed.
Reasonably Informing, All Aspects of Processing
your right to receive transparent communication that reasonably informs you — as the natural or legal person concerned — regarding all aspects of the processing, as delineated and described under the section Principle of Transparency.
Informing, Method of Processing
your right to receive transparent communication that confirms to you — as the natural or legal person concerned — whether the processing of data and information entails automation and automated methods, and where so, your right to have The Ikoku Philanthropies further inform you as described under the section Rights Concerning Data and Information via Automation.
Informing, Risks of Processing
your right to receive transparent communication that confirms to you — as the natural or legal person concerned — whether The Ikoku Philanthropies’s assessment of risks from processing leads to a determination of high risk, and if so, your right to confirmation that The Ikoku Philanthropies has prohibited such processing, unless a data processing risks assessment has been specifically conducted, with concerns addressed and risks minimized, as described under the section Responsibilities for Risk.
Informing, Further Communication, Discussion and Contact
your right to receive transparent communication that provides you — as the natural or legal person concerned — sufficient period of time and opportunity to ask questions and discuss concerns, the means for ongoing communication and notification, and the identity and contact details of the offices, persons and representatives responsible for the data and information concerning you and for their processing.

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

Rights of Data and Information via Automation

As the natural or legal person concerned, you shall have the rights — to not be subject to — and also to be reasonably informed by The Ikoku Philanthropies regarding personal data and information processed via automation or automated methods, including automated individual decision-making and profiling. You shall have the rights to thusly refuse and to be thusly informed especially where such automated methods and processing have a legal or similarly significant effect concerning you. Such rights therefore include all of the following:

Reasonably Informing, Confirmation of Automation or Automated Methods
your right to receive transparent communication that confirms to you — as the natural or legal person concerned — whether data and information from, about or otherwise relating to you have been, are or will be processed via automation or automated methods, including automated individual decision-making and profiling.
Reasonably Informing, All Aspects of Processing
your right to receive transparent communication delineating and describing to you — as the natural or legal person concerned — regarding all aspects of such processing, as delineated and described under the section Principle of Transparency.
Informing, Confirmation of Absence of a Child
your right to receive transparent communication that confirms to you — as the natural or legal person concerned — the absence and non-involvement of a child (including yourself) with respect to the personal data and information in question that have been, are or will be processed via automation and automated methods.

— and where a child is involved, your right to further confirmation that such processing is strictly prohibited, to notification of its stoppage, to remedy where applicable, and to further communication pertaining to your rights to ensure and verify and to object and stop such processing.

Informing, Confirmation of Absence of Sensitivity
your right to receive transparent communication that confirms to you — as the natural or legal person concerned — the absence of sensitive data and information from, about or otherwise relating to you in the proposed or reported processing via automation or automated methods.

— and where such sensitive data and information are involved, your right to receive further confirmation that such processing is prohibited, unless you are permitted to consider and give informed consent, as described under the section Principle of Sensitivity.

— and where the above also entails extensive or systematic review of natural persons or special categories of natural persons, your right to receive further confirmation that such processing is prohibited, unless a data processing risks assessment has also been specifically conducted, with concerns addressed and risks minimized, as described under the section Responsibilities for Risk.

Informing, Methods of Automated Processing
your right to receive transparent communication delineating and describing to you — as the natural or legal person concerned — how any data and information from, about or otherwise relating to you have been, are or will be processed via automation or automated methods — containing meaningful information about the algorithm or equivalent logic involved, as well as the significance and envisaged consequences of employing the algorithm or equivalent logic for you.

— and if logic, measures or methods involved are new, your right to further confirmation that such processing is prohibited, unless a data processing risks assessment has been specifically conducted, with concerns addressed and risks minimized, as described under the section Responsibilities for Risk.

Informing, Publicly Accessible Areas
your right to receive transparent communication delineating and describing to you — as the natural or legal person concerned — whether the above proposed or reported research, investigation or processing by means of automation and automated methods involves publicly accessible areas.

— and if involving publicly accessible areas, your right to confirmation that The Ikoku Philanthropies has prohibited such processing, unless a data processing risks assessment has been specifically conducted, with concerns addressed and risks minimized, as described under the section Responsibilities for Risk.

Informing, Legal or Significant Effects of Automated Processing
your right to receive transparent communication delineating and describing to you — as the natural or legal person concerned — the legal or similarly significant effects of having the data and information from, about or otherwise relating to you processed via automation and automated methods.

— and if there are such effects, your right to further confirmation that such processing is prohibited, unless a data processing risks assessment has been specifically conducted, with concerns addressed and risks minimized, as described under the section Responsibilities for Risk.

Informing, Scale of Automated Processing
your right to receive transparent communication delineating and describing to you — the scale and size of the data and information from, about or otherwise relating to you that have been, are or will be processed via automation and automated methods, and the scale and size of such processing itself.

— and if large-scale, your right to further confirmation that such processing is prohibited, unless a data processing risks assessment has been specifically conducted, with concerns addressed and risks minimized, as described under the section Responsibilities for Risk.

Informing, Risks of Automated Processing
your right to receive transparent communication delineating and describing to you — as the natural or legal person concerned — the risks to you of having the data and information from, about or otherwise relating to you processed via the proposed or reported automated individual decision-making, including profiling.

— and if high risk is determined, your right to further confirmation that such processing is prohibited, unless a data processing risks assessment has been specifically conducted, with concerns addressed and data and risks minimized, as described under the section Responsibilities for Risk.

Informing, Consent to Automated Processing
your right to receive transparent communication providing you — as the natural or legal person concerned — the opportunity to give and withdraw consent, as described and required in these Codes and Policies, to prior, present or future processing of data and information from, about or otherwise relating to you via automation and automated methods.
Informing, Decisions via Automated Processing
your right to receive transparent communication regarding, describing and explaining any decisions made or reached via automation and automated methods that have processed, are processing or will process data and information from, about or otherwise relating to you — as the natural or legal person concerned.
Informing, Data Rights and Exercising Them
your right to receive transparent communication confirming, delineating, describing and providing to you — as the natural or legal person concerned — the means and procedures to exercise all of your personal data rights in relation to any data and information from, about or otherwise relating to you that have been, are or will be processed via automation and automated methods — as well as additional rights to challenge any decisions made via such processing, to obtain human intervention, to express your point of view, and to have your point of view documented and added to the record.
Informing, Data Accessor, Collector and Processor
your right to receive transparent communication reasonably informing you — as the natural or legal person concerned — regarding the identity and contact details of The Ikoku Philanthropies and of the office responsible for personal data and information.

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

Rights to Consent

As the natural or legal person concerned, you shall have the rights to be asked, give and withdraw informed consent to the processing of data and information attributable to, identifying or otherwise relating to you. You shall also have the right to an informing consent process, and to your knowledge of and participation in an assent process concerning you. Such rights include all of the following:

Personhood, Dignity and Legal Rights
your right to have personal data and information attributable to, identifying or relating to you — as the natural or legal person concerned — processed by means that protect and respect your personhood, dignity and attendant legal rights.
Fulfillment of Informed Consent
your right to have personal data and information attributable to, identifying or relating to you — as the natural or legal person concerned — processed by means that fulfill the requirements for informed consent, as described under the section Principle of Informed Consent.
Respect for Consent
your right to have personal data and information attributable to, identifying or relating to you — as the natural or legal person concerned — processed by means that protect and respect your consent, consent decisions and consent rights.
Respect for Withdrawal
your right to have personal data and information attributable to, identifying or relating to you — as the natural or legal person concerned — processed by means that protect and respect your withdrawal of consent.
Invalidity of Consent
your right to have personal data and information attributable to, identifying or relating to you — as the natural or legal person concerned — processed by means that protect and respect your rights to be informed of the invalidity or non-binding nature of consent asked, given or presumed.

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

Rights to Confidentiality

As the natural or legal person concerned, you shall have the rights to confidentiality before, during and after The Ikoku Philanthropies processes data and information attributable to, identifying or otherwise relating to you. You shall also have the absolute rights to confidential conversation. Such rights require that all of the following apply:

Autonomy, Dignity and Legal Rights
your right to have personal data and information attributable to, identifying or relating to you — as the natural or legal person concerned — processed in a manner that protects and respects your autonomy, dignity and attendant legal rights.
Fulfillment of Confidentiality
your right to have personal data and information attributable to, identifying or relating to you — as the natural or legal person concerned — processed by means that fulfill the requirements for confidentiality and sensitivity, as described under the section Principle of Privacy and Confidentiality.
Fulfillment of Sensitivity
your right to have personal data and information attributable to, identifying or relating to you — as the natural or legal person concerned — processed by means that fulfill the requirements for confidentiality and sensitivity, as described under the section Principle of Sensitivity.
Protection of Confidentiality
your right to have personal data and information attributable to, identifying or relating to you — as the natural or legal person concerned — processed by means that protect and respect your confidentiality and confidentiality rights, especially your absolute right to confidentiality.
Breaches and Violations of Confidentiality
your right to receive transparent communication that reasonably informs you — as the natural or legal person concerned — of confirmed breaches or violations of your confidentiality.

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

Rights to Privacy

As the natural or legal person concerned, you shall have the rights to privacy before, during and after The Ikoku Philanthropies processes data and information attributable to, identifying or otherwise relating to you. You shall also have the absolute rights to private conversation and to private thought. Such rights require that all of the following apply:

Autonomy, Dignity and Legal Rights
your right to have personal data and information attributable to, identifying or relating to you — as the natural or legal person concerned — processed in a manner that protects and respects your autonomy, dignity and attendant legal rights.
Fulfillment of Privacy
your right to have personal data and information attributable to, identifying or relating to you — as the natural or legal person concerned — processed by means that fulfill the requirements for privacy, as described under the section Principles of Privacy and Confidentiality.
Fulfillment of Sensitivity
your right to have personal data and information attributable to, identifying or relating to you — as the natural or legal person concerned — processed by means that fulfill the requirements for sensitivity, as described under the section Principle of Sensitivity.
Protection of Privacy
your right to have personal data and information attributable to, identifying or relating to you — as the natural or legal person concerned — processed by means that protect and respect your privacy and privacy rights, especially your absolute rights to private conversation and to private thought.
Breaches and Violations of Privacy
your right to receive transparent communication that reasonably informs you — as the natural or legal person concerned — of confirmed breaches or violations of your privacy.

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

Rights to Protection and Security

As the natural or legal person concerned, you shall have the rights to adequate protection, safety and security of data and information attributable to, identifying or otherwise relating to you. You shall also have the rights to protect your intellectual, real and organizational property and proprietary rights before, during and after such processing. Such rights include all of the following:

Protection as Basic Right of Persons
your right to have all involved understand  data and information protection as a basic right with respect to you — as the natural or legal person concerned.
Protection, Safety and Security of Persons
your right to have data and information attributable to, identifying or otherwise relating to you — as the natural or legal person concerned — processed by means that ensure adequate levels of protection, safety and security against harms and risks to your body, mind and self.
Protection, Safety and Security of Rights
your right to have data and information attributable to, identifying or otherwise relating to you — as the natural or legal person concerned — processed by means that ensure adequate levels of protection, safety and security against harms and risks to your rights.
Protection, Safety and Security of Processing
your right to have data and information attributable to, identifying or otherwise relating to you — as the natural or legal person concerned — processed by means that ensure adequate levels of protection, safety and security against harms and risks to the data and information.
Protection of Intellectual Property
your right to have data and information attributable to, identifying or otherwise relating to you — as the natural or legal person concerned — processed by means that support you in protecting your intellectual property and intellectual property and proprietary rights, including but not limited to copyrights, patents, trademarks and trade secrets.
Protection of Real Property
your right to have data and information attributable to, identifying or otherwise relating to you — as the natural or legal person concerned — processed by means that support you in protecting your real property and real property rights, including but not limited to reasonable prevention or remediation against exposure, leakage, loss, theft, trespassing and vandalism.
Organizational Functioning, Integrity and Property as Entities
your right to have data and information attributable to, identifying or otherwise relating to you — as the natural or legal person concerned — conducted by means that support you in protecting your organizational functioning, integrity and property and attendant rights as an entity.

— and such rights shall include but not be limited to those pertaining to administration, coordination and management; data, information and network security; development and operations for products and services; safe-keeping of accounts, books and records; and restriction of access to headquarters, offices, operations or organizational spaces or sites that are physical, technical, telecommunicative or virtual in nature.

Breaches and Violations of Protection, Safety and Security
your right to receive transparent communication that reasonably informs you — as the natural or legal person concerned — of confirmed breaches or violations of your rights to protection, safety and security as well as your property and proprietary rights.

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

Rights to Ensure and Verify

As the natural or legal person concerned, you shall have the rights to reasonably ensure and verify the fulfillment of principles and rights of processing conducted on, about or otherwise relating to you, and of data and information attributable to, identifying or otherwise relating to you. Such rights require that all of the following apply:

Process in Writing and Documentable
your right to have your request to ensure or verify, its response and any further communication proceed in writing and be accessible, documentable and reproducible in standardly legible form.
Reasonably Transparent Communication
your right to have above communication fulfill the principles, rights and responsibilities for transparency with respect to the process to ensure and verify, and to the personal data and information attributable to, identifying or otherwise relating to you.
Informing and Consenting
your right to have the above communication fulfill the principles, rights and responsibilities for consent and being informed with respect to the process to ensure and verify, and to the personal data and information attributable to, identifying or otherwise relating to you.
Facilitating the Exercise of Rights
your right to have the above communication fulfill the principles, rights and responsibilities for supporting you in exercising all of your data and information rights with respect to the personal data and information attributable to, identifying or otherwise relating to you.
Responsive and Updating Communication
your right to have the above communication be responsive to reasonable requests without undue delay, and be as informing as possible regarding progress, updates and any decisions reached, including clear reasoning or rationale.
Reaching Commensurability
your right to have further communication pertaining to this process, and to the data and information, ensure commensurability is reached in good faith upon any supposed conflict of claims.
Further Process
your right to have further communication pertaining to this process, and to the data and information, clearly explain decisions and determinations reached, delineate actions taken, and inform you — as the natural or legal person concerned — of the possibilities and means for acceptance and closure, appeal, complaint, further review or otherwise seeking remedy.
Given Feasibility and Reasonableness
provided that your requests are both feasible and reasonable with respect to cost, frequency, number, proportionate effort, technical limits and concerns for the rights of other persons concerned, including The Ikoku Philanthropies.
Given No Adverse Effect on Rights of Others
provided also that exercising these rights does not adversely affect the civil liberties and basic, civil and fundamental rights of others — especially where those others are also natural or legal persons concerned.
Given Necessity, Non-Identification and Minimization
and provided that all such communication and access granted to you — as the natural or legal person concerned — whether pertaining to this process or the personal data and information, adhere to and fulfill the principles of necessity, non-identification and data-minimization.*

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

*to offer a clarifying example of reasonably transparent communication with these principles in mind: a good response to a request to ensure and verify may include written confirmation that a limited-scope but deep review has shown specified categories of data and information collected from specified categories or users, over the past year, have been and continue to be irreversibly anonymized.

Rights to Access

As the natural or legal person concerned, you shall have the rights to reasonable access to data and information attributable to, identifying or otherwise relating to you. Such rights shall include all of the following:

Request and Obtain Access to Data
your right to request and obtain access to any of the personal data and information attributable to, identifying or relating to you — as the natural or legal person concerned.
Request and Obtain Copy of Data
your right to request and obtain a copy of any of the personal data and information attributable to, identifying or relating to you — as the natural or legal person concerned.
Reasonably Transparent Communication
your right to have The Ikoku Philanthropies provide you — as the natural or legal person concerned — reasonably transparent communication regarding progress and decisions pertaining to your access or copy requests.
Given Feasibility and Reasonableness
provided that your requests are both feasible and reasonable with respect to cost, frequency, number, proportionate effort, technical limits and concerns for the rights of other persons concerned, including The Ikoku Philanthropies.
Given No Adverse Effect on Rights of Others
provided also that exercising these rights does not adversely affect the civil liberties and basic, civil and fundamental rights of others — especially where those others are also natural or legal persons concerned.
Given Necessity, Non-Identification and Minimization
and provided that all such communication and access granted to you — as the natural or legal person concerned — whether pertaining to this process or the personal data and information, adhere to and fulfill the principles of necessity, non-identification and data-minimization.

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

Rights to Portability

As the natural or legal person concerned, you shall have the rights to reasonable portability of data and information attributable to, identifying or otherwise relating to you. Such rights shall include all of the following:

Request and Receive the Data in Readable Format
your right to request and receive personal data and information attributable to, identifying or relating to you in a structured, commonly used and machine-readable format.
Transmit or Upload the Data and Information
your right to transmit or upload — via your own means — personal data and information attributable to, identifying or relating to you.
Request for Interoperable Transfer of Data and Information
your right to request to have directly transferred — interoperably by us — personal data and information attributable to, identifying or relating to you, but only to another entity that meets the requirements delineated in these Codes and Policies, under the section Responsibilities for Approval, Authorization and Transfer.
Reasonably Transparent Communication
your right to have The Ikoku Philanthropies provide you — as the natural or legal person concerned — reasonably transparent communication and notification regarding progress and decisions pertaining to your portability or transmission requests.
Given Technical Feasibility
provided that the processing of the personal data and information is being conducted by automated means and transmission of the personal data and information is technically feasible.
Given Feasibility and Reasonableness
provided also that your requests are both feasible and reasonable with respect to cost, frequency, number, proportionate effort, other technical limits and concerns for the rights of other persons concerned, including The Ikoku Philanthropies.
Given No Adverse Effect on Rights of Others
provided too that exercising these rights does not adversely affect the civil liberties and basic, civil and fundamental rights of others — especially where those others are also natural or legal persons concerned.
Given Necessity, Non-Identification and Minimization
and provided that all such communication and portability granted to you — as the natural or legal person concerned — whether pertaining to this process or the personal data and information, adhere to and fulfill the principles of necessity, non-identification and data-minimization.

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

Rights to Correction and Rectification

As the natural or legal person concerned, you shall have the rights to have reasonably corrected — or rectified — data and information attributable to, identifying or otherwise relating to you. Such rights shall include all of the following:

Correction of Inaccuracies
your right to have any of the personal data and information attributable to, identifying or relating to you that are inaccurate or incorrect corrected or rectified without undue delay.
Completion of Data and Information
your right to have any of the personal data and information attributable to, identifying or relating to you that are incomplete made complete without undue delay, including via supplemental statement.
Reasonably Transparent Communication
your right to have The Ikoku Philanthropies provide you — as the natural or legal person concerned — reasonably transparent communication and notification regarding progress and decisions pertaining to your correction or completion requests.
Given Feasibility and Reasonableness
provided that your requests are both feasible and reasonable with respect to cost, frequency, number, proportionate effort, technical limits and concerns for the rights of other persons concerned, including The Ikoku Philanthropies.
Given No Adverse Effect on Rights of Others
provided also that exercising these rights does not adversely affect the civil liberties and basic, civil and fundamental rights of others — especially where those others are also natural or legal persons concerned.
Given Necessity, Non-Identification and Minimization
and provided that all such communication and correction or completion granted to you — as the natural or legal person concerned — whether pertaining to this process or the personal data and information, adhere to and fulfill the principles of necessity, non-identification and data-minimization.

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

Rights to Erasure

As the natural or legal person concerned, you shall have the rights to have reasonably deleted — or erased — data and information attributable to, identifying or otherwise relating to solely you. Such rights shall include all of the following:

Request and Confirm Erasure
your right to have any of the personal data and information attributable to, identifying or relating to you deleted or erased and confirmed as such without undue delay.
Inform Other Recipients
your right — where the deleted or erased personal data and information have been made accessible or public or transferred to other recipients or third parties, and where financially and technically feasible — to have The Ikoku Philanthropies inform such other recipients of the request for deletion or erasure of the personal data and information as well as the deletion or erasure of any related links, copies or replications.
Reasonably Transparent Communication
your right to have The Ikoku Philanthropies provide you — as the natural or legal person concerned — reasonably transparent communication and notification regarding progress and decisions pertaining to your deletion or erasure requests.
Given Feasibility and Reasonableness
provided that your requests are both feasible and reasonable with respect to cost, frequency, number, proportionate effort, technical limits and concerns for the rights of other persons concerned, including The Ikoku Philanthropies.
Given No Adverse Effect on Rights of Others
provided also that exercising these rights does not adversely affect the civil liberties and basic, civil and fundamental rights of others — especially where those others are also natural or legal persons concerned.
Given Necessity, Non-Identification and Minimization
and provided that all such communication and deletion or erasure granted to you — as the natural or legal person concerned — whether pertaining to this process or the personal data and information, adhere to and fulfill the principles of necessity, non-identification and data-minimization.

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

Rights to Object and Stop

As the natural or legal person concerned, you shall have the rights to reasonably object to and have stopped, on grounds relating to your particular situation, at any time, any or all access or other processing of data and information attributable to, identifying or otherwise relating to you. You shall have such rights especially, but not limited to, when any of the following applies:

Unfair, Unlawful, Without Consent
where the processing of the personal data and information was, is, or will be unconsented, unfair or unlawful or otherwise not adhering to or fulfilling the policies, principles and rights for data and information.
Processing for Public or Research Reasons
where the processing of the personal data and information was, is, or will be conducted for archival, care, research or statistical purposes, including health, historical, medical or scientific, or for reasons of public benefit or public interest.
Processing for Marketing
where the processing of the personal data and information was, is, or will be conducted for direct marketing or other advertising or marketing purposes.
Reasonably Transparent Communication
provided that The Ikoku Philanthropies provide you — as the natural or legal person concerned — reasonably transparent communication and notification regarding progress and decisions pertaining to your objection or stoppage requests.
Given Feasibility and Reasonableness
provided also that your requests are both feasible and reasonable with respect to cost, frequency, number, proportionate effort, technical limits and concerns for the rights of other persons concerned, including The Ikoku Philanthropies.
Given No Adverse Effect on Rights of Others
provided too that exercising these rights does not adversely affect the civil liberties and basic, civil and fundamental rights of others — especially where those others are also natural or legal persons concerned.
Given Necessity, Non-Identification and Minimization
and provided that all such communication and objection or stoppage granted to you — as the natural or legal person concerned — whether pertaining to this process or the personal data and information, adhere to and fulfill the principles of necessity, non-identification and data-minimization.

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

Rights to Restrict Processing

As the natural or legal person concerned, you shall have the rights to reasonably obtain from The Ikoku Philanthropies, at any time, a restriction of any and all access or other processing of data and information attributable to, identifying or otherwise relating to you. You shall have such rights especially, but not limited to, when any of the following applies:

When Contesting Accuracy or Completeness
where you — as the natural or legal person concerned — contest the accuracy or completeness of the personal data and information, for a period enabling The Ikoku Philanthropies to verify the accuracy or completeness of the personal data and information.
When Contesting Fairness or Lawfulness
where you — as the natural or legal person concerned — contest the fairness or lawfulness of the personal data and information or their processing, for a period enabling The Ikoku Philanthropies to verify the fairness or lawfulness of the personal data and information or their processing.
When Exercising Rights to Object
where you — as the natural or legal person concerned — exercise your rights to object on any of the legitimate grounds delineated and described in these Codes and Policies, for a period enabling The Ikoku Philanthropies to verify the validity of the grounds for objection.
When Unfairness or Unlawfulness is Established but not Erasure
where you — as the natural or legal person concerned — and The Ikoku Philanthropies have established unfairness or unlawfulness of the personal data and information or their processing — or have determined that other grounds for objection are valid — but you decide against deletion or erasure and instead request the restriction of purposes, processing and use.
When Legal Claims are being Established, Exercised or Defended
where you — as the natural or legal person concerned — requests the preservation and storage of the personal data and information for your own establishing, exercising or defense of legal claims, though The Ikoku Philanthropies establishes that it no longer has need for the personal data and information or any of its processing.
Reasonably Transparent Communication
provided that The Ikoku Philanthropies provide you — as the natural or legal person concerned — reasonably transparent communication and notification regarding progress and decisions pertaining to your restriction requests.
Given Need for Consent for Processing Beyond Storage
provided also that, where restriction of processing is decided, any processing beyond storage requires the consent of you — as the natural or legal person concerned.
Given Notice on Lifting of Restriction
provided too that, where restriction of processing occurs, you — as the natural or legal person concerned — are informed without undue delay if and before the restriction of processing is lifted.
Given Feasibility and Reasonableness
provided also that your requests are both feasible and reasonable with respect to cost, frequency, number, proportionate effort, technical limits and concerns for the rights of other persons concerned, including The Ikoku Philanthropies.
Given No Adverse Effect on Rights of Others
provided as well that exercising these rights does not adversely affect the civil liberties and basic, civil and fundamental rights of others — especially where those others are also natural or legal persons concerned.
Given Necessity, Non-Identification and Minimization
and provided that all such communication and objection or stoppage granted to you — as the natural or legal person concerned — whether pertaining to this process or the personal data and information, adhere to and fulfill the principles of necessity, non-identification and data-minimization.

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

Rights to Notification

As the natural or legal person concerned, you shall have the rights to reasonable notification of persons — solely by The Ikoku Philanthropies — following decisions and actions taken during review of personal data and information attributable to, identifying or otherwise relating to you. Such rights shall include all of the following:

Recipients upon Correction or Rectification
your right, upon any decision to correct or rectify any personal data and information, to have The Ikoku Philanthropies send reasonably transparent communication to each recipient to whom the personal data and information have been disclosed or transferred.
Recipients upon Deletion or Erasure
your right, upon any decision to delete or erase any personal data and information, to have The Ikoku Philanthropies send reasonably transparent communication to each recipient to whom the personal data and information have been disclosed or transferred.
Recipients upon Restriction of Processing
your right, upon any decision to restrict the processing of any personal data and information, to have The Ikoku Philanthropies send reasonably transparent communication to each recipient to whom the personal data and information have been disclosed or transferred.
Reasonably Transparent Communication
your right to have The Ikoku Philanthropies provide you — as the natural or legal person concerned — reasonably transparent communication regarding progress and decisions pertaining to your notification requests, and on your reasonable additional request, to have The Ikoku Philanthropies inform you about those recipients.
Given Feasibility and Reasonableness
provided that your requests are both feasible and reasonable with respect to cost, frequency’, number, proportionate effort, technical limits and concerns for the rights of other persons concerned, including The Ikoku Philanthropies.
Given Expected Reductions in Obligation
provided specifically that the obligation is reasonably reduced where notification proves impossible or involves disproportionate effort.
Given No Adverse Effect on Rights of Others
provided also that exercising these rights does not adversely affect the civil liberties and basic, civil and fundamental rights of others — especially where those others are also natural or legal persons concerned.
Given Necessity, Non-Identification and Minimization
and provided that all such communication and objection or stoppage granted to you — as the natural or legal person concerned — whether pertaining to this process or the personal data and information, adhere to and fulfill the principles of necessity, non-identification and minimization.

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

C — Central Responsibilities

The Responsibilities of Data Administration and Management

The above principles of processing — and their attendant rights of personal data and information — also incur ten (10) central responsibilities for the administration and management of personal data and information and their processing. The Ikoku Philanthropies shall retain such responsibilities when accessing or otherwise processing personal data and information attributable to, identifying, or otherwise relating to you. The Policy will elaborate in some detail upon each of these responsibilities as you proceed on this page. In the meantime do keep in mind two opening points to be made here.

First, that The Ikoku Philanthropies and specifically its Founder, Alvan Azinna Chibuzo Ikoku, consider these responsibilities to be under the purview of their own Rights to Property — and so take any attempts to abrogate, diminish, disrupt, reduce or weaken their capacity to fulfill, maintain or retain such responsibilities very seriously, directing you to the notice on Your Duty to Company Integrity at the top of this Policy page.

And second, that, given the aforementioned, it should be understood that The Ikoku Philanthropies and its Founder shall have processing of personal data and information conducted under all of the following conditions:

Responsibilities for Data and Information
that The Ikoku Philanthropies and its Founder have and retain full responsibilities for determining and accounting for the characteristics, parameters and qualities of data and information.
Responsibilities for Processing
that The Ikoku Philanthropies and its Founder have and retain full responsibilities for determining and accounting for the characteristics, parameters and qualities of processing data and information.
Responsibilities for Measures and Methods
that The Ikoku Philanthropies and its Founder have and retain full responsibilities for developing and implementing computational, organizational and technical measures and methods for data and information and their administration, management and processing.
Responsibilities for Risks
that The Ikoku Philanthropies and its Founder have and retain full responsibilities for assessing and minimizing risks to the rights and associated interests of you and other natural and legal persons concerned.
Responsibilities for Protection, Safety and Security
that The Ikoku Philanthropies and its Founder have and retain full responsibilities for developing, implementing and revising protection and security measures for data and information and their processing.
Responsibilities for Review
that The Ikoku Philanthropies and its Founder have and retain full responsibilities for reviewing, updating and ensuring that computational, organizational and technical measures and methods are adequate, appropriate and effective for data and information and their administration, management and processing.
Responsibilities for Approval, Authorization and Transfer
that The Ikoku Philanthropies and its Founder, during all of the above, have and retain all responsibilities for approval, authorization and transfer pertaining to personal data and information and their administration, management and processing.
Responsibilities for Adherence and Regulation
that The Ikoku Philanthropies and its Founder, during all of the above, have and retain all responsibilities for ensuring the administration, management and processing of data and information are and remain in accordance with these Codes and Policies, with their delineated and described principles, rights and responsibilities, and with applicable guidelines, law and regulation.
Responsibilities for Records
that The Ikoku Philanthropies and its Founder, during all of the above, have and retain all responsibilities for creating, maintaining and safekeeping books and records for data and information and their processing.
Responsibilities for Notification
that The Ikoku Philanthropies and its Founder, during all of the above, have and retain all responsibilities for reasonably transparent communication with and notification of you — as the natural or legal person concerned — upon any breach or violation of the above.

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

Responsibilities for Data and Information

The Ikoku Philanthropies — when processing data and information attributable to, identifying or otherwise relating to you — shall have the responsibilities for determining and accounting for the characteristics, parameters and qualities of such data and information. The Ikoku Philanthropies is responsible for deciding and controlling, for instance, nature and scope, as well as context and at times content. Such responsibilities require that all of the following apply:

Nature of Data and Information
that The Ikoku Philanthropies and its Founder be the primary administrator and manager determining the nature of data and information to be accessed or otherwise processed, including but not limited to deciding and authorizing the form, genre, language, medium, personal or identifying capacity, sensitivity and type of data and information.
Scope of Data and Information
that The Ikoku Philanthropies and its Founder be the primary administrator and manager determining the scope of data and information to be accessed or otherwise processed, including but not limited to deciding and authorizing the field, range, scale, size and time of data and information.
Context of Data and Information
that The Ikoku Philanthropies and its Founder be the primary administrator and manager determining the context for data and information to be accessed or otherwise processed, including but not limited to deciding and authorizing certain areas, parts, products, services and sites of The Ikoku Philanthropies for the data and information.
Where Publisher, Content of Data and Information
that, with the above taking precedence and guaranteed, The Ikoku Philanthropies and its Founder be the primary administrator and manager determining the content of data and information to be accessed or otherwise processed, where we are ourselves the primary publisher of such data and information.
Accounting for Data and Information
that, with the above taking precedence and guaranteed, The Ikoku Philanthropies and its Founder be the primary administrator and manager accounting for, reevaluating, reviewing and revising the context, nature, scope and at times content of data and information in fulfilling the principles, rights and responsibilities of their processing.

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

Responsibilities for Processing

The Ikoku Philanthropies — when processing data and information attributable to, identifying or otherwise relating to you — shall have the responsibilities for determining and accounting for the characteristics, parameters and qualities of such data and information. The Ikoku Philanthropies is responsible for deciding and controlling, for instance, nature and scope, as well as context, purposes and at times content. Such responsibilities require that all of the following apply:

Nature of Data and Information Processing
that The Ikoku Philanthropies and its Founder be the primary administrator and manager determining the nature of processing for data and information, including but not limited to deciding and authorizing computation, equipment, filing system, means, mechanisms, methods, procedures and technologies for such processing.
Purposes of Data and Information Processing
that The Ikoku Philanthropies and its Founder be the primary administrator and manager determining the purposes for processing data and information, including but not limited to deciding and authorizing actual or proposed applications, benefits, ends, impacts, interests, objectives, recipients and uses for data and information via such processing.
Scope of Data and Information Processing
that The Ikoku Philanthropies and its Founder be the primary administrator and manager determining the scope of processing for data and information, including but not limited to deciding and authorizing field, range, scale, size and time of each application, method, process or utilization for such processing.
Context of Data and Information Processing
that The Ikoku Philanthropies and its Founder be the primary administrator and manager determining the context for processing data and information, including but not limited to deciding and authorizing certain areas, parts, products, services and sites of The Ikoku Philanthropies for such processing.
Where Publisher, Content of Data and Information Processing
that, with the above taking precedence and guaranteed, The Ikoku Philanthropies and its Founder be the primary administrator and manager determining the content of processing data and information, where we are ourselves the primary publisher of such data and information.
Accounting for Data and Information Processing
that, with the above taking precedence and guaranteed, The Ikoku Philanthropies and its Founder be the primary administrator and manager accounting for, reevaluating, reviewing and revising the content, context, nature, purposes and scope for processing data and information in our fulfillment of data and information principles, rights and responsibilities.

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

Responsibilities for Measures and Methods

The Ikoku Philanthropies — when processing data and information attributable to, identifying or otherwise relating to you — shall have the responsibilities for developing and implementing computational, organizational and technical measures, including methods. The Ikoku Philanthropies is responsible for deciding and controlling, for instance, the adequacy, appropriateness and effectiveness of such measures for specific data and information, their processing, as well as their administration and management. Such responsibilities require that all of the following apply:

Measures Meeting Best Practices Standards
that The Ikoku Philanthropies and its Founder be the primary administrator and manager designing, developing and implementing computational, organizational and technical measures that meet best practices standards, to the most reasonable extent possible, in keeping with expectations for data and information, their processing, as well as their administration and management.
Measures Accounting for Data and Information
that The Ikoku Philanthropies and its Founder be the primary administrator and manager designing, developing and implementing computational, organizational and technical measures that are adequate, appropriate and effective specifically for the context, nature and scope of the data and information.
Measures Accounting for Data and Information Processing
that The Ikoku Philanthropies and its Founder be the primary administrator and manager designing, developing and implementing computational, organizational and technical measures that are adequate, appropriate and effective specifically for the context, nature, purposes and scope for the processing of data and information.
Where Publisher, Measures Accounting for Content
that, with the above taking precedence and guaranteed, The Ikoku Philanthropies and its Founder be the primary administrator and manager designing, developing and implementing computational, organizational and technical measures that are adequate, appropriate and effective specifically for the content of data and information and of their processing, where we are ourselves the primary publisher of such data and information.
Measures Meeting Codes and Policies Standards
that, during all of the above, The Ikoku Philanthropies and its Founder be the primary administrator and manager designing, developing and implementing computational, organizational and technical measures that are furthermore compatible with standards set via our data and information principles, rights and responsibilities.

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

Responsibilities for Risk

The Ikoku Philanthropies — when processing data and information attributable to, identifying or otherwise relating to you — shall have the responsibilities for assessing and minimizing risks to the rights and associated interests of you and other natural and legal persons concerned. The Ikoku Philanthropies is responsible for anticipating and reducing risks, for instance, of varying likelihood, number, origin and severity, as well as assessing and ensuring favorable relations between benefit and risk, as found in specific data and information sets and specific processing methods.

The assessment of risk is among the most important responsibilities The Ikoku Philanthropies can carry out for you. Such responsibilities therefore entail a one- or three-part evaluation, depending on the level of risk we discern. The first part of the evaluation, which every proposed research or investigation undergoes, requires that all of the following apply:

Early Definition and Determination of Risk
that The Ikoku Philanthropies and its Founder be the primary administrator and manager defining and determining the factors leading to, likelihood, number, origin and severity of risks to you — as the natural or legal person concerned — of processing the personal data and information to the personal data and information and also to the rights and associated interests of the natural and legal persons concerned.
Risk Determination Accounting for Aspects of Data and Information
that The Ikoku Philanthropies and its Founder be the primary administrator and manager conducting the above early determination of risk to you — as the natural or legal person concerned — while accounting for decisions as to content, context, nature and scope of the data and information.
Risk Determination Accounting for Aspects of Processing
that The Ikoku Philanthropies and its Founder be the primary administrator and manager conducting the above early determination of risk to you — as the natural or legal person concerned — while accounting for decisions as to content, context, nature, purposes and scope of processing the data and information.
Early and Objective Establishment of Risk
that The Ikoku Philanthropies complete the above early determination of risk on the basis of an objective assessment that establishes whether the processing of personal data and information involves no risk, a risk, low risk or high risk to you — as the natural or legal person concerned.
Early and Effective Mitigation of Risk
that The Ikoku Philanthropies and its Founder be the primary administrator and manager responding to the early determination and establishment of risk to you — as the natural or legal person concerned — by developing and implementing adequate, appropriate and effective measures for mitigating risks identified, including best practices methods with respect to factors for, likelihood, number, origin and severity of risks and to the content, context, nature, purposes and scope of the data and information as well as their processing.
Early and Effective Establishment of Benefit-Risk Relation
that The Ikoku Philanthropies also conclude the above early determination of risk to you — as the natural or legal person concerned — with an objective assessment that establishes the relation between benefit and risk of the data and information and their processing.
Decision on Data Processing Risks Assessment
where a specific processing uses new methods or technologies and accounting for the content, context, nature, purposes and scope of the processing results in a high risk to the rights and associated interests of natural persons concerned, that The Ikoku Philanthropies decide to conduct a data processing risks assessment.

The second part of the evaluation occurs when a data processing risks assessment (also known in the GDPR as a data protection impact assessment) is indicated. Understanding when that is required shall entail the anticipation and assessment of the level of risk to you and the level of difficulty you may or will likely have in exercising your data and information rights — as the natural or legal person concerned. The Ikoku Philanthropies should therefore conduct such a data processing risks assessment where there is any of the following:

Automation or Automated Methods with Legal Effects
where processing primarily involves automation or automated methods — including but not limited to automated individual decision-making and profiling — that produces legal or similarly significant effects on you — as the natural or legal person concerned.
Processing on a Large Scale with Sensitivity
where processing is conducted on a large scale with sensitive personal data and information (or with criminal convictions and offenses or security-related data), thus potentially affecting large numbers of natural persons who may not easily exercise their data and information rights.
Processing on a Publicly Accessible Area
where processing is conducted on or to systematically monitor a publicly accessible area.

The final part of the data processing risks assessment should, first entail, as in the early determination of risk above, a delineation and description of the factors for, likelihood, number, origin and severity of risks. And then the assessment shall include all of the following:

Systematic Description of Processing Operations and Purposes
systematically describe and explain the proposed processing operations and their purposes, including the content, context, nature and scope of the processing and of the personal data and information.
Assessment of Necessity and Proportionality
systematically assess the necessity and proportionality of the processing operations in relation to the purposes of such processing and to the personal data and information.
Assessment from Similar Data, Information and Processing
systematically draw careful and selective insights from similar processing operations and technologies on similar personal data and information — to the degree that the processing and person data and information are highly similar with respect to content, context, nature, purpose and scope, as well as the factors for, likelihood, number, origin and severity of risks.
Review of Measures for Accuracy and Security of Data and Information
review and ensure the use of adequate and appropriate organizational and technical measures to minimize factors and risks that result in the inaccuracy and insecurity of personal data and information during the processing.
Review of Measures for Accuracy and Security of Processing
review and ensure the use of adequate and appropriate organizational and technical measures to minimize factors and risks that result in the inaccuracy and insecurity of data and information processing itself.
Review of Computational and Equivalent Procedures
review and ensure the use of adequate and appropriate logic and computational, mathematical or statistical procedures, where profiling and automated decision-making is involved.
Review of Such Procedures for Accuracy, Efficacy and Ethics of Decision-Making
review and ensure the use of adequate and appropriate computational, organizational and technical measures to minimize factors and risks that result in the inaccuracy, inappropriateness and ineffectiveness of decision-making, where automation including profiling or automated decision-making is involved.
Review of Such Procedures for Risks to Rights of Persons
review and ensure the use of adequate and appropriate computational, organizational and technical measures to take into account and minimize potential risks involved for the rights and associated interests of natural and legal persons concerned.
Review of Such Procedures for Prevention of Discrimination and Stigmatization
review and ensure the use of adequate and appropriate computational, organizational and technical measures to prevent, inter alia, discriminatory and stigmatizing effects on natural persons concerned on the basis of sensitive data.

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

Responsibilities for Protection, Safety and Security

The Ikoku Philanthropies — when processing data and information attributable to, identifying or otherwise relating to you — shall have the responsibilities for ensuring a level of protection, safety and security commensurate with the characteristics, sensitivity and established risks of the data and information and their processing. Such responsibilities require that all of the following apply:

Measures Mitigating Anticipated or Established Risk
that The Ikoku Philanthropies and its Founder be the primary administrator and manager designing, developing, implementing and reviewing adequate and appropriate computational, organizational and technical measures to minimize factors and risks that result in the inaccuracy, inappropriateness, ineffectiveness and insecurity of data and information and their processing, as described in these Codes and Policies.
Specific Attention to Protection by Design
that The Ikoku Philanthropies and its Founder be the primary administrator and manager designing, developing, implementing and reviewing computational, organizational and technical measures with specific and rigorous attention to fulfilling the principles of necessity, non-identification and data-minimization to the fullest possible and reasonable extent, as described in these Codes and Policies.
Specific Attention to Protection by Default
that The Ikoku Philanthropies and its Founder be the primary administrator and manager designing, developing, implementing and reviewing computational, organizational and technical measures with specific and rigorous attention to fulfilling the principles of data and information protection by default, which further requires that personal data and information are not made accessible to an indefinite number of natural or legal persons without the consent, intervention and request of you — as the natural or legal person concerned.
Ensuring Confidentiality of Data, Information and Processing Systems and Services
that The Ikoku Philanthropies and its Founder be the primary administrator and manager designing, developing, implementing and reviewing organizational and technical measures that are appropriate and effective to ensure the ongoing confidentiality of data and information and processing systems and services.
Ensuring Privacy of Data, Information and Processing Systems and Services
that The Ikoku Philanthropies and its Founder be the primary administrator and manager designing, developing, implementing and reviewing organizational and technical measures that are appropriate and effective to ensure the ongoing privacy of data and information and processing systems and services.
Ensuring Security of Data, Information and Processing Systems and Services
that The Ikoku Philanthropies and its Founder be the primary administrator and manager designing, developing, implementing and reviewing organizational and technical measures that are appropriate and effective to ensure the ongoing security of data and information and processing systems and services.
Ensuring Integrity of Data, Information and Processing Systems and Services
that The Ikoku Philanthropies and its Founder be the primary administrator and manager designing, developing, implementing and reviewing organizational and technical measures that are appropriate and effective to ensure the ongoing integrity of data and information and processing systems and services.
Ensuring Resilience of Data, Information and Processing Systems and Services
that The Ikoku Philanthropies and its Founder be the primary administrator and manager designing, developing, implementing and reviewing organizational and technical measures that are appropriate and effective to ensure the ongoing resilience of data and information and processing systems and services.
Ensuring Availability of Data, Information and Processing Systems and Services
that The Ikoku Philanthropies and its Founder be the primary administrator and manager designing, developing, implementing and reviewing organizational and technical measures that are appropriate and effective to ensure the ongoing availability of data and information and processing systems and services, including the ability to restore availability and access to personal data and information in a timely manner in the event of a physical or technical incident.

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

Responsibilities for Review

The Ikoku Philanthropies — when processing data and information attributable to, identifying or otherwise relating to you — shall have the responsibilities for reviewing and updating computational, organizational and technical measures, including methods. The Ikoku Philanthropies is responsible for ensuring that such measures and methods are optimally adequate, appropriate and effective for the data and information and their administration, management and processing. Such responsibilities require that all of the following apply:

Ensuring Best Practices Standards for Review Measures
that The Ikoku Philanthropies and its Founder be the primary administrator and manager ensuring that the assessing, evaluating, testing and updating involved in the above reviewing of measures meet best practices standards, to the most reasonable extent possible, in keeping with expectations for the personal data and information and their processing.
Reviewing Measures for Data and Information
that The Ikoku Philanthropies and its Founder be the primary administrator and manager reviewing and updating computational, organizational and technical measures to be adequate and effective for the data and information.
Reviewing Measures for Data and Information Processing
that The Ikoku Philanthropies and its Founder be the primary administrator and manager reviewing and updating computational, organizational and technical measures to be adequate and effective for the data and information processing and for the fulfillment of principles, rights and responsibilities of such processing.
Reviewing Measures for Confidentiality and Privacy
that The Ikoku Philanthropies and its Founder be the primary administrator and manager reviewing and updating computational, organizational and technical measures to be adequate and effective for ensuring the confidentiality and privacy of the data and information and their processing.
Reviewing Measures for Protection and Security
that The Ikoku Philanthropies and its Founder be the primary administrator and manager reviewing and updating computational, organizational and technical measures to be adequate and effective for ensuring the protection and security of the data and information and their processing.
Reviewing Measures for Communication and Notification
that The Ikoku Philanthropies and its Founder be the primary administrator and manager reviewing and updating computational, organizational and technical measures to be adequate and effective for fulfilling principles, rights and responsibilities of reasonably transparent communication and notification.
Reviewing Measures for Books and Records
that The Ikoku Philanthropies and its Founder be the primary administrator and manager reviewing and updating computational, organizational and technical measures to be adequate and effective for fulfilling standards commensurate with the responsibilities for books and records.
Reviewing Measures for Approval, Authorization and Transfer
that The Ikoku Philanthropies and its Founder be the primary administrator and manager reviewing and updating computational, organizational and technical measures to be adequate and effective for fulfilling standards commensurate with the responsibilities for approval, authorization and transfer regarding the data and information.
Reviewing Measures for Regulation
that The Ikoku Philanthropies and its Founder be the primary administrator and manager reviewing and updating computational, organizational and technical measures to be adequate and effective for ensuring the administration, management and processing of the data and information are and remain in accordance with these Codes and Policies, and with applicable guidelines, law and regulation.

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

Responsibilities for Approval, Authorization and Transfer

The Ikoku Philanthropies — when processing data and information attributable to, identifying or otherwise relating to you — shall have all responsibilities for approval, authorization, assignment, delegation and transfer pertaining to personal data and information and their administration, management and processing. The Ikoku Philanthropies shall have such authorization and oversight responsibilities internally and externally, including for any partner, third party, third country or international organization. Such responsibilities therefore require that all of the following apply:

Sole Approval and Authorization
that The Ikoku Philanthropies — specifically the Founder, Alvan Azinna Chibuzo Ikoku — and its Founder be the sole administrator and manager approving and authorizing the administration, management and processing of personal data and information.
Sole Approval and Authorization of Access and Actions
that The Ikoku Philanthropies — specifically the Founder, Alvan Azinna Chibuzo Ikoku — and its Founder be the sole administrator and manager approving and authorizing access, activities, measures, operations and any equivalent actions pertaining to the administration, management and processing of personal data and information.
Sole Approval and Authorization of Communications and Transparency
that The Ikoku Philanthropies — specifically the Founder, Alvan Azinna Chibuzo Ikoku — and its Founder be the sole administrator and manager approving and authorizing communications, notifications, reports, transparency and any equivalent correspondence pertaining to the administration, management and processing of personal data and information.
Sole Approval and Authorization of Persons and Third Parties
that The Ikoku Philanthropies — specifically the Founder, Alvan Azinna Chibuzo Ikoku — and its Founder be the sole administrator and manager approving and authorizing persons, entities, offices, partners and any equivalent third parties pertaining to the administration, management and processing of personal data and information.
Assigned or Delegated Administration, Management and Processing
that any administration, management and processing of personal data and information assigned or delegated to persons and third parties not proceed or continue except on explicit, legitimate and specific instructions and purposes from The Ikoku Philanthropies — specifically the Founder, Alvan Azinna Chibuzo Ikoku — as given via the required approval and authorization.
Ensuring Adherence to Requirements for Approvals and Authorizations
that The Ikoku Philanthropies — specifically the Founder, Alvan Azinna Chibuzo Ikoku — and its Founder be the sole administrator and manager ensuring all approvals and authorizations pertaining to the administration, management and processing of personal data and information adhere to definitions and requirements for written approval and authorization, as delineated and described in these Codes and Policies.
Ensuring Adherence to Requirements for Communication and Notification
that The Ikoku Philanthropies — specifically the Founder, Alvan Azinna Chibuzo Ikoku — and its Founder be the sole administrator and manager ensuring all approvals and authorizations pertaining to the administration, management and processing of personal data and information adhere to definitions and requirements for written communication and notification, as delineated and described in these Codes and Policies.
Ensuring Accordance with Codes and Policies
that The Ikoku Philanthropies — specifically the Founder, Alvan Azinna Chibuzo Ikoku — and its Founder be the sole administrator and manager ensuring all approvals and authorizations pertaining to the administration, management and processing of personal data and information are and remain in accordance with these Codes and Policies.
Ensuring Accordance with Founding, Mission and Code of Ethics
that The Ikoku Philanthropies — specifically the Founder, Alvan Azinna Chibuzo Ikoku — and its Founder be the sole administrator and manager ensuring all approvals and authorizations pertaining to the administration, management and processing of personal data and information are and remain in accordance with the founding, mission and Code of Ethics of The Ikoku Philanthropies.
Ensuring Accordance with Applicable Guidelines, Law and Regulation
that The Ikoku Philanthropies — specifically the Founder, Alvan Azinna Chibuzo Ikoku — and its Founder be the sole administrator and manager ensuring all approvals and authorizations pertaining to the administration, management and processing of personal data and information are and remain in accordance with applicable guidelines, law and regulation.

Furthermore, where there is the assignment or delegation of any administration, management or processing of personal data and information, there should also be a contract or equivalent legal instrument — between The Ikoku Philanthropies and the person or third party to receive the assignment or delegation (the “assignee” or “delegate”) — written, approved, agreed to and signed by all parties, and containing all of the following:

Sole Approval and Authorization
agreement and attestation by all parties that The Ikoku Philanthropies — specifically the Founder, Alvan Azinna Chibuzo Ikoku — and its Founder be the sole administrator and manager approving and authorizing the administration, management and processing of personal data and information.
Explicit, Legitimate and Specific Instructions and Purposes
agreement and attestation by all parties that the assignee or delegate above shall carry out only the explicit, legitimate and specific instructions and purposes delineated and described in the contract or equivalent legal instrument, including but not limited to content, context, nature, purpose, scope and time duration pertaining to personal data and information, their administration, management and processing, and the natural and legal persons concerned.
Explicit, Legitimate and Specific Recipients and Transfers
agreement and attestation by all parties that the assignee or delegate above shall follow only documented instructions with respect to transfers of any personal data and information to recipients, categories of recipients, a third party, a third country or an international organization, and ensure the appropriate safeguards.
Commitment to Confidentiality and Privacy
agreement and attestation by all parties that the assignee or delegate above are and remain committed to confidentiality and privacy, confidentiality and privacy protections, and confidentiality privacy rights, as delineated and described in these Codes and Policies.
Measures for Protection and Security
agreement and attestation by all parties that the assignee or delegate above shall implement approved and authorized computational, organizational and technical measures that ensure the protection and security of personal data and information, and their processing, as delineated and described in these Codes and Policies.
Measures for Rights and Interests of Persons Concerned
agreement and attestation by all parties that the assignee or delegate above shall implement approved and authorized computational, organizational and technical measures that ensure the fulfillment, protection and respect of the rights of natural and legal persons concerned, as well as facilitate the exercising of such rights, as delineated and described in these Codes and Policies.
Reasonably Transparent Communication and Notification
agreement and attestation by all parties that the assignee or delegate above shall implement approved and authorized computational, organizational and technical measures that ensure the fulfillment of principles, rights and responsibilities for reasonably transparent communication and notification, as delineated and described in these Codes and Policies.
Ensuring Accordance with Responsibilities for Books and Records
agreement and attestation by all parties that the assignee or delegate above shall implement approved and authorized computational, organizational and technical measures that ensure accordance with the responsibilities and standards for book and records, as delineated and described in these Codes and Policies.
Ensuring Accordance with Codes and Policies
agreement and attestation by all parties that the assignee or delegate above shall implement computational, operational and technical measures that ensure accordance with these Codes and Policies.
Ensuring Accordance with Founding, Mission and Code of Ethics
agreement and attestation by all parties that the assignee or delegate above shall implement computational, operational and technical measures that ensure accordance with the founding, mission and Code of Ethics of The Ikoku Philanthropies.
Ensuring Accordance with Applicable Guidelines, Law and Regulation
agreement and attestation by all parties that the assignee or delegate above shall implement computational, operational and technical measures that ensure accordance with applicable guidelines, law and regulation.
Further Assignment, Delegation or Engagement
agreement and attestation by all parties that the assignee or delegate above shall not further assign, delegate or engage another person or party, except where given prior written approval and authorization by The Ikoku Philanthropies — specifically the Founder, Alvan Azinna Chibuzo Ikoku — as well as another written contract or equivalent legal instrument meeting these standards and protections for data and information principles, rights and responsibilities, as described here and in these Codes and Policies.
Validity, Legal Binding and Liabilities
agreement and attestation by all parties that the contract or equivalent legal instrument and conditions as described above shall be valid.

— also that the contract or equivalent legal instrument shall legally bind the assignee or delegate above with respect to The Ikoku Philanthropies — specifically the Founder, Alvan Azinna Chibuzo Ikoku — including but not limited to liabilities to The Ikoku Philanthropies.

— and that such validity, binding, conditions and liabilities shall continue even where the assignee or delegate above further assigns, delegate or engages another person or party.

Erasure or Return at the End of Assignment or Delegation
agreement and attestation by all parties that the assignee or delegate above shall, on the choice and request of The Ikoku Philanthropies, delete, erase or return all personal data and information and their copies, upon cessation, completion or end of the assignment or delegation.
Responsible Entities, Offices and Persons
the identity and contact information — for all parties involved — of the entities, offices and persons, or their representatives, responsible for the personal data and information; their administration, management and processing; and any assignment, delegation or transfer.

In addition to the above provisions, where there is a transfer of personal data and information to a third party, third country or international organization, there should also be a contract or equivalent legal instrument — between The Ikoku Philanthropies and the third party or third country or international organization to receive the transfer (the “transferee”) — written, approved, agreed to and signed by all parties, and containing all of the following:

Substitution of Transferee for Assignee or Delegate
all of the above provisions for the contract or equivalent legal instrument, but where applicable substituting “transferee” for “assignee” or “delegate.”
Description of the Overarching Arrangement and Purposes for Transfer
where applicable, a description of the overarching or ongoing arrangement, activity or relationship under which the transfer is conducted, as well as a description of the legitimate purposes for any processing, management or administration of the transferred data and information; and a systematic evaluation of the regulatory environment of the transferee with respect to standards and protections for data and information principles, rights and responsibilities, as described here and in these Codes and Policies.
Accordance with Codes, Policies and Regulations
agreement and attestation by all parties that the transferee fully comply with this Data and Information Policy, with applicable provisions of these Codes and Policies, and with applicable guidelines, law and regulation.
Measures and Safeguards for Above Compliance
agreement and attestation by all parties that the transferee shall have and implement additional transferee-owned and rigorously reviewed measures and safeguards to ensure the full compliance with this Data and Information Policy, with applicable provisions of these Codes and Policies, and with applicable guidelines, law and regulation.
Specific Safeguards for Protection of Rights of Persons
agreement and attestation by all parties that the transferee shall have and implement additional transferee-owned and rigorously reviewed measures and safeguards to ensure the fulfillment, protection and respect of the rights of natural and legal persons concerned, as well as facilitate the exercising of such rights, as delineated and described in these Codes and Policies.
Where a Request for Data Portability Transfer by Person Concerned
in addition to the above, where a natural or legal person concerned is exercising data portability rights and also making a request for the interoperable transfer of the data and information, reasonably informed consent of the natural and legal persons concerned, if consent is permitted, as described in these Codes and Policies.
Where Transfer is Single Action Without Ongoing Arrangement
and where the transfer is a single-occurrence action without an ongoing arrangement with The Ikoku Philanthropies — as in the case of a simple exercise of data portability rights and request for interoperable transfer — agreement and attestation by all parties that the transferee shall assume all liability for any breach or violation of standards and protections for data and information principles, rights and responsibilities, as delineated and described in this Data and Information Policy, these Codes and Policies, and applicable guidelines, law and regulation.

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

Responsibilities for Adherence and Regulation

The Ikoku Philanthropies — when processing data and information attributable to, identifying or otherwise relating to you — shall have all responsibilities for ensuring that the administration, management and processing of the data and information are and remain in accordance with internal and external standards. The Ikoku Philanthropies shall have such responsibilities with respect to these Codes and Policies, their principles, rights and responsibilities, as well as applicable field-specific guidelines, law and mandatory regulations. Such responsibilities therefore require that all of the following apply:

Ensuring Administration and Accordance with DRB Policy
that The Ikoku Philanthropies and its Founder be the sole administrator and manager designing, developing, implementing and reviewing computational, organizational and technical measures to ensure all data and information, their processing, and the administration and management of data and information processing undergo adequate and periodic review, recommendation, approval and disapproval procedures of the DRB and remain in accordance with the decisions of the DRB process.
Ensuring Accordance with Data and Information Policy
that The Ikoku Philanthropies and its Founder be the sole administrator and manager designing, developing, implementing and reviewing computational, organizational and technical measures to ensure the administration, management and processing of personal data and information are and remain in accordance with this Data and Information Policy.
Ensuring Accordance with Data and Information Principles, Rights and Responsibilities
that The Ikoku Philanthropies and its Founder be the sole administrator and manager designing, developing, implementing and reviewing computational, organizational and technical measures to ensure the administration, management and processing of personal data and information are and remain in accordance with the exercising and fulfillment of data and information principles, rights and responsibilities, as delineated and described in these Codes and Policies.
Ensuring Accordance with Codes and Policies
that The Ikoku Philanthropies and its Founder be the sole administrator and manager designing, developing, implementing and reviewing computational, organizational and technical measures to ensure the administration, management and processing of personal data and information are and remain in accordance with these Codes and Policies.
Ensuring Accordance with Founding, Mission and Code of Ethics
that The Ikoku Philanthropies and its Founder be the sole administrator and manager designing, developing, implementing and reviewing computational, organizational and technical measures to ensure the administration, management and processing of personal data and information are and remain in accordance with the founding, mission and Code of Ethics of The Ikoku Philanthropies.
Ensuring Accordance with Applicable Guidelines, Law and Regulation
that The Ikoku Philanthropies and its Founder be the sole administrator and manager designing, developing, implementing and reviewing computational, organizational and technical measures to ensure the administration, management and processing of personal data and information are and remain in accordance with applicable local, regional, national, international and field-specific guidelines, law and regulation.
Communication, Cooperation and Coordination with Compliance, Regulatory and Public Authorities
that The Ikoku Philanthropies and its Founder be the sole administrator and manager communicating, cooperating, coordinating and ensuring accordance of administration, management and processing of personal data and information with compliance, regulatory and public authorities, including but not limited to offices dedicated to guidelines, law and legislation, licensing, professions matters, public and occupational health, public and occupational safety, regulations, security, and taxes, fees and other financial matters.

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

Responsibilities for Records

The Ikoku Philanthropies — when processing data and information attributable to, identifying or otherwise relating to you — shall have all responsibilities for creating, maintaining and safekeeping books and records for the data and information and for their processing. Such responsibilities require that all of the following apply:

Ensuring Adherence to Accurate, Reasonably Transparent Communication
that The Ikoku Philanthropies and its Founder be the sole administrator and manager creating, maintaining, safekeeping and transmitting books and records for the data and information and for their processing in a manner that ensures the adherence to definitions, principles and requirements for accurate, reasonably transparent communication, as delineated and described in these Codes and Policies.
Ensuring Confidentiality and Privacy of Books and Records
that The Ikoku Philanthropies be the sole administrator and manager creating, maintaining, safekeeping and transmitting books and records for the data and information and for their processing in a manner that ensures the adherence to definitions, principles, rights and requirements for confidentiality and privacy, as delineated and described in these Codes and Policies.
Ensuring Integrity and Security of Books and Records
that The Ikoku Philanthropies and its Founder be the sole administrator and manager creating, maintaining, safekeeping and transmitting books and records for the data and information and for their processing in a manner that ensures the adherence to definitions, principles, rights and requirements for integrity and security, as delineated and described in these Codes and Policies.
Where Needed, Ensuring Availability and Reproducibility of Books and Records
that The Ikoku Philanthropies and its Founder be the sole administrator and manager creating, maintaining, safekeeping and transmitting books and records for the data and information and for their processing in a manner that ensures their limited reproducibility and availability, upon necessity and reasonable request, specifically for demonstration of processing and compliance with standards, as delineated and described in these Codes and Policies.

The Ikoku Philanthropies shall create, maintain and safely keep all books and records for personal data and information and for their processing, including where appropriate and possible in a manner adhering to Principles of Non-Identification and Transparency, and so where appropriate and possible in versions of records that are de-identified and de-personalized via their categorization, making sure they contain all of the following:

Purposes for Processing
the purposes for the processing of the personal data and information.
Categories of Processing
the categories of processing of the personal data and information.
Categories of Personal Data and Information
the categories of personal data and information.
Categories of Natural and Legal Persons
the categories of natural and legal persons concerned, with respect to the personal data and information and their processing.
Categories of Recipients
the categories of recipients to whom the personal data and information have been, are or will be disclosed or transferred, including any recipients in third countries or international organizations.
Erasure of Categories of Personal Data and Information
where possible, the envisaged time limits for erasure of the different categories of personal data and information.
Transfers of Personal Data and Information
any transfers of the personal data and information to a third country, third party or international organization, including the identification of the third country, third party or international organization and documentation of appropriate safeguards.
Transmission of Record
any request and authorized transmission of any such record of processing, including the time and reason for the request and communication, person who authorized the communication, the identification of the recipients, and documentation of appropriate safeguards.
Measures for Protection and Security
where possible, a general description of the computational, technical and organizational security measures taken to ensure the protection and security of the personal data and information and their processing.
Responsible Entity, Office or Persons
the identity and contact information of The Ikoku Philanthropies and the office or persons responsible for such personal data and information and their processing.

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

Responsibilities for Notification

The Ikoku Philanthropies — when processing data and information attributable to, identifying or otherwise relating to you — shall have all responsibilities for reasonably transparent communication with and notification upon any breach or violation with respect to the data and information or their processing. The Ikoku Philanthropies shall have such notification responsibilities when intended recipient is you, any other natural or legal persons concerned, and any applicable regulatory or supervisory authority. Such responsibilities require that all of the following apply:

Decision to Notify on Recognition of Breach or Violation
that, upon recognition of a breach or violation pertaining to the personal data and information or their processing, The Ikoku Philanthropies conducts a competent and rigorous evaluation determining whether the breach or violation results in a risk to the rights and associated interests of you — and any other natural or legal persons concerned — on the basis of an objective assessment that establishes the likelihood, number, origin and severity or risks and whether the breach or violation involves no risk, a risk, low risk or high risk.

— that if no risk, The Ikoku Philanthropies may decide not to notify you.

— that if an unlikely risk or low risk, The Ikoku Philanthropies may decide not to notify you only if it promptly conducts the mitigation measures described below.

— that if high risk, The Ikoku Philanthropies should notify you and promptly conduct the mitigation measures described below.

Time to Notify on Recognition of Breach or Violation
that, within seventy-two (72) hours of becoming aware of a breach or violation of high risk pertaining to personal data and information or their processing, The Ikoku Philanthropies send reasonably transparent communication and notification to you — as the natural or legal person concerned — and to any applicable regulatory authority.
Delay to Notify on Recognition of Breach or Violation
that, if such notification above is sent after seventy-two (72) hours of becoming aware of a breach or violation pertaining to personal data and information or their processing, The Ikoku Philanthropies also sends explanation of reasons for the delay to you — as the natural or legal person concerned — and to any applicable regulatory authority.

— where it is not possible to provide the required full details of the breach or violation all at once, or at the same time, that The Ikoku Philanthropies provide the required details in phases without undue further delay.

— and where such a delay was due to reasonable time requested for necessary investigation, including in coordination with law enforcement, that The Ikoku Philanthropies provide as much detail it can first in phases, then without undue delay after the investigation period is completed.

Nature of Breach or Violation
that, upon recognition of a breach or violation pertaining to personal data and information or their processing, The Ikoku Philanthropies have the reasonably transparent communication and notification above describe the nature of the breach or violation, including where possible, the categories and approximate number of natural and legal persons concerned and the categories and approximate number of personal data and information records.
Consequences of Breach or Violation
that, upon recognition of a breach or violation pertaining to personal data and information or their processing, The Ikoku Philanthropies have the reasonably transparent communication and notification above describe the consequences of the breach or violation, including where applicable, risks to the rights and associated interests of you — as the natural or legal person concerned.
Measures to Mitigate Breach or Violation
that, upon recognition of a breach or violation pertaining to personal data and information or their processing, The Ikoku Philanthropies have the reasonably transparent communication and notification above describe the measures The Ikoku Philanthropies has taken or proposed to address the breach or violation, including, where appropriate, measures to mitigate risks to and possible adverse effects on you — as the natural or legal person concerned.
Personal Measures to Prevent and Reduce Risks and Adverse Effects
that, upon recognition of a breach or violation pertaining to personal data and information or their processing, The Ikoku Philanthropies have the reasonably transparent communication and notification above describe, explain and recommend measures that you — as the natural or legal person concerned — should promptly take to prevent and reduce any possible adverse effects or risks that could arise from the breach or violation.
Responsible Entity, Office or Persons
that the reasonably transparent communication and notification above include the identity and contact information of The Ikoku Philanthropies and the office or persons responsible for such personal data and information and their processing.
Ensuring Mitigation of Adverse Effects and Risks
that The Ikoku Philanthropies and its Founder be the sole administrator and manager promptly assessing, characterizing and establishing the risks and adverse effects resulting from the breach or violation pertaining to personal data and information or their processing, and then developing and implementing appropriate and effective measures for mitigating risks identified, including best practices methods with respect to factors for, likelihood, number, origin and severity of risks and to the content, context, nature, purposes and scope of the personal data and information, of their processing, and of the breach or violation.
Ensuring Adherence to Reasonably Transparent Communication
that The Ikoku Philanthropies and its Founder be the sole administrator and manager creating, securing and transmitting such notification above in a manner that ensures the adherence to definitions, principles and requirements for reasonably transparent communication, as delineated and described in these Codes and Policies.
Ensuring Confidentiality and Privacy of Communication and Notification
that The Ikoku Philanthropies and its Founder be the sole administrator and manager creating, securing and transmitting such notification above in a manner that ensures the adherence to definitions, principles, rights and requirements for confidentiality and privacy, as delineated and described in these Codes and Policies.
Ensuring Documentation of Breach, Violation and Communication and Notification
that The Ikoku Philanthropies and its Founder be the sole administrator and manager creating, maintaining and transmitting books, documentation and records of the breach or violation and of the communication and notification above, in a manner that ensures their limited reproducibility and availability, upon necessity and reasonable request, specifically for demonstration of compliance with standards, as delineated and described in these Codes and Policies.

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

D — Expected Processing

The Expectations and Categories of Processing

Success at fulfilling the principles, rights and responsibilities of personal data and information partly depends on a set of shared, reasonable expectations for the administration, management and processing of data and information. Developing that shared understanding requires a schema for presenting what can at times be a complex amount and confluence of data, information, people and operations. The Policy here thus clarifies the broad categories of content, sources, purposes, persons concerned, and specific recipients that The Ikoku Philanthropies reasonably expects to consult, engage and work with during the administration, management and processing of data and information attributable to, identifying and otherwise relating to you. The Ikoku Philanthropies feels that providing these categories — and brief descriptions or examples — should facilitate your understanding during the consent process and the exercising of your data and information rights. The Policy starts by delineating them below:

Sources for Data and Information Processing
The Ikoku Philanthropies expects to handle ten (10) broad sources for processing data and information, both personal and non-personal.
Content of Data and Information Processing
The Ikoku Philanthropies expects to handle five (5) broad types and twenty-five (25) specific categories of content for data and information, both personal and non-personal.
Purposes for Data and Information Processing
The Ikoku Philanthropies expects to handle ten (10) broad purposes for processing data and information, both personal and non-personal.
Persons Concerned during Data and Information Processing
The Ikoku Philanthropies expects to engage with (15) types of natural and legal persons concerned when processing data and information, both personal and non-personal.
Recipients Specified and Authorized for Data and Information Processing
The Ikoku Philanthropies expects to have only eight (8) specified and authorized recipients engaged with and responsible for the administration, management and processing of data and information, both personal and non-personal.

It should therefore be expected that the above schema of broad categories will be part of our communication with you, as a rubric for presenting the sources, purposes, content, persons concerned and recipients pertaining to your personal data and information, and for informing and consenting you accordingly. The Ikoku Philanthropies thus hopes — and by way of this Policy — to be clearer and better able to respect your consent decisions when processing the data and information, and to also more effectively fulfill applicable principles, rights and responsibilities of personal data and information.

Personal Data and Information, Sources

There are ten (10) broad sources — or points of activity and engagement — at and through which The Ikoku Philanthropies reasonably expects to access or otherwise process data and information attributable to, identifying or otherwise relating to you — with your knowledge and informed consent. These sources may include any of the following:

Account or Profile Data and Information
The Ikoku Philanthropies expects to access and otherwise process personal data and information provided by you via an Account and Profile. At various points of your activity, engagement and visit with The Ikoku Philanthropies, you may be asked you to sign up for an Account or create a publicly visible Profile. If you decide to sign up for such an Account, you will be asked to provide account-specific identifying data and information: your name, email address, telephone number, and at times, a profile photograph, a home address, and a means of payment (like a credit card) to be stored within your account. If you choose to take full advantage of our Profile options, or our communication, connecting, sharing and other features, you may decide to provide more in the way of profile-specific identifying data and information: messages, posts, photographs and other audio-visual material, as well as contacts information. Depending on what you provide, some may be sensitive personal data and information. The Ikoku Philanthropies asks that you do this with thought, and will provide you with clear ways to control the visibility (or privacy settings) of such personal data and information.
Application or Product Data and Information
The Ikoku Philanthropies expects to access and otherwise process personal data and information via your specific use of applications and products. There are certain applications and products The Ikoku Philanthropies may provide that create unique items of data and information (such as a unique application number) when you download and install them on your device. Application-unique identifying data and information, as well as product-specific identifying data and information, may be periodically sent to our servers, and there collected, analyzed and otherwise processed. This may occur not only when you use the application or product on your device, but also when you install and uninstall that application or product.
Browser Data and Information
The Ikoku Philanthropies may access and otherwise process personal data and information via your specific browser and browsing. There are a range of browser-associated technologies — or what we like to call “bats” — such as cookies, pixel tags, web beacons and similar technologies, each of which are designed to collect specific forms of browser-associated technologies data and information (or “bat data”). These technologies are typically placed on your browser as you visit a variety of other sites and services throughout the internet (oftentimes without your knowledge). The Ikoku Philanthropies may choose to use such mechanisms to identify you as well as collect and otherwise process personal data and information at various points of your activity, engagement and visit with us — including for the purposes of authenticating you, ensuring any private or sensitive information is seen only by you, customizing what you see on sites to your browser type, location and preferred language, and responding better to your declared preferences and settings during your experience with us. If we do so, it shall be with your knowledge and informed consent.
Device Data and Information
The Ikoku Philanthropies may access and otherwise process personal data and information via your specific use of devices. At various points of your activity, engagement and visit, The Ikoku Philanthropies may access and collect what it calls device-specific identifying data and information (or “didi”) — data and information that specifically identifies the device you are using. Examples of such data and information include but are not limited to: your IP and MAC address, model of your device, operating system, unique device identifier, and data and information about your mobile network that, once again, includes your phone number. Note that The Ikoku Philanthropies may connect and combine such device-specific identifying data and information with those from other sources during your creation or use of an account or profile, application, product, service or site. If The Ikoku Philanthropies does so, it shall be with your knowledge and informed consent.
Locally Stored Data and Information
The Ikoku Philanthropies may access and otherwise process personal data and information via locally stored datasets and technologies. Note that — while most sources have us collect and otherwise process data and information at central servers located with us — there are a range of mechanisms to collect and store personal data and information directly on your device. These include browser web storage and application data caches. The Ikoku Philanthropies may decide to use such technologies to better understand your visitor and user activity. If we do so, it shall be with your knowledge and informed consent.
Location Data and Information
The Ikoku Philanthropies may access and otherwise process personal data and information via technologies specifically focused on your location. At various points of your activity, engagement and visit, The Ikoku Philanthropies may access, collect and store location-specific identifying data and information — what The Ikoku Philanthropies calls “locids” and “loc-ID data” — about your geographic location, position in an area, motions and movement. The technologies The Ikoku Philanthropies may use to determine such personal data and information may include GPS, IP and other sensors with the ability to connect with nearby cell towers, devices, Wi-Fi access points and hot spots. If The Ikoku Philanthropies does so, it shall be with your knowledge and informed consent.
Log Data and Information
The Ikoku Philanthropies expect to access and otherwise process personal data and information via technologies that produce records — or logs — after an activity or operation has occurred. There are a range of log-generating technologies — what The Ikoku Philanthropies calls “logets” and “loggers” active whenever you or The Ikoku Philanthropies are active — that result in record-like data and information often known as log files or server logs. Such data and information may include your page requests and search queries; events associated with your device such as crashes, errors, system activity, and hardware settings; or the URLs of sites that referred you to us, as well as the date and time of your referral request. Reviewing such logs is critical for maintaining the functioning of our Sites, Products and Services, as well as improving our response to any support or trouble-shooting requests you make. They thus represent one of the few categories and sources of data and information defined as necessary for any engagement with The Ikoku Philanthropies — where possible and reasonable The Ikoku Philanthropies will endeavor to render such data and information anonymous and non-personal.
Government and Public Office Data and Information
The Ikoku Philanthropies may access and otherwise process personal data and information via publicly accessible means provided by government and public offices. Again with your knowledge and informed consent, The Ikoku Philanthropies may choose to use such means to authenticate you, approve or open an account, confirm the accuracy of credentials and other data and information you provide, and verify your identity prior to allowing access to confidential, private or sensitive personal data and information.
Service and Site Data and Information
The Ikoku Philanthropies may access and otherwise process personal data and information via your specific use of services and sites. There are certain services and sites The Ikoku Philanthropies may provide that create specific items of data and information when you use them at various points of your activity, engagement and visit with The Ikoku Philanthropies. Service-specific data and information, as well as site-specific data and information, may be periodically sent to servers of The Ikoku Philanthropies, and there collected, analyzed and otherwise processed. The Ikoku Philanthropies may choose to use such mechanisms to accurately and effectively improve the functioning of and your experience with its Sites and Services. If The Ikoku Philanthropies does so, it shall be with your knowledge and informed consent.
Third Party Data and Information
The Ikoku Philanthropies may, in certain contexts and situations, consider accessing and otherwise processing personal data and information via other third parties. As you may already know, there are a range of third-party purchasers and providers of data and information — (also known here as “tipps” and “tippers”) — generating, managing, trading and vending in variously free or regulated markets of personal and non-personal data and information. There are also a select number of conscientious and privacy-preserving third-party processors of data and information. The Ikoku Philanthropies has strict policy restrictions regarding any choice made to partake in any vendor exchanges or processing agreements on your behalf and for your (as well as our) benefit. Be certain that if The Ikoku Philanthropies does so, it shall be with your reasonably transparent knowledge and informed consent.

Personal or Non-Personal? — There is some discussion about whether data and information collected via cookies and similar technologies can be treated as non-personal data and information, as has often been the case in a number of well-known platforms and sites. At The Ikoku Philanthropies the policy on this matter is hopefully clear:

Nature or State at Initial or Early Processing as Determinative
that at times it is sufficient and reasonable — even ideal or necessary — to conduct our initial access or other processing of data and information in a manner that results in non-personal forms and states from the outset or very soon after, with no ability or possibility of attributing to, identifying or otherwise relating to a natural or legal person. Further aggregation of such non-personal data and information with multiple equivalently non-personal datasets will most likely be required to ensure this non-personal state. Where all such conditions are irreversibly met, such data and information may be safely treated as non-personal.
Irreversible Anonymization as Determinative
that previously personal data and information can also become — or safely be treated as — non-personal. But only if and to the extent that their processing goes beyond simply fulfilling the principles of non-identification, and includes successfulirreversible anonymization combined with aggregation. In other words, here too further aggregation of such newly anonymized data and information with multiple equivalently anonymized datasets will most likely be required to attain and ensure the non-personal state. And where all such conditions are irreversibly met, such data and information may be safely treated as non-personal.
Aggregation as Key for Ensuring Against Re-Identification
that one of The Ikoku Philanthropies’s primary concerns when deciding whether to safely treat de-identified or anonymized personal data and information as non-personal is the possibility of cross-reference or combination with identifying data and information, and having this occur in a manner that renders the dataset (or a resultant profile) effectively attributable to, identifying or otherwise directly relating to you. Currently, the best protection against such possibility is the processes of data summary and transformation entailed in aggregation, as defined and described in these Codes and Policies.
So Possible Re-Identification as Also Determinative
therefore that, to the extent that data and information can be combined to identify a natural or legal person (by cross-reference or combination, but also even by deduction or inference) — or re-identify previously de-identified data and information — or de-anonymize data and information previously thought to be irreversibly anonymized — all such de-identified and anonymized data and information are and remain personal at The Ikoku Philanthropies. And so they are subject to our requirements for fulfilling the principles, rights and responsibilities of personal data and information. It should be noted that such a likelihood — and risk to natural and legal persons concerned — is high for data and information that are particularly or uniquely identifying, as well as those described or discussed as confidential, private or sensitive.
So Combination as Also Determinative
and so wherever The Ikoku Philanthropies combines data and information that are non-personal with those that are personal the result is a combined form The Ikoku Philanthropies appropriately treats as personal, for as long as the combination remains intact.

It should therefore be expected that the above sources and points of activity and engagement for personal data and information may variously result in data and information sets treated as either personal or non-personal. The Ikoku Philanthropies will inform and consent you accordingly. Then The Ikoku Philanthropies will respect your consent decisions when processing the data and information, and also remain committed to fulfilling any applicable principles, rights and responsibilities of personal data and information.

Personal Data and Information, Content

There are five (5) broad types — and twenty-five (25) specific categories — of personal data and information that The Ikoku Philanthropies reasonably may access or otherwise process with your knowledge and informed consent. As should be evident in the listing and brief descriptions to follow, some are by nature sensitive data and information — certainly meriting thought on your part regarding what and whether to provide or consent to accessing and other processing. And some do incur additional duties and responsibilities on The Ikoku Philanthropies’s part — to keep you knowledgeable and informed, particularly about the range of personal data and information other entities could be collecting about you. Below the Policy delineates and describes these broad types as well as the specific categories under each one:

Biographical, Communications, Social —

Life Events and History
Data and information containing, describing, identifying or indicating your life events and personal history, including events that happened in your life, to you and around you, and their effect and influences on you and your surroundings.
Family and Relationships
Data and information containing, describing, identifying or indicating your family history, members, relationships, structure and status changes such as adoption, anniversary, death, divorce, marriage, miscarriage, reconciliation, reunion.
Educational and Professional Career
Data and information containing, describing, identifying or indicating your educational and professional career, including academic and aptitude tests and results, certifications, classes and courses, degrees, employee files, employment history, evaluations, grades and transcripts, interviews, job titles, military career records, professional license records, references, salary, school attended, trade union membership, training completed, veteran status, work history, workplace disability, workplace and educational disciplinary actions.
Communication and Correspondence
Data and information containing, describing, identifying or indicating your communications and correspondence, including email records, letters, mail, memos, messages, messenger chats and chat history, notes, phone call records, postal activity, telephone recordings, texts and text message history, video calls and chats, video conferences and conversations, voice mail, and telecommunications meta-data.
Community and Public Life
Data and information containing, describing, identifying or indicating character, content and qualities of your public life, including community engagement, leadership and service, community, life and public activities, event attendance, political and religious affiliations and practice, public and society interactions, reputation and social status.
Social Connections and Network
Data and information containing, describing, identifying or indicating your friends and social connections, including actual and social network friends, acquaintances, associations, chat and messenger history, Philanthropies and network membership, online hosting.
Tickets, Offenses and Crimes
Data and information containing, describing, identifying or indicating your record of offenses, including arrests, charges, convictions, crimes, fines, pardons, probations, summons, ticket citations, watch and wanted lists.

Economic, Financial, Transactional —

Accounts and Cards
Data and information containing, describing, identifying or indicating your banking and other financial account information, including accounts names and numbers, credit cards names and numbers, debit cards numbers, insurance policy accounts names and numbers, investment accounts names and numbers, loan and mortgage accounts names and numbers.
Assets and Ownership
Data and information containing, describing, identifying or indicating what you previously did or currently own, rent or rent out, develop, lease or otherwise borrow or possess, including art, automobile ownership, rental, leasing, registration and insurance records; businesses records, estates records, home value and taxes, housing ownership, rental, furnishing and insurance records; intellectual property, investment records, length of time in residence, offices and buildings, office decor and workplace equipment, personal possessions, property records, real estate.
Income and Transactions
Data and information containing, describing, identifying or indicating your income and buying, selling and other transactional activities, including buying and spending habits and budgets, client records, commercial records, customer records, donations and gifts, earnings and wages, income history, judgments, loan records, purchases, sales, taxes, trading or bartering transactions, wholesale or retail transactions.
Credit Capacity and Standing
Data and information containing, describing, identifying or indicating your reputation with regards to money and financial goals, including credit or borrowing capacity, credit records, credit reports and scores, credit standing, credit worthiness, liens and bankruptcies.

Mental, Psychological, Preferences —

Beliefs, Memories and Thought
Data and information containing, describing, identifying or indicating what and how you believe, remember or think, including ideas and thoughts, memories and mementos, philosophical and religious beliefs, readings and writings.
Knowledge and Experience
Data and information containing, describing, identifying or indicating what and how you know and experience first-hand, including aptitude, cognition, conscience, consciousness, intelligence, mental abilities and capacity; as well as your experience of what you have and have not been through, your knowledge of what you know and do not know, your learning of what you have learned and have not learned; the manner in which the aforementioned experience, knowledge and learning develops; the extent of your awareness of the aforementioned; and the extent to which the aforementioned, its process and your awareness can be altered, monitored, regulated or reproduced.
Preferences, Opinions and Intentions
Data and information containing, describing, identifying or indicating your preferences, opinions and intentions, including content and media preferences, favorites, fetishes, habits and proclivities, interests, likes and dislikes, hopes and feelings about a topic, outlook, perspectives, predictions and projections, promises and resolutions, tendencies and inclinations.
Uniquely and Privately Authenticating
Data and information containing, describing, identifying or indicating identifiers that uniquely or semi-uniquely identifies you as part of private and authenticating activity, most often something only you or one other living person could know, including well-protected answers to clues or hints, well-constructed, well-protected and regularly changed passcodes and passwords, well-constructed, well-protected and regularly changed PINs, rarely used and well-protected names or pseudonyms (given or taken during confirmation, rites-passage or an equivalently undocumented activity or event), coupled with the use of (a) a single-use and time-limited passcode generator, (b) physically authenticating keys and (c) a highly privacy-preserving passcode and password management systems.

Physical, Physiological, Interactive —

Activities and Behaviors
Data and information containing, describing, identifying or indicating your online or offline activities, behavior and choices, including browsing history, call logs, links clicked, referrals or reposts, search history, time spent, usage, visible and detectable attitude, demeanor, and emotional and facial states.
Culture, Ethnicity and Origins
Data and information containing, describing, identifying or indicating your cultural or “racial” lineage or origins, including assigned or self-described ethnicity and race, genetic material and test results, genealogies and heritage tracing, national origin, natively spoken languages, dialects and accents.
Demographic and Epidemiological
Data and information containing, describing, identifying or indicating demographic characteristics you share with others, including age range, education range, geographic residence, income brackets, morbidity and mortality factors and rates, self-described classifications, ranges for socioeconomic status indicators, and traits with ranges for physical and physiological characteristics such as adjusted BMI ranges, bone density ranges and height ranges.
Medical and Health
Data and information containing, describing, identifying or indicating your fitness, health, medical and wellness care, condition or status, including blood type, dentistry and dental records, diagnoses, disabilities, DNA code and other genetic material, drug tests and results, family, health and individual health history; fitness, health, medical and wellness facilities frequented or visited; fitness, health, medical and wellness practice or memberships; fitness, health, medical and wellness records; health and life insurance records, laboratory tests and results, medical card number, prescriptions, remedies and therapies.
Physical Characteristics and Markings
Data and information containing, describing, identifying or indicating your specific physical characteristics, including age, birthmarks, eye color, hair color, height, moles, piercings, sex, skin tone, tattoos, teeth, weight.
Sexual Characteristics and Relations
Data and information containing, describing, identifying or indicating your sexual life and orientation, including activities, gender expression and identity, history, memberships, networks and locations visited, relations and relationships, traditional and non-traditional partnerships.
Uniquely and Publicly Identifying
Data and information containing, describing, identifying or indicating identifiers that uniquely or semi-uniquely identifies you as part of public activity, including a specific individual name, alias, government or institution-issued identification and numbers, handwriting, profile pictures, signatures, usernames, and biometric data employed in eye, iris and retina recognition, facial recognition, fingerprinting and voiceprints, video footage and voice recording.

Technological, Tracing, Tracking —

Contact Information
Data and information containing, describing, identifying or indicating means and mechanisms for contacting you, including email address, physical address, postal address, telephone number.
Computers, Devices and Applications
Data and information containing, describing, identifying or indicating computers, devices and applications that you specifically use, including application-unique numbers, browser fingerprints, device-unique numbers, IP addresses, ISP, MAC addresses, language preferences, operating system, serial make, model and numbers, storage files.
Location, Motion and Movement
Data and information containing, describing, identifying or indicating your geo- or positional location, motions and movements, including the following at any moment and over time: city, country, county, distance from point, GPS coordinates, neighborhood, room and building number, state or province, street and block, town and village.

This is Serious! How Can I Protect and Enjoy Myself? — The Ikoku Philanthropies completely agrees: this is indeed a very serious matter. But you can still enjoy the Products, Services and Sites by, first, being thoughtful about exercising your rights to consent and the consent process. And second, focusing on making sure you are doing what’s described under Uniquely and Privately Authenticating Data and Information, namely:

Only-You-Could-Know Standard
making sure you are authenticating yourself with something only you or one other living person could know.
Well-Protected Answers to Clues or Hints
making sure you are authenticating yourself with answers to security clues, hints or questions that are also hard to find or guess, not obvious, rarely used and well-protected.
Well-Constructed, Well-Protected and Regularly Changed Passwords
making sure you are authenticating yourself with passcodes and passwords that are also well-constructed (that is, gobbledygook and nonsensical), well-protected and regularly changed.
Rarely Used, Undocumented and Well-Protected Names or Pseudonyms
where necessary, making sure that any names or pseudonyms you offer or use to authenticate yourself are themselves rarely used, relatively undocumented and well-protected — for instance, given or taken during confirmation, rites-passage or equivalently undocumented activity or event).
Coupled With a Time-Limited Passcode-Generating Authenticator
wherever it is possible, making sure you are also authenticating yourself with a well-protected authenticator device that generates a single-use and time-limited code to enter after you have inputted your passcode or password.
Coupled With a Physically Inserted Authenticating Key
wherever it is possible, making sure you are also authenticating yourself with a physical authenticating key that you must have in hand and insert to proceed with sensitive activity.
Coupled With a Privacy-Preserving Password Management System
always and in every instance, making sure you are also authenticating yourself with passcodes and passwords kept in a highly privacy-preserving passcode and password management system, certainly those that use encryption and preferably those that do not require backup to another company’s central server.

Can Above Personal Become Non-Personal? — There is some discussion about whether personal data and information of the categories, kinds and types delineated above could eventually become or be treated as non-personal data and information, after undergoing a number of de-identifying processes. At The Ikoku Philanthropies the policy on this matter is strict, highly respectful and hopefully clear:

Nature or State at Initial or Early Processing as Determinative
that at times it is sufficient and reasonable — even ideal or necessary — for The Ikoku Philanthropies to conduct an initial access or other processing of data and information in a manner that results in non-personal forms and states from the outset or very soon after, with no ability or possibility of attributing to, identifying or otherwise relating to a natural or legal person. Further aggregation of such non-personal data and information with multiple equivalently non-personal datasets will most likely be required to ensure this non-personal state. Where all such conditions are irreversibly met, such data and information may be safely treated as non-personal.
Irreversible Anonymization as Determinative
that previously personal data and information can also become — or safely be treated as — non-personal. But only if and to the extent that their processing goes beyond simply fulfilling the principles of non-identification, and includes successful irreversible anonymization combined with aggregation. In other words, here too further aggregation of such newly anonymized data and information with multiple equivalently anonymized datasets will most likely be required to attain and ensure the non-personal state. And where all such conditions are irreversibly met, such data and information may be safely treated as non-personal.
Aggregation as Key for Ensuring Against Re-Identification
that one of The Ikoku Philanthropies’s primary concerns when deciding whether to safely treat de-identified or anonymized personal data and information as non-personal is the possibility of cross-reference or combination with identifying data and information, and having this occur in a manner that renders the dataset (or a resultant profile) effectively attributable to, identifying or otherwise directly relating to you. Currently, the best protection against such possibility is the processes of data summary and transformation entailed in aggregation, as defined and described in these Codes and Policies.
So Possible Re-Identification as Also Determinative
therefore that, to the extent that data and information can be combined to identify a natural or legal person (by cross-reference or combination, but also even by deduction or inference) — or re-identify previously de-identified data and information — or de-anonymize data and information previously thought to be irreversibly anonymized — all such de-identified and anonymized data and information are and remain personal at The Ikoku Philanthropies. And so they are subject to our requirements for fulfilling the principles, rights and responsibilities of personal data and information. It should be noted that such a likelihood — and risk to natural and legal persons concerned — is high for data and information that are particularly or uniquely identifying, as well as those described or discussed as confidential, private or sensitive.
So Combination as Also Determinative
and so wherever The Ikoku Philanthropies combines data and information that are non-personal with those that are personal the result is a combined form The Ikoku Philanthropies appropriately treats as personal, for as long as the combination remains intact.

It should therefore be expected that the above types and specific categories of personal data and information are most likely to result in data and information sets treated as personal (even confidential, private and sensitive) till their deletion, erasure or destruction, if possible. Only on the successful implementation of assuredly irreversible anonymization and aggregation measures will there be possibility of treatment as non-personal. The Ikoku Philanthropies will inform and consent you accordingly. Then The Ikoku Philanthropies will respect your consent decisions when processing the data and information, and also remain committed to fulfilling any applicable principles, rights and responsibilities of personal data and information.

Personal Data and Information, Purposes

The primary objective whenever The Ikoku Philanthropies accesses or otherwise processes personal data and information is to provide and improve experiences you and all other natural and legal persons have with the Products, Services and Sites, as well as with the affiliates, divisions, subsidiaries and varied sections of The Ikoku Philanthropies. One way of ensuring this occurs is by clarifying the ten (10) categories of purposes The Ikoku Philanthropies reasonably expects to ask consent for when processing data and information attributable to, identifying or otherwise relating to you. The Policy delineates and describes them below:

Account and Profile Opening, Operation, and Maintenance
The Ikoku Philanthropies will likely need to access and otherwise process personal data and information to enable you to securely activate an Account and Profile, verify your identity, authenticate yourself during future logins and further add to, complete and enhance your Account and Profile. The Ikoku Philanthropies may also need to access and otherwise process personal data and information to help you add, amend, or clarify any application and biographical information, audiovisual media, prose and textual material, and other content you provide. Such processing may also be needed to facilitate you taking full advantage of any communication, connecting, sharing and other features of our Sites, Products and Services; and to keep sufficient track of your activity and help requests to aid in any maintenance issues you bring to our attention. The Ikoku Philanthropies may also access and otherwise process personal data and information for loss prevention and anti-fraud purposes.
Operation and Personalization of Sites, Products, Services
The Ikoku Philanthropies may need to access and otherwise process personal data and information to generally offer and operate the Products, Services and Sites and whenever you seek to personalize your experience with any of their sections. The personal data and information most useful for such personalization include, for instance, browser language and location settings, notice of news and events associated with your preferences, preferred activities and products and their updates, preferred screen views, and preferred views of feeds with their algorithms adjusted to your settings and activity tendencies.
Maintenance and Troubleshooting of Sites, Products, Services
The Ikoku Philanthropies will likely need to access and otherwise process personal data and information to help us detect and resolve developing and repeat issues within sections of the Products, Services and Sites, as well as to analyze your activity among that of other users and visitors in an attempt to enhance the experience and overall efficacy of these sections.
Further Development, Feedback and Testing of Products, Services, Sites
The Ikoku Philanthropies may need to access and otherwise process personal data and information for internal purposes such as auditing, data analysis and research to improve the Products, Services and Sites as well as communications with and other users and visitors. The Ikoku Philanthropies will also at times ask you to personally participate in focus groups, testing, and staged roll-outs of newer and hopefully improved versions of the Products, Services and Sites. Your initial feedback will be vital for such work and following up with you will also be essential.
Direct and Indirect Advertising and Marketing
The Ikoku Philanthropies may choose to access and otherwise process personal data and information, in restricted and carefully regulated ways, to help with its Advertising and Marketing Services. The Ikoku Philanthropies may also ask for your testimonials regarding your experience with sections of the Products, Services and Sites. Your opt-in consent to any such access and other processing — as well the clear opportunity to freely halt or withdraw it — will be required, and reasonably and transparently informed.
Opinion, Polls, Surveys, Thoughts Regarding Communities, Fields, Industries
The Ikoku Philanthropies may ask you to consider participating in polls, surveys and other approved and regulated research aiming to ascertain opinions, outlooks, perspectives and thoughts regarding the communities, fields and industries The Ikoku Philanthropies affects, conducts work in or for, and ultimately impacts. The applications, purposes and uses of the results of such work — and any associated personal data and information — will be made clear, as will be your right to informed consent and opportunity to end your participation at any time.
Future Directions, Research and Development
Much of what is accessed and otherwise processed above will — The Ikoku Philanthropies envisions and with your consent — be incorporated during considerations of future directions for The Ikoku Philanthropies’s work, including decisions to direct longer-term research and development toward different or new communities, concerns, methods, projects, subject matter and technologies as well as different or new Sites, Products and Services.
Legal Obligations and Regulations
From time to time, The Ikoku Philanthropies expects to have to access and otherwise process personal data and information in order to fulfill legal obligations and respond to both regulation and reporting requirements. The Ikoku Philanthropies will ensure that, to the most reasonable extent possible, you are reasonably and transparently informed and consented before, during and after required responses to such obligations.
Organizational Duties, Functions and Responsibilities
The Ikoku Philanthropies also expects to — regularly — access and otherwise process personal data and information to fulfill the principles, rights and responsibilities of personal data and information, their administration, management and processing, and general duties, functions and integrity and property rights as an organization. As with the above categories of purposes, The Ikoku Philanthropies will ensure that, to the most reasonable extent possible, you are reasonably and transparently informed and consented before, during and after such processing.
Updates on The Ikoku Philanthropies
Finally, The Ikoku Philanthropies will also very likely need to access and otherwise process personal data and information to send important notices, such as communications about The Ikoku Philanthropies and associated communities, significant changes to these Codes and Policies, and major modifications of the Products, Services and Sites. Such communication — and the personal  data and information it requires — remains among the most important to your experience of and participation in The Ikoku Philanthropies and the local and global communities you foster and help create. You may therefore not opt out of receiving these specific and necessary notifications — and The Ikoku Philanthropies hopes you do not mind.

Visiting with No Personal Data or Information: Finally, The Ikoku Philanthropies would like to note that your provision of any personal data and information, and your consent to any processing, should be understood as freely given and meaningful. During your first arrival, activities, engagement or visit, The Ikoku Philanthropies may ask you to provide personal data and information. You will not be required to provide the requested personal data and information to browse or occasionally visit the Products, Services and Sites. And there is much to enjoy here in that manner. Though do note that if you decide not to do so, you might not be able to take full advantage of the Products, Services and Sites — as is customary, expected and hopefully understandable.

Personal Data and Information, Persons Concerned

There are fifteen (15) broad categories of natural and legal persons concerned for personal data and information that The Ikoku Philanthropies reasonably expects to administer, manage and process. The Policy delineates and describes them below:

Browsers and Visitors
The Ikoku Philanthropies will likely need to access and otherwise process personal data and information attributable to persons acting, defined and described as browsers and visitors of the Sites, Products and Services.
Consumers and Customers
The Ikoku Philanthropies will likely need to access and otherwise process personal data and information attributable to persons acting, defined and described as consumers and customers with respect to the Sites, Products and Services.
Applications and Products Users
The Ikoku Philanthropies will likely need to access and otherwise process personal data and information attributable to persons acting, defined and described as users of the Sites, Products and Services and any associated applications.
Sites and Services Users
The Ikoku Philanthropies will likely need to access and otherwise process personal data and information attributable to persons acting, defined and described as users of the Sites, Products and Services.
Communities and Societies of Users and Visitors
The Ikoku Philanthropies will likely need to access and otherwise process personal data and information attributable more broadly to communities and societies of persons acting, defined and described as users and visitors of the Sites, Products and Services.
Directors, Executives and Managers
The Ikoku Philanthropies will likely need to access and otherwise process personal data and information attributable to persons acting, defined and described as directors, executives and managers of The Ikoku Philanthropies, its series, subsidiaries and affiliates, as well as the Sites, Products and Services.
Potential, Current and Former Personnel
The Ikoku Philanthropies will likely need to access and otherwise process personal data and information attributable to persons acting, defined and described as potential, current and former employees, personnel and other agents of The Ikoku Philanthropies, its series, subsidiaries and affiliates, as well as the Sites, Products and Services.
Family Members and Beneficiaries of Leadership and Personnel
The Ikoku Philanthropies will likely need to access and otherwise process personal data and information attributable to persons acting, defined and described as family members and beneficiaries of directors, executives and managers as well as employees, personnel and other agents of The Ikoku Philanthropies, its series, subsidiaries and affiliates, as well as the Sites, Products and Services.
Stakeholders and Shareholders
The Ikoku Philanthropies will likely need to access and otherwise process personal data and information attributable to persons acting, defined and described as interests-, shares- and stakeholders of The Ikoku Philanthropies, its series, subsidiaries and affiliates, as well as the Sites, Products and Services.
Partners and Affiliates
The Ikoku Philanthropies will likely need to access and otherwise process personal data and information attributable to persons acting, defined and described as potential, current and former partners and members or participants in other affiliations and equivalent arrangements with respect to The Ikoku Philanthropies, its series, subsidiaries and affiliates, as well as the Sites, Products and Services.
Consultants and Contractors
The Ikoku Philanthropies will likely need to access and otherwise process personal data and information attributable to persons acting, defined and described as potential, current and former consultants, contractors and other participants in equivalent arrangements with respect to The Ikoku Philanthropies, its series, subsidiaries and affiliates, as well as the Sites, Products and Services.
Third Party Servicers and Suppliers
The Ikoku Philanthropies will likely need to access and otherwise process personal data and information attributable to persons acting, defined and described as potential, current and former third-party servicers and suppliers and other participants in equivalent arrangements with respect to The Ikoku Philanthropies, its series, subsidiaries and affiliates, as well as the Sites, Products and Services.
Volunteers and Internships
The Ikoku Philanthropies will likely need to access and otherwise process personal data and information attributable to persons acting, defined and described as potential, current and former apprentices, interns, volunteers and other participants in equivalent arrangements with respect to The Ikoku Philanthropies, its series, subsidiaries and affiliates, as well as the Sites, Products and Services.
Professional and Licensing Bodies
The Ikoku Philanthropies will likely need to access and otherwise process personal data and information attributable to persons acting, defined and described as members, representatives or other agents of professional, licensing and equivalent bodies where applicable to the activities and work of The Ikoku Philanthropies, its series, subsidiaries and affiliates, as well as the Sites, Products and Services.
Public and Regulatory Offices
The Ikoku Philanthropies will likely need to access and otherwise process personal data and information attributable to persons acting, defined and described as members, representatives or other agents of governmental, public, regulatory and equivalent offices where applicable to the activities and work of The Ikoku Philanthropies, its series, subsidiaries and affiliates, as well as the Sites, Products and Services.

Visiting with No Personal Data or Information: Finally, The Ikoku Philanthropies would like to note that your provision of any personal data and information, and your consent to any processing, should be understood as freely given and meaningful. During your first arrival, activities, engagement or visit, The Ikoku Philanthropies may ask you to provide personal data and information. You will not be required to provide the requested personal data and information to browse or occasionally visit the Products, Services and Sites. And there is much to enjoy here in that manner. Though do note that if you decide not to do so, you might not be able to take full advantage of the Products, Services and Sites — as is customary, expected and hopefully understandable.

NonPersonal and Anonymous Data and Information

The Ikoku Philanthropies expects the commitment to fulfilling principles, rights and responsibilities of consent, necessity, minimization — and most pertinently non-identification — to regularly entail accessing and otherwise processing data and information in forms and states that do not permit association with or identification of any specific natural or legal person concerned. It is therefore important to here clarify expectations for the definition and processing of what The Ikoku Philanthropies would classify and treat as non-personal data and information:

Nature or State at Initial or Early Processing as Determinative
that it is at times be sufficient and reasonable — even ideal or necessary — to conduct our initial access or other processing of data and information in a manner that results in non-personal forms and states from the outset or very soon after, with no ability or possibility of attributing to, identifying or otherwise relating to a natural or legal person. Further aggregation of such non-personal data and information with multiple equivalently non-personal datasets will most likely be required to ensure this non-personal state. Where all such conditions are irreversibly met, such data and information may be safely treated as non-personal.
Irreversible Anonymization as Determinative
that previously personal data and information can also become — or safely be treated as — non-personal. But only if and to the extent that their processing goes beyond simply fulfilling the principles of non-identification, and includes successful irreversible anonymization combined with aggregation. In other words, here too further aggregation of such newly anonymized data and information with multiple equivalently anonymized datasets will most likely be required to attain and ensure the non-personal state. And where all such conditions are irreversibly met, such data and information may be safely treated as non-personal.
Aggregation as Key for Ensuring Against Re-Identification
that one of The Ikoku Philanthropies’s primary concerns when deciding whether to safely treat de-identified or anonymized personal data and information as non-personal is the possibility of cross-reference or combination with identifying data and information, and having this occur in a manner that renders the dataset (or a resultant profile) effectively attributable to, identifying or otherwise directly relating to you. Currently, the best protection against such possibility is the processes of data summary and transformation entailed in aggregation, as defined and described in these Codes and Policies. Through aggregation The Ikoku Philanthropies can take newly anonymized but raw forms of data and information and generate datasets in summary, statistical, numerical or non-numerical forms — forms that make re-identification or de-anonymization very difficult or improbable even with cross-referencing or combination.
So Possible Re-Identification as Also Determinative
therefore that, to the extent that data and information can be combined to identify a natural or legal person (by cross-reference or combination, but also even by deduction or inference) — or re-identify previously de-identified data and information — or de-anonymize data and information previously thought to be irreversibly anonymized — all such de-identified and anonymized data and information are and remain personal at The Ikoku Philanthropies. And so they are subject to requirements for fulfilling the principles, rights and responsibilities of personal data and information. It should be noted that such a likelihood — and risk to natural and legal persons concerned — is high for data and information that are particularly or uniquely identifying, as well as those described or discussed as confidential, private or sensitive.
So Combination as Also Determinative
and so wherever The Ikoku Philanthropies combines data and information that are non-personal with those that are personal the result is a combined form The Ikoku Philanthropies appropriately treats as personal, for as long as the combination remains intact.

As may be evident from the explanation above, the sources — or points of activity and engagement — where The Ikoku Philanthropies may access and otherwise process non-personal data and information do include those for personal forms. Similarly, categories, types and purposes of processing for non-personal data and information also include those delineated previously in sections dedicated to personal forms. But there are sources, categories and purposes of processing specifically appropriate for, compatible with, designed and reserved for data and information that are non-personal in form. These include the following:

Any Legitimate and Consented Purpose
The Ikoku Philanthropies may access or otherwise process non-personal information — if it remains in irreversibly anonymized and aggregated form — for any explicit, legitimate and specific purpose consented to by you — as the natural or legal person initially concerned. Such non-personal data and information is not further subject to the principles, rights, and responsibilities of personal data and information — except the requirement to maintain the non-personal form and ensure the processing solely for consented purposes.
Non-Identifying Operation and Improvement of Products, Services, Sites
The Ikoku Philanthropies may, for example, access and otherwise process anonymized data and information such as the area code, postal or zip code, selected language, unique device identifier, referrer URL and time zone where a Site, Product or Service is being used. The Ikoku Philanthropies may then aggregate and analyze the data and information with the consented purposes of understanding and improving time- and location-specific operations of the Products, Services and Sites. The Ikoku Philanthropies may thus ensure that such enhanced understanding and development of the Products, Services and Sites occurs without personal data and information attributable to, identifying or otherwise directly relating to you or any other natural or legal person.
Non-Identifying Enhancement of Understanding and Response to Activity and Behavior at Products, Services, Sites
The Ikoku Philanthropies may also access and otherwise process anonymized data and information regarding visitor and user activities on the Products, Services and Sites. This anonymized data and information may also be further aggregated then analyzed to produce better information and insight about visitor and user activity and behavior in different sections and parts of the Products, Services and Sites. The Ikoku Philanthropies may thus ensure that such enhanced understanding and development of our responses to visitors and users of Products, Services and Sites occurs without personal data and information attributable to, identifying or otherwise directly relating to you or any other natural or legal person
Combination After Anonymization for Minimally Identifying but Highly Informed Personalization
Also, upon your visit to a Service The Ikoku Philanthropies may ask your consent to use data to better respond to your preferences. If you give such consent, The Ikoku Philanthropies may temporarily combine irreversibly anonymized and aggregated data and information on visitor tendencies (non-personal) with your own recently stated preferences upon adding a profile (personal), and more accurately have such aggregated data on visitor behavior inform how The Ikoku Philanthropies responds to your preferences. The temporarily combined data and information will be treated as personal for the duration, and thus subject to all the principles, rights and responsibilities of personal data and information. The Ikoku Philanthropies may undo the combined form at any given time during or after your visit.
Subsequent Serial Anonymization and Aggregation for Minimally Identifying but More Highly Informed Personalization
Then The Ikoku Philanthropies may also at points of activity during your above visit — again with your consent — collect irreversibly anonymized data and information about how well The Ikoku Philanthropies responded during the combination period. The Ikoku Philanthropies may further aggregate such data and information with multiple anonymized datasets compiled from many other visitors, about responses during their combination periods. Then we may analyze what can now be treated as non-personal data and information to improve such responses to other visitors’ preferences. Or your experience during your next visit.

Visiting and Non-Personal Data and Information: Finally, The Ikoku Philanthropies would like to note that your provision of any personal data and information, and your consent to any processing, should be understood as freely given and meaningful. During your first arrival, activities, engagement or visit, The Ikoku Philanthropies may ask you to provide personal data and information. You will not be required to provide the requested personal data and information to browse or occasionally visit the Products, Services and Sites. And there is much to enjoy here in that manner. Though do note that if you decide not to do so, you might not be able to take full advantage of the Products, Services and Sites — as is customary, expected and hopefully understandable.

Recipients of Data and Information and Their Processing

As part of best practices standards to ensure the fulfillment of the principles, rights and responsibilities of personal data and information, as well as the general duties, functions, integrity and rights of the company, The Ikoku Philanthropies clarify below the only official recipients of data and information, whether personal or non-personal, and their administration, management and processing. Most all of the individual recipients shall be internal to The Ikoku Philanthropies and The Ikoku Group. And The Ikoku Philanthropies furthermore ensures that all such specific individual recipients shall be reviewed, vetted and authorized by the Founder and The Ikoku Philanthropies prior to, during and after any assignment, delegation or transfer and associated data and information activities and operations. Below the Policy delineates and describes the official entities and their sole authorizer:

The Alvan Ikoku Group LLC
The Alvan Ikoku Group LLC (also The Ikoku Group and The Alvan Azinna Chibuzo Ikoku Group) for data and information and their administration, management and processing conducted at, by and through its Products, Services and Sites.
The Ikoku Corporation division of The Ikoku Group
The Alvan Ikoku Corporation division of The Ikoku Group, for data and information and their administration, management and processing conducted at, by and through its Products, Services and Sites.
The Ikoku Holdings division of The Ikoku Group
The Alvan Ikoku Holdings division of The Ikoku Philanthropies, for data and information and their administration, management and processing conducted at, by and through its Products, Services and Sites.
The Ikoku Services division of The Ikoku Group
The Alvan Ikoku Services division of The Ikoku Group, for data and information and their administration, management and processing conducted at, by and through its Products, Services and Sites.
The Ikoku Philanthropies division of The Ikoku Group
The Alvan Ikoku Philanthropies division of The Ikoku Group, for data and information and their administration, management and processing conducted at, by and through its Products, Services and Sites.
Publiks Inc and The Publiks Group division of The Ikoku Group
Publiks Inc and The Publiks Group division of The Ikoku Group, for data and information and their administration, management and processing conducted at, by and through their Products, Services and Sites.

Sole Founder, President, CEO and Authorizer: Finally, the sole natural person recipient and sole person with authorization powers with respect to the above and any other administration, management and processing of data and information, whether personal or non-personal, is Alvan Azinna Chibuzo Ikoku, Founder, President, CEO and Chair of The Ikoku Group and Publiks Inc.

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Central and Associated Policies

Provision

As stated earlier, The Ikoku Philanthropies User Agreement and Code of Conduct consist of several Codes and Policies that collectively govern all of your activity with, within, for or pertaining to The Ikoku Philanthropies (as well as its series, subsidiaries and affiliates). By continuing, you indicate that you understand that these Codes and Policies include — but are not limited to — the Founding and Governing Code of Ethics, the Policy on Privacy and Confidentiality, the Terms and Conditions of Use and Service, and the Acceptable Use Policy along with all Associated Codes and Policies. We provide access to all of the described below.

Founding Code of Ethics

Founding Code of Ethics (HTML and PDF)

Privacy and Confidentiality

Policy on Privacy and Confidentiality (HTML and PDF)

Terms and Conditions

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

Acceptable Use Policy

Acceptable Use Policy (HTML and PDF)

All Associated Policies

All Associated Policies (HTML and PDF)

*Note

*Note: Please see the main Policies page for notice on conditions incompatible with the founding and mission of The Ikoku Philanthropies.

Ethics in the Division, and Company

The Codes and Policies above deeply reflect the founding and mission of The Ikoku Group and The Ikoku Philanthropies. They inform each instance of commitment, effort and work to achieve benefit, impact and success. The result, therefore, are three features evident in the company, the division, their products, services, sites, and most importantly, their communities:

01.

The Ikoku Group as a Company of and about Ethics

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

02.

Built with Integrity and Respect in Mind

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

03.

In Divisions that are Safe, Secure and Respectful

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

More About Us

The Ikoku Philanthropies

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

— About The Group

Mission, Scope, Founder

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

— Founding & Governance

Nature, Leadership, Ethics

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

— Policies

Agreement, Codes, Terms, Conditions

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

— Press & Media

News, Events, Coverage

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

— Reports

Alerts, Newsletters, Periodicals

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

— Careers at The Ikoku Group

Positions, Volunteers, Contributors