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.

There are fifteen (15) overarching principles of processing personal data and information. Publiks 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 section. In the meantime do keep in mind that, as much as feasibly and reasonably possible, Publiks endeavors to have processing of personal data and information fulfill all of the following:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

Below are subsequent criteria Publiks should follow to determine the applicability of this Policy to an activity or operation. It should be understood that Publiks 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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

Below are subsequent criteria Publiks 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 Publiks 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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

Below are subsequent criteria Publiks 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 Publiks 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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

Below are subsequent criteria Publiks 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 Publiks 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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

Below are subsequent criteria Publiks 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 Publiks 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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

Below are subsequent criteria Publiks should follow to determine and ensure the lawfulnessof processing data and information attributable to, identifying or otherwise relating to you. It should be understood that Publiks 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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

Below are subsequent criteria Publiks 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 Publiks 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:

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

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

Below are subsequent criteria Publiks 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 Publiks 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 Publiks upholds with respect to consent and its subsequent ethics requirements:

The second part consists of the standard Publiks 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 Publiks determines consent to be given and maintained only if and to the extent that the following standard has been met:

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 Publiks does regarding personal data and information. Publiks 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.

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:

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 Publiks endeavors to achieve and maintain a quality of informed consent meeting the above standard, by having all of the following apply:

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, Publiks still insists on treating you as a deciding human being and individual as much as possible, and so aftercarrying 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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its 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 Publiks should still normally be developed and conducted without resorting to personal profiling, surveillance or tracking.

Below are subsequent criteria Publiks 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 Publiks 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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

Below are subsequent criteria Publiks should follow to determine and maintain non-identificationwhen processing data and information attributable to, identifying or otherwise relating to you. It should be understood that Publiks 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 Publiks’ preferred (or normative) approach to design when it comes to handling personal data and information attributable to, identifying or otherwise relating to you:

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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

*you may learn more about the principles of protection and security by design and by default on this Policy section 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 section under Principles of Confidentiality and Privacy.

Below are subsequent criteria Publiks 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 Publiks 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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

Below are subsequent criteria Publiks 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 Publiks 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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its 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 Publiks should still normally be developed and conducted without resorting to personal profiling, surveillance or tracking.

Below are subsequent criteria Publiks 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 Publiks 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 Publiks determine or decide whether and what to treat as sensitive personal data and information:

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:

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 Publiks shall be expected to consider and possibly allow, as well as the conditions for such review:

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 Publiks expects to receive, asking to be added to the above narrow exception, and this Policy’s further expectation that Publiks 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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

*you may learn more about the principles of protection and security by design and by default on this Policy section 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 section under Principles of Confidentiality and Privacy.

Below are the subsequent criteria Publiks should follow when addressing any communication or notification to the public or to you. It should be understood that Publiks 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:

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 — Publiks determines such communication and notification to be reasonably transparent only if and to the extent that all of the following also apply:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

The principle of commensurability and its criteria delineated below are followed by Publiks 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. Publiks 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 Publiks. It consists of the following:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

The above principles of processing also provide you — as the natural or legal person concerned — fifteen (15) overarching rights of personal data and information. Publiks 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 section. 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 Publiks or Publiks 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, Publiks endeavors to have processing of personal data and information fulfill all of your following rights:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

As the natural or legal person concerned, you shall have the rights to be reasonably informed — solely by Publiks — 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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

As the natural or legal person concerned, you shall have the rights to be reasonably informed — solely by Publiks — 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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

As the natural or legal person concerned, you shall have the rights — to not be subject to — and also to be reasonably informed by Publiks 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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

As the natural or legal person concerned, you shall have the rights to confidentiality before, during and after Publiks 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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

As the natural or legal person concerned, you shall have the rights to privacy before, during and after Publiks 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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its 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.

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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

As the natural or legal person concerned, you shall have the rights to reasonably obtain from Publiks, 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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

As the natural or legal person concerned, you shall have the rights to reasonable notification of persons — solely by Publiks — 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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

The above principles of processing — and its attendant rights of personal data and information — also incur ten (10) central responsibilities for the administration and management of personal data and information and its processing. Publiks 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 section. In the meantime do keep in mind two opening points to be made here.

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

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

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

Publiks — 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. Publiks 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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

Publiks — 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. Publiks 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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

Publiks — 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. Publiks is responsible for deciding and controlling, for instance, the adequacy, appropriateness and effectiveness of such measures for specific data and information, its processing, as well as its administration and management. Such responsibilities require that all of the following apply:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

Publiks — 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. Publiks 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 Publiks can carry out for you. Such responsibilities therefore entail a one- or three-part evaluation, depending on the level of risk The Publiks Group discerns. The first part of the evaluation, which every proposed research or investigation undergoes, requires that all of the following apply:

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. Publiks should therefore conduct such a data processing risks assessment where there is any of the following:

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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

Publiks — 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 its processing. Such responsibilities require that all of the following apply:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

Publiks — 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. Publiks is responsible for ensuring that such measures and methods are optimally adequate, appropriate and effective for the data and information and its administration, management and processing. Such responsibilities require that all of the following apply:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

Publiks — 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 its administration, management and processing. Publiks 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:

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 Publiks 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:

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 Publiks 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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

Publiks — 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. Publiks shall have such responsibilities with respect to the Codes and Policies, its 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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

Publiks — 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 its processing. Such responsibilities require that all of the following apply:

Publiks shall create, maintain and safely keep all books and records for personal data and information and for its 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 its categorization, making sure they contain all of the following:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

Publiks — 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 its processing. Publiks 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:

And furthermore, by engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to Publiks, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of Publiks, 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 its entirety without modification.

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 Publiks 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. Publiks 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:

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. Publiks 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.

There are ten (10) broad sources — or points of activity and engagement — at and through which Publiks 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:

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 Publiks the policy on this matter is hopefully clear:

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. Publiks will inform and consent you accordingly. Then Publiks 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.

There are five (5) broad types — and twenty-five (25) specific categories — of personal data and information that Publiks 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 Publiks’ 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 —

Economic, Financial, Transactional —

Mental, Psychological, Preferences —

Physical, Physiological, Interactive —

Technological, Tracing, Tracking —

This is Serious! How Can I Protect and Enjoy Myself? — Publiks completely agrees: this is indeed a very serious matter. But you can still enjoy the Products and Services 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:

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 Publiks the policy on this matter is strict, highly respectful and hopefully clear:

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 its 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. Publiks will inform and consent you accordingly. Then Publiks 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.

The primary objective whenever Publiks 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 and Services, as well as with the affiliates, divisions, subsidiaries and varied sections of Publiks. One way of ensuring this occurs is by clarifying the ten (10) categories of purposes Publiks 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:

Visiting with No Personal Data or Information: Finally, Publiks 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, Publiks 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 and Services. 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 and Services — as is customary, expected and hopefully understandable.

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

Visiting with No Personal Data or Information: Finally, Publiks 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, Publiks 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 and Services. 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 and Services — as is customary, expected and hopefully understandable.

Publiks 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 Publiks would classify and treat as non-personal data and information:

As may be evident from the explanation above, the sources — or points of activity and engagement — where Publiks 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:

Visiting and Non-Personal Data and Information: Finally, Publiks 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, Publiks 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 and Services. 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 and Services — as is customary, expected and hopefully understandable.

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, Publiks clarify below the only official recipients of data and information, whether personal or non-personal, and its administration, management and processing. Most all of the individual recipients shall be internal to Publiks and The Ikoku Group. And Publiks furthermore ensures that all such specific individual recipients shall be reviewed, vetted and authorized by the Founder and Publiks 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 its sole authorizer:

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.

As stated earlier, The Publiks User Agreement and Code of Conduct consist of several Codes and Policies that collectively govern all of your activity with, within, for, in reference to and otherwise pertaining to Publiks, including its series, subsidiaries, and affiliates, and the Products and Services. By continuing, you indicate that you understand that the Codes and Policies include — but are not limited to — the Founding and Mission Statement, the Founding and Governing Code of Ethics, the Policy on Privacy and Confidentiality, the Terms and Conditions of Use and Service, and the Acceptable Uses Policy along with all Associated Codes and Policies. Access to the aforementioned is provided below.

Statement on Founding and Mission of Publiks (HTML)

Founding Code of Ethics (HTML)

Policy on Privacy and Confidentiality (HTML)

Terms and Conditions of Use and Service (HTML)

Acceptable Use Policy (HTML)

All Policies (HTML)