Preamble
Overview
The Codes and Policies of The Alvan Ikoku Philanthropies (collectively, the āPoliciesā or āCodes and Policiesā)* constitute The Ikoku Philanthropies User Agreement and Code of Conduct, and as such govern any and all activity conducted at, by, for, in, on behalf of, with or otherwise pertaining to The Ikoku Philanthropies.
Therefore, persons engaged in any such activity are expected to uphold the principles delineated below.
Your Agreement
āĀ With respect to the Agreement you enter into with The Ikoku Philanthropies via the Codes and Policies, and especially The Ikoku Philanthropies User Agreement and Code of Conduct, you understand and adhere to the following:
And furthermore, by engaging in any activity at, by, for, in, on behalf of, with or otherwise pertaining to The Ikoku Philanthropies, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of The Ikoku Philanthropies, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the divisions, series, subsidiaries, or affiliates, as well as any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the Products or Services, you accept and agree to the terms, conditions, and requirements described above, and in the Codes and Policies, in their entirety without modification.
Your Consent to The Policies
āĀ With respect to your ability to agree and consent to the Codes and Policies, and especially to The Ikoku Philanthropies User Agreement and Code of Conduct, you represent and warrant the following:
And furthermore, by engaging in any activity at, by, for, in, on behalf of, with or otherwise pertaining to The Ikoku Philanthropies, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of The Ikoku Philanthropies, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the divisions, series, subsidiaries, or affiliates, as well as any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the Products or Services, you accept and agree that your consent meets the conditions, principles, and requirements for consent as delineated and described in theseĀ Codes and Policies.
Your Abiding by The Policies
ā You represent, warrant, and covenant that, given the above attestation about your consent to the Codes and Policies, and The Ikoku Philanthropies User Agreement and Code of Conduct, you have read, understood, consented to, and agreed to be legally bound by and abide by The Ikoku Philanthropies User Agreement and Code of Conduct, and the Codes and Policies, in their entirety without modification, including as they are amended from time to time by The Ikoku Philanthropies.
Your Duty to the Policies
Your Duty to Organizational Integrity
And you further legally accept and agree that no application, interpretation, judgment, or other compliance, proceeding, or reading from, of, with, or otherwise relating to the Founding Ethics, the Codes and Policies, or any equivalent code, policy, or other document or material shall, in any way, entail any abrogation, diminishment, interference, or violation pertaining to any of the terms, conditions, principles, requirements, rights ā including the attendant properties and protections ā of company and organizational integrity.
Your Accordance with Ethics
āĀ You represent, warrant, and covenant that, given the above attestation about your consent to the Codes and Policies, and The Ikoku Philanthropies User Agreement and Code of Conduct, you ensure that your abiding by and adhering to their conditions, policies, principles, requirements, and rights shall further remain in accordance with the Founding and Governing Code of Ethics.
Your Accordance with Mission
ā You represent, warrant, and covenant that, given the above attestation about your consent to the Codes and Policies, and The Ikoku PhilanthropiesĀ User Agreement and Code of Conduct, you ensure that your abiding by and adhering to their conditions, policies, principles, requirements, and rights shall further remain in accordance with the founding mission and purposes of The Ikoku Philanthropies and The Ikoku Group, without incompatibility, as described and delineated in the Codes and Policies and the Founderās Operating Agreement of The Alvan Ikoku Group LLC (the āFounderās Operating Agreementā and the āFounderās Agreementā).ā
Your Attention to Changes
āĀ With respect to any changes to the aforementioned and below, you understand, agree to and adhere to the following::
And furthermore, by engaging in any activity at, by, for, in, on behalf of, with or otherwise pertaining to The Ikoku Philanthropies, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of The Ikoku Philanthropies, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the divisions, series, subsidiaries, or affiliates, as well as any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the Products or Services, you accept and agree to the terms, conditions, and requirements described above, and in the Codes and Policies, in their entirety without modification.
Your Questions and Feedback
Your questions regarding the Codes and Policies will help tremendously to make The Ikoku Philanthropies, including the divisions, series, subsidiaries, and affiliates, as well as the Products and Services, including theĀ Sites,Ā active, collaborative, safe and secure places and tools for doing work.
So if you have any questions, or thoughts, suggestions and feedback, please email them to policies@ikokuphilanthropies.com.
How to Report
And the reporting of any violations of the Codes and Policies will also help to make The Ikoku Philanthropies, including the divisions, series, subsidiaries, and affiliates, as well as the Products and Services, including theĀ Sites,Ā active, collaborative, safe and secure places and tools for doing work. The Duty to Report is also one of the principles of the Founding and Governing Code of Ethics.
So if you see, think or worry that a violation of code or policy may have occurred or may be occurring, please email policies@ikokuphilanthropies.com.
Do Read All Policies Before Continuing
Please, therefore, take the time to read and understand all of the Codes and Policies, and to revisit them whenever they are updated, before continuing to visit or use the Sites and any of the other Products or Services, and especially if you intend to be or are among the leadership staff, employees, volunteers, educators, researchers, donors, funding recipients, and partners, collaborators, agents or third-parties in any capacity formally approved by The Ikoku Group and the Founder and Owner, Alvan Azinna Chibuzo Ikoku.
The Codes and Policies, as well as some further clarifying definitions, are made available to you below.
Notes
Definitions
Provision
Provided below are definitions of terms to be used for purposes of the Codes and Policies, all official documents, policies and statements, and for any action, activity, communication, operation or participation in, within, with, for, on behalf of, in reference to, or otherwise pertaining to The Ikoku Philanthropies, its series, subsidiaries, and affiliates, and the Products and Services.
Basic Definitions
What is āRespect for Personsā
The Ikoku Philanthropies holds the fullest and most humane understanding of respect for personsĀ to be essential to its formation, development, management, and operations. These Codes and Policies are to constitute a central means of defining, determining, obtaining, safeguarding and ultimately having persons enjoy such respect. Therefore, it should be understood that The Ikoku Philanthropies takes as the basis for the Codes and Policies the following:
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Who are āThe Ikoku Philanthropiesā
ā In the Codes and Policies, and in all official documents, materials, and statements, including as presented on the Products and Services, the Sites, and elsewhere, āThe Ikoku Philanthropiesā refers to The Alvan Ikoku Philanthropies, a private, nongovernmental, nonpolitical and nonreligious organization formed as a registered series and division of The Alvan Ikoku Group LLC, which is itself a series limited liability company in the State of Delaware āĀ also officially doing business as The Alvan Azinna Chibuzo Ikoku Philanthropies and The Ikoku Philanthropies ā as well as any and all of the divisions, series, subsidiaries, and affiliates of The Ikoku Philanthropies, any and all of the Products and Services of The Ikoku Philanthropies, and any and all of the areas, offices, parts, sections, and assets and properties of The Ikoku Philanthropies, including but not limited to the following:
And furthermore, by engaging in any activity at, by, for, in, on behalf of, with or otherwise pertaining to The Ikoku Philanthropies, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of The Ikoku Philanthropies, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the divisions, series, subsidiaries, or affiliates, as well as any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the Products or Services, you accept and agree to the terms, conditions, and requirements described above, and in the Codes and Policies, in their entirety without modification.
What are āProducts,ā āServicesā and āSitesā
āĀ And in the Codes and Policies, as well as in all of the official documents, materials, and statements of The Ikoku Philanthropies, including as they present on the Products and Services of The Ikoku Philanthropies and elsewhere, āProductsā and āServicesā refer toĀ ā but are not limited to the following:
And furthermore, by engaging in any activity at, by, for, in, on behalf of, with or otherwise pertaining to The Ikoku Philanthropies, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of The Ikoku Philanthropies, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the divisions, series, subsidiaries, or affiliates, as well as any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the Products or Services, you accept and agree to the terms, conditions, and requirements described above, and in the Codes and Policies, in their entirety without modification.
Who Is āThe Founderā and āThe Ownerā
ā For the purposes of the Codes and Policies ā as well as any other official communications, documents, statements and other materials of The Ikoku Philanthropies ā āthe Founderā and āthe OwnerāĀ are understood to entail agreement and adherence to the following:
And furthermore, by engaging in any activity at, by, for, in, on behalf of, with or otherwise pertaining to The Ikoku Philanthropies, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of The Ikoku Philanthropies, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the divisions, series, subsidiaries, or affiliates, as well as any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the Products or Services, you accept and agree to the terms, conditions, and requirements described above, and in the Codes and Policies, in their entirety without modification.
Who Are āWe,ā āOurā and āUsā
ā For the purposes of the Codes and Policies, āwe,ā āourā and āusā are understood to entail agreement and adherence to the following:
And furthermore, by engaging in any activity at, by, for, in, on behalf of, with or otherwise pertaining to The Ikoku Group, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of The Ikoku Group, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the divisions, series, subsidiaries, or affiliates, as well as any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the Products or Services, you accept and agree to the terms, conditions, and requirements described above, and in the Codes and Policies, in their entirety without modification.
Who Are āYou,ā āUserā and āVisitorā
ā For the purposes of the Codes and Policies, āyouā is understood to entail agreement and adherence to the following:
And furthermore, by engaging in any activity at, by, for, in, on behalf of, with or otherwise pertaining to The Ikoku Philanthropies, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of The Ikoku Philanthropies, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the divisions, series, subsidiaries, or affiliates, as well as any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the Products or Services, you accept and agree to the terms, conditions, and requirements described above, and in the Codes and Policies, in their entirety without modification.
Further Definitions
āActivityā
References to āactivityā and āactivitiesā mean and include the following:
āApplicable Law, Regulationā
References to āapplicable lawā and āapplicable regulationā mean and include mandatory law and mandatory regulation of an official government and competent jurisdiction agreed to by The Ikoku Philanthropies and the Founder, Alvan Azinna Chibuzo Ikoku, whose effect broadly regulates the economy, sector, industry, or equivalent in which The Ikoku Philanthropies and the Founder conduct the specific activities in question or under review and, furthermore, whose application and interpretation (a) is specified to the relevant facts and specificities pertaining to the activities in question or under review and (b) has undergone full judicial review in official bodies, courts, and tribunals of competent jurisdiction agreed to by The Ikoku Philanthropies and the Founder. Any law, regulation, or equivalent (e.g. policy) whose effect, enforcement, or equivalent application or interpretation is found to primarily target The Ikoku Philanthropies, the Founder, or activities particular to either would neither meet nor qualify nor satisfy this definition, meaning, legal standard, or equivalent application or interpretation of references to āapplicable lawā or āapplicable regulation.ā
āArguablyā and āClearlyā
References to āclearly lawfulā and equivalents such as āclearly constitutionalā and āclearly ethicalā mean and include application or interpretation of law and regulation (a) that meet, qualify, and satisfy the definition, meaning, and legal standard delineated in the Codes and Policies for references to āapplicable lawā or āapplicable regulationā and (b) that has been and shall be, with certainty, deemed lawful, constitutional, ethical or equivalent via full government and judicial review in official bodies, courts, and tribunals of competent jurisdiction agreed to by The Ikoku Philanthropies and the Founder. References to āarguably lawfulā and equivalents such as āarguably constitutionalā and āarguably ethicalā mean and include argumentation, conjecture, deliberation, reasoning, or equivalent that assert, hypothesize, posit, or equivalent as to the probability that a proposed application or interpretation of law, regulation, or equivalent (e.g. policy) would meet, qualify, and satisfy this definition, meaning, and legal standard for references to āclearly lawfulā and equivalents such as āclearly constitutionalā and āclearly ethical,ā and therefore, would neither meet nor qualify nor satisfy this definition, meaning, legal standard, or equivalent application or interpretation of references to āclearly lawfulā and equivalents such as āclearly constitutionalā and āclearly ethical.ā
āConfidentialityā and āConfidentialā
References to āconfidentialityā and āconfidentialā mean and include that which is entailed in definitions, meanings, principles, processes, protections, requirements, rights, and equivalent provided for in applicable law and regulation as well as in the Codes and Policies. Where biospecimens, data, information, or equivalent are concerned, references to ābiospecimens,ā āconfidential data,ā āconfidential information,ā or equivalent mean and include the following:
āConsentā
References to āconsentā and āconsentedā mean and include only anĀ affirmative, revocable and unambiguous indication of a natural or legal personās wishes via a written communication or instrument that meets the following standard:
āConsentā should not be confused with āagreementā or ācontractā and the requirements for these three types of written instruments should not be conflated.
Furthermore, consent has particular implications and requirements explained twice in the Codes and Policies ā first, in theĀ Policy on Data and InformationĀ and second, in theĀ Policy on Human Subjects Research and Investigation ā and The Ikoku Philanthropies advises you to regularly visit those sections forĀ an extended and updated explanation of aspects of consent relevant to several processes at the company, where your in-depth understanding of consentās requirements will likely be of benefit to all involved.
āData Aggregationā
References to āaggregationā and āaggregatedā in the context of processing data and information mean and include processing where raw data and information are accessed and collected, deidentified and compiled, then transformed and rendered in a summary form ā using categories and ranges ā for statistical analysis. Anonymization, as well as transformation from individual data points and persons to categories and ranges, is often expected, preferred and at times required. The raw data and information can be aggregated to provide numerical and non-numerical insights, insights about a specific action or characteristics over time, opportunities for comparison with and across other similarly aggregated or prepared datasets, and greaterĀ opportunities for analysis, compiling and merging with multiple other similarly aggregated or prepared datasets.
āData Review Boardā
References to ādata review boardā (also the āDRBā) in the context of processing data and information mean and include aĀ board of data and information ethics evaluators established and maintained in accord with and for the purposes of determination, review and approval or non-approval as described in theĀ Policy on Data and Information.
References to āDRB approvalā mean and include determinations of the DRB that the data or information or their processing has been reviewed and may be processed or conducted at a specific part, product, section, service or site of The Ikoku Philanthropies within the constraints set forth by the DRB, by the Policy on Data and Information, by these Codes and Polices, and by applicable guidelines, law, and regulations.
āDe-identificationā
References to āde-identificationā ā in the context of either research and investigation or processing biospecimens, data, and information ā mean and include the access, collection, or other processing of personal biospecimens, data, and information by means that do not actively or immediately identify a specific natural or legal person.
Typically, de-identification de-links or uncouples the connection between personal biospecimens, data, and information and the identity of the natural or legal person concerned, but also keeps identifying information that can ā relatively easily or quicklyĀ ā be recoupled or re-linked in certain situations and for certain purposes.
Personal biospecimens, data, and information that have undergone a process of de-identification or have been described as āde-identifyingā or āde-identifiedā are andĀ remain personal biospecimens, data, and information (since theyĀ could be used to identify a natural or legal person, for example, when combined with additional information like a security question, reversible barcode or original un-redacted document).
For this reason, such de-identified personal biospecimens, data, and information, as well as their access, collection and other processing, require and remain under the stringent protections and regulations delineated and described in the Codes and Policies and in either the Policy on Data and InformationĀ or the Policy on Human Subjects Research and Investigation. Moreover, natural or legal persons concerned still have Policy-specified rights to ensure and verify that such de-identification has been and remains properly and truly conducted.
āGovernment, Judicial Reviewā
References to āgovernment reviewā and ājudicial reviewā and equivalent mean and include adherence to all of the following:
āHealth Care Operationsā
References to āhealth care operationsā mean and include any of the following activities:
And furthermore, by engaging in any activity at, by, for, in, on behalf of, with or otherwise pertaining to The Ikoku Philanthropies, any part or section of The Ikoku Philanthropies, any part or section of the divisions, series, subsidiaries, or affiliates, as well as any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the Products or Services, you accept and agree to the terms, conditions, and requirements described above, and in the Codes and Policies, in their entirety without modification.
āHuman Subjectā
References to āhuman subject,ā āhuman subject under study,ā and āhuman subject concernedāĀ in the context of research or investigation mean and includeĀ a living individual or natural person about or from whom a researcher or investigator (whether non-professional, professional or student) conducting research or investigation:
ā (a) obtains biospecimens, data, or information through interaction or intervention with the individual, and analyzes, studies, uses, or otherwiseĀ processes the biospecimens, data, or information; or
ā (b) analyzes, generates, obtains, studies, uses, or otherwise processes identifiable biospecimens, identifiable private or sensitive data, or identifiable private or sensitive information.
āIdentifiable Biospecimenā
References to āidentifiable biospecimenā and āpersonal biospecimenā in the context of research or investigation mean and includeĀ a biospecimen for which the identity of a human subject is or may be ascertained or associated with the biospecimen.
References to āidentifiable biospecimenā and āpersonal biospecimenā in the context of research or investigation alsomean and include a biospecimen accessed or otherwise processed by means that relates to, identifies, or can be used to identify or contact a human subject or natural person.
āIdentifiable Personā and āIdentifierā
References to āidentifiable personā in the context of processing data and information mean and include someone who can be directly or indirectly identified via use of or reference to an āidentifierā or a combination of āidentifying information,ā and examples of such identifiers or identifying information include, but are not limited to, a name, an identification number, a phone number, location data, an online identifier (such as a username), a device identifier (such as an IP address), or one or more items of information specific to the cultural, economic, financial, genetic, mental, physical, physiological, psychological, religious, social or spiritual identity or characteristics of a natural or legal person.
The Ikoku Philanthropies also refers to such an identifiable person as aĀ ānatural or legal person who is a subject of, or identifiable by, the data and informationā as well as a ānatural or legal person concernedā in the context of activities, operations, policies or statements pertaining to personal data and information.
Such an identifiable person is also known as a ādata subjectā in the European Unionās GDPR lawĀ and is also included in the definition and use of āconsumerā in theĀ California Consumer Privacy Act (CCPA).
āIntellectual Property, Externalā
And furthermore, by engaging in any activity at, by, for, in, on behalf of, with or otherwise pertaining to The Ikoku Philanthropies, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of The Ikoku Philanthropies, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the divisions, series, subsidiaries, or affiliates, as well as any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the Products or Services, you accept and agree to the terms, conditions, and requirements described above, and in the Codes and Policies, in their entirety without modification.
āInteraction, Researchā
References to āinteractionā in the context of research or investigation mean and include communication or interpersonal contact between a researcher or investigator and a human subject, eitherĀ for research or investigation purposes or as part of activity determined to constitute research or investigation.
Also, references to ābenign behavioral interactionsā or ābenign interactionsā in the context of research or investigation mean and include interactions that are, after rigorous assessment and by written consent and written instrument,Ā confirmed by the human subject, internal review board and researcher or investigator to be:
ā (a) brief in duration;
ā (b) harmless;
ā (c) painless;
ā (d) not physically invasive,
ā (e) not likely to have a significant adverse lasting impact on the human subject; and
ā (f) neither offensive nor embarrassing.
āInternal Review Boardā
References to āinternal review boardā (also the āIRBā) in the context of research or investigation mean and include aĀ board of research ethics evaluators established and maintained in accord with and for the purposes of determination, review, and approval or non-approval as described in theĀ Policy on Human Subjects Research and Investigation.
References to āIRB approvalā mean and include determinations of the IRB that the research or investigation has been reviewed and may be conducted at a specific at a specific part, product, section, service or site of The Ikoku Philanthropies, or other institution and setting, within the constraints set forth by the IRB, by the Policy on Human Subjects Research and Investigation, by these Codes and Polices, by other institutional policy, and by applicable guidelines, law, and regulations.
āIntervention, Researchā
References to āinterventionā in the context of research or investigation mean and includeĀ both:
ā (a) procedures by which biospecimens, data, or information are accessed, gathered or otherwise processed;Ā and
ā (b) manipulations of a human subject or a human subjectās environment that are performed for research or investigation purposes or as part of activity determined to constitute research or investigation.
Also, references to ābenign behavioral interventionsā or ābenign interventionsā in the context of research or investigation mean and include interventions that are, after rigorous assessment and by written consent and written instrument,Ā confirmed by the human subject, internal review board and researcher or investigator to be:
ā (i) brief in duration;
ā (ii) harmless;
ā (iii) painless;
ā (iv) not physically invasive,
ā (v) not likely to have a significant adverse lasting impact on the human subject; and
ā (vi) neither offensive nor embarrassing.
āIrreversible Anonymizationā
References to āirreversible anonymizationā (or āanonymizationā for The Ikoku Group) ā in the context of either research and investigation or processing biospecimens, data, and information ā mean and include the access, collection, or other processing of biospecimens, data, and information by means that do not permit and irreversibly prevents the biospecimens, data, and information from being attributable to, or identifying, a specific natural or legal person.
Only after biospecimens, data, and information have undergone processes of irreversible anonymization, and thus become irreversibly anonymized, may they be described as āanonymizedā biospecimens, data, and information, whose access, collection, or other processing may not require the stringent protections and regulations delineated and described in the Codes and Policies and in either the Policy on Data and InformationĀ or the Policy on Human Subjects Research and Investigation.
It must be noted that there are ongoing concerns that such āanonymizedā biospecimens, data, and information may possibly and technically become comparatively or increasinglyĀ āun-anonymizedā or even personal (for example, when cross-referenced with datasets or information specifying physical and temporal location, or when subjected to certain methods of data aggregation, preparation, and mining).Ā For this reason, natural or legal persons concerned still have Policy-specified rights to ensure and verify that suchĀ irreversible anonymization has been and remains properly and truly conducted.
āMinimal Riskā
References to āminimal riskā in the context of research or investigation and processing biospecimens, data, and information mean and include the likelihood, magnitude and probability of physical or psychological harm that is normally encountered in the daily lives ā or in the routine professionally licensed dental, medical or psychological examination or routine educational situations Ā ā of healthy, undiscriminated and unharassed persons.
āNon-Identificationā
References to ānon-identificationā ā in the context of either research and investigation or processing biospecimens, data, and information ā mean and include the access, collection, or other processing of biospecimens, data, and information by means that do not permit or require the biospecimens, data, and information to be attributable to, or identify, a specific natural or legal person.
Personal biospecimens, data, and information that have undergone a process of non-identification or have been described as ānon-identifyingā may still be personal biospecimens, data, and information (in cases where theyĀ could be used to identify a natural or legal person, for example, when combined or cross-referenced with additional information or data sets), and so may stillĀ require and remain under the stringent protections and regulations delineated and described in the Codes and Policies in either the Policy on Data and InformationĀ or the Policy on Human Subjects Research and Investigation.
Moreover, natural or legal persons concerned still have Policy-specified rights to ensure and verify that such non-identification has been and remains properly and truly conducted. For this reason, The Ikoku Philanthropies makes clear distinctions between de-identification, pseudo-anonymization or pseudonymization, and irreversibleĀ anonymization.
āNotice,ā āGivingā and āDeliveryā
Reference to ānoticeā mean and include only written communication or notification properly delivered to its recipient; and ādeliveryā and āgiving noticeā shall be deemed to have been properly initiated and conducted if:
āĀ (a) served in person;
āĀ (b) sent via electronic mail;
āĀ (c) posted by United States mail, full postage prepaid thereon;
āĀ (d) sent by special courier service; or
āĀ (e) sent by telecopy, any of these options if conducted via a manner and formĀ consented to by the recipient for such purposes, and if sent to the correct mailing or electronic address or number designated by and consented to by the recipient for such purposes, or if none is designated, at the correct address or number of the recipient listed on the records of The Ikoku Philanthropies.
Furthermore, such delivery and notice shall be deemed to have been completed:
āĀ (i) in the case of personal or special courier delivery, on the date of actual receipt of such notice by the recipient;
āĀ (ii) in the case of mail delivery, when deposited in the United States mail, postage prepaid thereon, addressed to the recipient at designated or correct address as it appears on the records of The Ikoku Philanthropies;
āĀ (iii) if electronically transmitted, as provided in the Codes and Policies; or
āĀ (iv) in the case of facsimile delivery, when transmitted to the recipient at designated or correct fax number as it appears on the records of The Ikoku Philanthropies.
āOfficial Personsā
References to āofficial personā and āofficial personsā of an entity mean and include ā but are not limited to āĀ natural or legal persons appointed, contracted, elected, employed, entrusted or otherwise engaged by the entity as administrators, agents, beneficiaries, conservators, contractors, directors, employees, exchangers, executives, evaluators, freelancers, guardians, interest-holders, investigators, leaders, managers, officers, partners, personnel, representatives, sellers, shareholders, stakeholders, stockholders, traders, trustees, volunteers, workers, or in any administration, affiliation, association, benefiting, business, conservatorship, contract, decision-making, directorship, employment, engagement, exchange, evaluation, finance, franchise, funding, guardianship, governance, interest-holding, investigation,Ā leadership, license, management, membership, operations, oversight, partnership, permission, representation, sales, shareholding, sponsorship, stakeholding, stockholding, supervision, regulation, third-party, trade, trusteeship or other agent or equivalent arrangement or capacity, or their equivalent.
āPersonal Dataā and āPersonal Informationā
References to āpersonal dataā and āpersonal informationā mean and include data and information for which the identity of a specificĀ natural or legal person is or may be ascertained or associated with the data and information.
References to āpersonal dataā and āpersonal informationā also mean and include data and information accessed or otherwise processed by means that relate to, identify or can be used to identify or contact a natural or legal person.
āPrivacyā and āPrivateā
References to āprivacyā and āprivateā mean and include that which is entailed in definitions, meanings, principles, processes, protections, requirements, rights, and equivalent provided for in applicable law and regulation as well as in the Codes and Policies. Where biospecimens, data, information, or equivalent are concerned, references to ābiospecimens,ā āprivate data,ā āprivate information,ā or equivalent mean and include the following:
āProcessing, of Biospecimens, Data, Informationā
References to āprocessing,ā āprocessā or āprocessedā ā in the context of biospecimens, data, and information or research and investigation ā mean and include any activities or operations or sets of activities or operations that are performed on biospecimens, data, or information or on their sets ā whether confidential, identifiable, identifying, personal, private, sensitive or not ā and whether or not by automated means.
Such activities, operations and their means include, but are not limited to, accessing,Ā adaptation or alteration, alignment or combination, archiving or filing, bartering or trading, borrowing or renting or leasing, buying or purchasing,Ā circulation orĀ dissemination or otherwise making available, collection, consultation,Ā deletion or erasure or destruction,Ā detecting, disclosure,Ā documenting, developing, gathering or compiling, generating or preparing,Ā evaluating or assessing,Ā examining or analyzing, filming or streaming, giving or donating,Ā organization, profiling or predicting,Ā publication, publishing or otherwise making public, receiving, recording, reporting, restriction,Ā retrieval, saving or storage,Ā searching or searching for, selling or trading in,Ā structuring, tracking, transferring,Ā transmission, use or otherwise putting into activity or operation.
āProfiling, with Biospecimens, Data, Informationā
References to āprofilingā ā in the context of processing biospecimens,Ā data and information or research and investigation ā mean and include any processing of personal biospecimens, data, and information or any research and investigation that uses such biospecimens, data, and information to evaluate certain personal aspects or attributes relating to a natural person, including, but not limited to, analyzing or predicting aspects concerning that natural personās behavior, choices or decision-making,Ā economic or financial situation, health, fitness or wellness, hobbies orĀ interests, location or movements, performance at work, personal preferences, psychology, reliability, rest or sleep.
Profiling commonly accesses, collects, tracks then analyzes biospecimens, data, and information associated with an individualās behavior, habits, interests and personality in order to make decisions and predictions about that individual. A good number of these decisions and predictions have or lead to legal or similarly significant effects, implications and even consequences for that individual. Think, for instance, of decisions not to offer that individual a job, loan or mortgage ā or to present to that individual mostly or only apartment listings in certain neighborhoods, mostly or only certain health or medical treatment options, mostly or only a set of individuals to monitor or police ā based on profiling working with personal biospecimens, data, and information.
To more easily clarify whether profiling is occurring in relation to you, you may ask whether a person or entity is:
ā (a) collecting personal biospecimens, data, and information about you from a variety of sources, some publicly accessible, some you thought were private;
ā (b) analyzing that collected personal biospecimens, data, and information, on an intimate or large scale, for aspects, attributes or characteristicsĀ of you and other individuals;
ā (c) looking for associations in the collected biospecimens, data, and information to identify correlations between those aspects, attributes or characteristics andĀ behaviors of you and other individuals;
ā (d) creating profiles that can be associated with, applied to and tracked with you;
ā (e) predicting your behavior based on the assigned, applied or tracked profiles; or
ā (f) making decisions about you based on assessments during this process.
Where such profiling is primarily or solely conducted by automated means ā using, for instance, algorithms, artificial intelligence or machine-learning ā it is considered one approach or method underĀ āautomated individual decision-makingā and āautomated decision-making.ā
Automated individual decision-making often involves no human participation in the analysis, equally low human discernment in the decision-making, and thus often reduced opportunity for holding an entity accountable or responsible when errors or adverse effects result.
Note that just because an association or correlation is found in the collected biospecimens, data, and information does not mean that it is significant or that it would be accurate, appropriate, ethical or correct to use it in making the decisions in question.
Thus, The Ikoku Philanthropies recommends the following in these processing and research contexts:
ā (i) that you be reasonably informed before, during and after the processing or research;
ā (ii) that in certain instances ā where the individual is a child ā such processing and research be strictly prohibited;
ā (iii) that in other instances ā where sensitive biospecimens, data, and information are involved ā additional protections be in place;
ā (iv) that in other instances ā for instance, large-scale processing, or monitoring a publicly accessible place ā such collected biospecimens, data, or information and their associated risks be minimized by conducting a ādata processing risks assessmentā or a āresearch and processing risks assessmentā then addressing any concerns found; and finally
ā (v) that you be asked to consent, where you are permitted to consent.
āPseudo-anonymizationā or āPseudonymizationā
References to āpseudo-anonymizationā and āpseudonymizationāĀ ā in the context of either research and investigation or processing biospecimens, data, and information ā mean and include the access or other processing of biospecimens, data, and information conducted by means that do not permit the personal biospecimens, data, or information to be attributed to, or identify, a specificĀ natural or legal personĀ without the use of additional information ā provided that such additional information is kept separately and is subject to ātechnical and organizational measuresā to ensure that the personal biospecimens, data, or information are not attributed to, or identify, the natural or legal person concerned.
Pseudo-anonymization and pseudonymization are employed in processing that is highly protective and respectful of the consent decisions, confidentiality, privacy, security and for-purpose-only uses of the natural or legal person concerned and of the biospecimens, data, and information themselves. TheĀ ātechnical and organizational measuresā (required, for example, by the European Union GDPR law) serve as a means for us to increase the confidentiality, privacy and security around āre-identifyingĀ informationā that ā when necessary or upon an authorized or authenticated userās request ā could be combined to re-attribute personal biospecimens, data, and information to a natural or legal person.
Therefore, personal biospecimens, data, and information that have undergone a process of pseudo-anonymization or pseudonymizationĀ are andĀ remain personal biospecimens, data, and information (since theyĀ could be used to identify a natural or legal person, for example, when locked-out users request to regain access to their account or stored content).
For this reason, āpseudo-anonymizedā or āpseudonymizedāĀ personal biospecimens, data, and information, as well as their access and other processing, require and remain under the stringent protections and regulations delineated and described in the Codes and Policies and in either the Policy on Data and InformationĀ or the Policy on Human Subjects Research and Investigation. Moreover, natural or legal persons concerned still have Policy-specified rights to ensure and verify that suchĀ pseudonymization has been and remains properly and truly conducted.
āResearch and Investigationā
References to āresearchā or āinvestigationā mean and include aĀ systematic study designed to contribute to or develop generalizable knowledge, with such studyĀ including research development, evaluation, and testing. Activities that meet this definition constitute research or investigation for purposes of the Codes and Policies, whether or not they are conducted or supported under a program that is considered research or investigation for other purposes.
āRestriction of Processingā
References to ārestriction of processingā of biospecimens, data, and information mean and include any activities or operations or sets of activities or operations which mark stored biospecimens, data, and information, or their sets,Ā with the aim of limiting their processing in the future.
āRisks of Processingā
References to ārisksā and ārisks of processingā in the context of personal biospecimens, data, and information mean and include the anticipated, assessed or reported risks of any processing of personal biospecimens, data, and information to the personal biospecimens, data, and information and alsoĀ to the rights and associated interests of the natural and legal persons concerned or the human subject under study.
Such risks, of varying likelihood and severity, may result from processing that leads to physical, material or non-material damage. Think, for instance, of processing that results in discrimination or discriminatory effects, financial loss, fraud, identity theft, reputational damage, unauthorized reversal of anonymization, deidentification or pseudonymisation, violations of confidentiality or privacy, or any other significant economic or social disadvantage. Think, too, of processing that deprives natural and legal persons of their rights or prevents them from exercising their personal data and information rights.
Those risks are considered high where processing entails, and possibly reveals, sensitive personal biospecimens, data, and information, criminal convictions and offenses or related security measures. Processing is high-risk, too, where automated individual decision-making, including profiling, is involved; where personal biospecimens, data, and information of vulnerable natural persons, including children, are processed; where personal biospecimens, data, and information is being processed from or to monitor publicly accessible spaces; and where processing is done on a large scale and involves a large amount of personal biospecimens, data, and information, affecting a large number of persons who may also not be able to as easily exercise their Policy-specified rights pertaining to the biospecimens, data, and information. Think, also, of processing that may be sound in its methods but is conducted on personal biospecimens, data, and information that are sensitive or valuable, and where it would be considerably harmful to natural and legal persons if there wereĀ accidental, malicious,Ā unauthorized or unlawful access,Ā alteration, destruction, disclosure, exposure, leakage, loss or theft.
For many of these situations, processing is strictly prohibited. But at times it may be permitted by conducting a ādata processing risks assessmentā or āresearch and processing risks assessmentāĀ then effectively addressing any concerns found and reported, including eliminating any identified factors leading to risks andĀ further anonymizing or minimizingĀ the personal biospecimens, data, and information.
āSealā and āSealedā
The Founder, President and Chair shall provide for a company seal, which may have the name of The Ikoku Group or the pertinent division, series, subsidiary or affiliate inscribed thereon and shall otherwise be in such form as may be approved from time to time by the Founder. Thus, references to āseal,ā āsealedā and requirements for any instrument to be sealed mean only the use of said approved company seal by causing it to be personally impressed or affixed on an official instrument of The Ikoku Philanthropies by a person authorized to do so by the Founder, President and Chair via express and written instrument signed and sealed. No person or entity shall use the said approved company seal in any manner, including āfor identification purposes only,ā unless such use has been approved by the Founder, President and Chair via express and written instrument signed and sealed.
āSensitivityā and āSensitiveā
References to āsensitivityā and āsensitiveā mean and include that which is entailed in definitions, meanings, principles, processes, protections, requirements, rights, and equivalent provided for in applicable law and regulation as well as in the Codes and Policies. Where biospecimens, data, information, or equivalent are concerned, references to ābiospecimens,ā āsensitive data,ā āsensitive information,ā or equivalent mean and include the following:
āSignatureā and āSignedā
In a number of state, federal and international statutes pertaining to activities, operations and jurisdictions of importance to The Ikoku Philanthropies, the definition of signature does not include a stamped, computer generated, digital or electronic signature. Thus, references to āsigned,ā āsignature,ā and requirements for any instrument to be signed mean only a personally signed and handwritten mark by the person whose signature is so required and authorized, with stamped, computer generated, facsimile, digital or electronic forms of signature not permitted to serve as substitute.
āThird Partyā and āThird Countryā
The Ikoku Philanthropies endeavors, in its official documents and policies, to clearly and consistently consider and describe varied persons and relations that help with the fulfillment of the originating mission and purposes.Ā Thus, references to āthird partyā mean and include a person or entity who is not one of the principals of an activity or relationship (i.e. an agreement, contract, operation, service or transaction) but is involved in that activity or relationship inĀ an official or recognized capacity.
Meanwhile, references to āthird countryā mean and include a person or entity located in a country different from the principal country (or region) that serves as the expected or typical setting for an activity or relationship. But (similar to a third party) that person or entity and associated country has become a party to and setting for the activity or relationship inĀ an official or recognized capacity.
All activities, relationships and equivalent arrangements between The Ikoku Philanthropies and a third party or third country require, in addition to our official documents and policies, approval and authorization from the Founder as well as a written contract or equivalent legal instrument, the further requirements for which are often delineated and described in the Codes and Policies.
āTrial,ā āClinicalā or āResearchā
References to āclinical trial,ā āresearch trial,ā or ātrialā in the context of researchĀ mean and include a research or investigation study in which one or more human subjects are prospectively assigned to one or more interactions or interventions (which may include placebo or other control) to evaluate the effects of the interactions or interventions on biomedical, behavioral, physiological, psychological or technological outcomes.
āUser Content, Data and Feedbackā
References to āuser content, data or information, and feedbackā mean and include the following:
Please do also see the Policies on Data and Information, on Human Subjects Research and Investigation, and on Intellectual Property for further pertinent details concerning user content, data, and feedback.
āWriting,ā āWritten,ā and āElectronic Communicationā
References to āwritingā and āwrittenā mean and include only a recorded textual message in a recognized and standardized official language, expressly transcribed into physical, character- and letter-based form by a consenting person being the āwriter,ā to a consenting natural or legal person being the ārecipient,ā capable of comprehension by ordinary standardized visual, tactile or auditory means of reading and interpretation, and shall include āelectronic mail (email)ā and very similarly written āelectronic communication,ā provided that the conditions set forth below are met:
(1) Clarity, Legibility and No Inference āĀ As with allĀ actionable, applicable, approvable,Ā legitimate and official communication from, for, of, in, within or pertaining to The Ikoku Philanthropies, āelectronic communicationā must be expressly written, clearly legible and require no inference (orĀ āguessworkā) as to its content, meaning, sender or writer, and such communication must also create a record that:
(2) Approval ofĀ Means of Communication āĀ As with all actionable, applicable, approvable,Ā legitimate and official communication from, for, of, in, within or pertaining to The Ikoku Philanthropies, acceptable forms of electronic communication must adhere to the above and furthermore be approved for conducting specified purposes of The Ikoku Philanthropies via unanimous agreement and consent of the following:
(3) Provided and Unrevoked Consent āĀ As with all actionable, applicable, approvable,Ā legitimate and official communication from, for, of, in, within or pertaining to The Ikoku Philanthropies, writing by electronic communication may be deemed validly delivered, and any contracts or agreements thereof dependably enforceable, only if delivered to a recipient who has provided an unrevoked and written consent to the use of such means of transmission and communication for the specified activityĀ pertaining to The Ikoku Philanthropies.
(4) Clear Conditions of ConsentĀ āĀ As with all actionable, applicable, approvable,Ā legitimate and official communication from, for, of, in, within or pertaining to The Ikoku Philanthropies, such electronic transmission is not formally authorized, and no contracts or agreements thereof are dependably enforceable, unless in addition to satisfying the aforementioned conditions ā as well as the requirements for consentĀ ā the consent to the transmission has been preceded by or includes a clear written statement to the recipient as to:
(5) Facsimile, Email, Message Boards andĀ Networks:Ā Furthermore, electronic communication or transmission shall include only:
No means of communication, notice, or notification by, from or on behalf of The Ikoku Philanthropies can, may or shall in itself entail any violation of confidentiality or privacy or any significant risk to the basic, civil and fundamental rights of a natural person ā nor shall the performance of any official agreements, contracts, duties or responsibilities of The Ikoku Philanthropies require such means of communication, notice, or notification. Where the conditions above and in the Codes and Policies have not been met The Ikoku Philanthropies considers such communication, notice, or notification to have not been authorized or approved and require that both the Founder be notified immediately and a remedy of the situation be promptly achieved.
Further References
Where duties, expectations, freedoms, principles, rights, responsibilities, standards as well as means, measures, methods, and practices are referred to, they are as delineated and described in the Codes and Policies. And unless where normally expected and the context otherwise clearly indicates ā for instance, there is only one primary company, The Ikoku Group, one Founder and one Owner ā words used in the singular include the plural, and the plural includes the singular.
Policies
Provision
As stated earlier, the governance of The Alvan Ikoku Philanthropies is, in important part, conducted via the following codes and policies:
Ikoku User Agreement
The Ikoku Philanthropies User Agreement and Code of Conduct, which
Founding Statement
Statement on Founding of The Ikoku Philanthropies (HTML)
Governance Statement
Statement on Governance of The Ikoku Philanthropies (HTML)
Founding Code of Ethics
Founding Code of Ethics (HTML)
Privacy and Confidentiality
Policy on Privacy and Confidentiality (HTML)
Terms and Conditions
Terms and Conditions of Use and Service (HTML)
The Acceptable Uses Policy
Acceptable Use Policy (HTML)
Associated Policies
Accessibility and Disability
Accessibility and Disability (HTML)
Conflicts of Interest
Conflicts of Interest (HTML)
Data and Information
Data and Information (HTML)
Discrimination and Harassment
Discrimination and Harassment (HTML)
Diversity and Inclusion
Diversity and Inclusion (HTML)
Fairness and Justice
Fairness and Justice (HTML)
Financial Transactions
Financial Transactions (HTML)
Forced Labor, Trafficking, Slavery
Forced Labor, Trafficking, Slavery (HTML)
Human Subjects Research and Investigation
Human Subjects Research and InvestigationĀ (HTML)
Intellectual Property
Policy on Intellectual Property (HTML)
Members and Voting
Members and Voting (HTML)
Organizational Independence
Organizational IndependenceĀ (HTML)
Organizational Integrity
Organizational Integrity (HTML)
Private Nature and Public Good
Private Nature and Public Good (HTML)
Reasonable Transparency
Reasonable Transparency (HTML)
Safety and Security
Safety and Security (HTML)
Societal Impact and Sustainability
Societal Impact and Sustainability (HTML)
Updates and Keeping Informed
Once again, by continuing to engage in activity within, on behalf of, and in reference to The Ikoku Philanthropies, and by continuing to visit and use the Products and Services, you indicate that you understand that The Ikoku Philanthropies reserves the right to update the Codes and Policies from time to time, and at any time, and that you are encouraged to check back periodically to review the most current, updated version of the Codes and Policies. As a person or entity engaging in any activity with, within, for, on behalf of, in reference or otherwise pertaining to The Ikoku Philanthropies, or a visitor or user of the Products or Services, it remains your responsibility to keep informed about such posted changes.
Concluding
And as concluding aviso and proviso, you are informed as well as reminded that by conducting any activity at, by, for, in, on behalf of, with or otherwise pertaining to The Ikoku Philanthropies, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of The Ikoku Philanthropies, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the divisions, series, subsidiaries, or affiliates of The Ikoku Philanthropies, as well as any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the Products or Services of The Ikoku Philanthropies, you accept and agree to the conditions, principles, protections, requirements, standards, statements, and terms described above and in the Codes and Policies, regarding the Founding and Governance of The Ikoku Philanthropies, in their entirety without modification, including as updated from time to time by the Founder.
Ethics at the Company, in Company
The Codes and Policies above deeply reflect the founding and mission of The Ikoku Philanthropies and its parent company, The Ikoku Group. They inform the work of The Ikoku Philanthropies and The Ikoku Group and efforts to achieve benefit, impact, and success. The result, therefore, are three features evident in the division and company, their products and services, and most importantly, their communities:
A Company of and about Ethics
A company and division whose ethics and policies are carefully crafted, then adhered to by a range of individuals and entities working in varied relation to The Ikoku Group and The Ikoku Philanthropies to establish, develop and operate a private company dedicated to fostering care and creativity, ethics and innovation.
Built with Integrity and Respect in Mind
A company and division who take as their basis the most robust conceptions of humanity, integrity and respect as well as independence and fundamental freedoms, liberties and rights ā up to and beyond what the law protects and provides for ā as they carry out and embody their founding and core mission and purposes.
Areas of Focus Chosen for Mission and Work
And a company and division whose areas of focus have been expressly chosen to ensure attention to issues of enduring concern to the Founder ā and so committed to providing products, services, sites and spaces that remain safe, secure and respectful places to do work, to teach and learn, to form, inform and, where needed, transform local and global communities.