Conditions
Introduction
The Policy on Data and Information delineates the conditions, principles, and protections for data and information that are integral to the Agreement you enter into whenever — and wherever — you commence or continue any conduct or service relating in any way, directly or indirectly, to Publiks. Please, therefore, take the time to read what follows carefully.
Your Policy Agreements
Section 11.1.0. First, with respect to the Data and Information Policy you enter into via your Agreement with the Codes and Policies, you understand and agree to abide by the following:
11.1.1. Policy, Name, Nature
that the name of this Policy is the “Policy on Data and Information of Publiks Inc and The Publiks Group” (the “Data and Information Policy,” the “Data Policy,” and the “Information Policy”) and that the nature of this Policy is to serve as the policy on data and information of Publiks Inc and The Publiks Group;
11.1.2. Policy, Composition
that the Data and Information Policy consists of all conditions, principles, protections, and equivalent provisions for data and information in the Codes and Policies of Publiks Inc and The Publiks Group (the “Codes and Policies” and the “Policies”) and the Publiks Conduct and Service Agreement (the “Agreement”), which therefore include, but are not limited to, those delineated below;
11.1.3. Policy, Agreement
that you understand the Data and Information Policy to be an integral part of the Codes and Policies and the Agreement you enter into with Publiks;
11.1.4. Policy, Consent
that your consent to the Codes and Policies and the Agreement includes your legally equivalent consent to the Data and Information Policy;
11.1.5. Policy, Duties
that your duties to the Codes and Policies and the Agreement includes your legally equivalent duties to the Data and Information Policy;
11.1.6. Policy, Entry
that your entry into the Agreement includes your legally equivalent entry into the Data and Information Policy, and similarly occurs whenever you commence or continue any conduct or service at, by, for, in, on, with or otherwise relating to Publiks;
11.1.7. Policy, Legally Abiding
that your attestation about your reading, understanding, consenting and agreeing to legally abide by the Codes and Policies and the Agreement includes your legally attestation about your reading, understanding, consenting and agreeing to legally abide by the Data and Information Policy, in its entirety without modification or severability, as amended from time to time solely by the Founder;
11.1.8. Policy, Legally Binding
that your attestation about your reading, understanding, consenting and agreeing to be legally bound by the Codes and Policies and the Agreement includes your legally equivalent attestation about your reading, understanding, consenting and agreeing to be legally bound by the Data and Information Policy, in its entirety without modification or severability, as amended from time to time solely by the Founder;
11.1.9. Policy, Knowledge
that your attestation about your awareness and acceptance of your responsibility to keep informed and update your knowledge of the Codes and Policies and the Agreement includes your legally equivalent awareness and acceptance of your responsibility to keep informed and update your knowledge of the Data and Information Policy, in its entirety without modification or severability, as amended from time to time solely by the Founder.
Your Policy Understandings
Section 11.2.0. Second, with respect to your understandings of the Data and Information Policy, you covenant, represent, and warrant the following:
11.2.1. Policy Understandings
that you have read, understood, consented to, and agreed to be legally bound by and abide by applicable understandings of data and information as they are normally operative and reasonably interpreted in law, policy, and society;
11.2.1.1. Policy Understandings, A
the above including such understandings of data protecting, providing for, and otherwise pertaining to material and matter that are often collected, processed and stored in character, numerical or other symbolic form, representing continuous or discrete values that convey and describe factual, qualitative, quantitative, statistical, or other aspects of an activity, occurrence, person, phenomenon, situation, or equivalent and related analysis, inquiry, measurement, observation, query, research, or study;
11.2.1.2. Policy Understandings, B
the above including such understandings of information protecting, providing for, and otherwise pertaining to material and matter about an activity, occurrence, person, phenomenon, situation, or equivalent that are collected, communicated, recorded or stored and have the ability to inform or provide facts, insight, knowledge, or meaning;
11.2.2. Policy Understandings, Conditions
that you have read, understood, consented to, and agreed to be legally bound by and abide by understandings of data and information conditions as they are defined and provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation, to be fulfilled and respected and not breached or violated, in any way, by you;
11.2.3. Policy Understandings, Definitions
that you have read, understood, consented to, and agreed to be legally bound by and abide by understandings of data and information definitions as they are defined and provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation, to be fulfilled and respected and not breached or violated, in any way, by you;
11.2.4. Policy Understandings, Practices
that you have read, understood, consented to, and agreed to be legally bound by and abide by understandings of data and information practices as they are defined and provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation, to be fulfilled and respected and not breached or violated, in any way, by you;
11.2.5. Policy Understandings, Principles
that you have read, understood, consented to, and agreed to be legally bound by and abide by understandings of data and information principles as they are defined and provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation, to be fulfilled and respected and not infringed or violated, in any way, by you;
11.2.6. Policy Understandings, Processes
that you have read, understood, consented to, and agreed to be legally bound by and abide by understandings of data and information processes as they are defined and provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation, to be fulfilled and respected and not breached or violated, in any way, by you;
11.2.7. Policy Understandings, Rights
that you have read, understood, consented to, and agreed to be legally bound by and abide by understandings of data and information rights as they are defined and provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation, to be fulfilled and respected and not infringed or violated, in any way, by you;
11.2.8. Policy Understandings, Safeguards
that you have read, understood, consented to, and agreed to be legally bound by and abide by understandings of data and information safeguards and resulting protections as they are defined and provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation, to be fulfilled and respected and not breached or violated, in any way, by you;
11.2.9. Policy Understandings, Violations
that you have read, understood, consented to, and agreed to be legally bound by and abide by understandings of data and information breach, diminishment, incompatibility, infringement, and violation as they are defined and provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation, to not be brought about, in any way, by you.
Your Policy Commitments
Section 11.3.0. Third, with respect to your commitments to the Data and Information Policy, you understand and agree to abide by the following:
11.3.1. Policy Commitments, Basis
that your commitment is the basis for any conduct or service at, by, for, in, on, with, or otherwise relating to Publiks that you commence or continue — including via any of the Products or Services, or the divisions, series, subsidiaries, or affiliates — and that any such conduct or service is free of any infringement of the most humane, protective and respectful interpretations of data and information, the Data and Information Policy, the Codes and Policies, and applicable law and regulation;
11.3.2. Policy Commitments, Conditions
that this commitment include but not be limited to upholding for every person at Publiks the most humane, protective and respectful interpretations of data and information conditions, including as provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation;
11.3.3. Policy Commitments, Definitions
that this commitment include but not be limited to upholding for every person at Publiks the most humane, protective and respectful interpretations of data and information definitions, including as provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation;
11.3.4. Policy Commitments, Principles
that this commitment include but not be limited to upholding for every person at Publiks the most humane, protective and respectful interpretations of data and information principles, including as provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation;
11.3.5. Policy Commitments, Processes
that this commitment include but not be limited to upholding for every person at Publiks the most humane, protective and respectful interpretations of data and information processes, including as provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation;
11.3.6. Policy Commitments, Rights
that this commitment include but not be limited to upholding for every person at Publiks the most humane, protective and respectful interpretations of data and information rights, including as provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation;
11.3.7. Policy Commitments, Safeguards
that this commitment include but not be limited to upholding for every person at Publiks the most humane, protective and respectful interpretations of data and information safeguards and resulting protections, including as provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation;
11.3.8. Policy Commitments, Practices
that you respectfully assist solely via Your Duties as described in the Codes and Policies and the Data and Information Policy and in no way interfere with or impede the reasonable efforts authorized and executed solely by the Founder to translate the aforementioned commitments into practices for adopting and applying policies pertaining to data and information; for adjudicating and determining compliance with the policies; and for fulfilling Publiks’s own duties pertaining to data and information, data and information conditions, data and information definitions, data and information principles, data and information processes, data and information rights, and data and information safeguards and their resulting protections, including as provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation;
11.3.9. Policy Commitments, Protections
that you also respectfully assist solely via Your Duties as described in the Codes and Policies and the Data and Information Policy and in no way interfere with or impede the reasonable efforts authorized and executed solely by the Founder to develop and enforce data and information protections derived from, first, applicable law and regulation, and second, from advances in data and information that protect persons in ways that go beyond what such law and regulation currently provides.
Principles
Provision
The Policy on Data and Information requires your adherence to the conditions above and correlative conditions and principles delineated below.
A — On Data
Conditions for Data
Section 11.5.0. With respect to conditions for data and data administration, you understand and agree to abide by the following:
11.5.1. Data Conditions
that, in addition to your Agreement, you do not infringe, in any way, the ensuing conditions for data and data administration;
11.5.2. Data Conditions, Administration
that the data and data administration of Publiks and provisions attendant to such data and data administration — as administered solely by the Founder, and executed solely via the Founder’s authorization — are attained, maintained and protected, and not infringed in any way;
11.5.3. Data Conditions, Areas
that data and data administration in areas, offices, parts, properties, sections, and equivalent of Publiks — and attendant principles and provisions for such data and data administration — are attained, maintained and protected, and not infringed in any way;
11.5.4. Data Conditions, Founder
that data and data administration for the Founder and Founder-related activities, administration, conduct, and service — and attendant principles and provisions for such data and data administration — are attained, maintained and protected, and not infringed in any way;
11.5.5. Data Conditions, Ownership
that the data ownership of Publiks and Publiks Administration and the rights attendant to such data ownership — including that providing for and otherwise pertaining to the data interests-, share-, stake- and stock-holding, ownership, and equivalent of Publiks and Publiks Administration, solely and wholly by the Founder, Alvan Azinna Chibuzo Ikoku — are attained, maintained and protected, and not infringed in any way;
11.5.7. Data Conditions, Reporting
that measures for reporting actual, anticipated or apparent infringement related to data and data administration at Publiks — and attendant principles and provisions for such reporting — are attained, maintained and protected, and not infringed in any way;
11.5.6. Data Conditions, Practices
that practices for ensuring data and data administration at Publiks, including through its conduct and service — and attendant principles and provisions for such practices — are attained, maintained and protected, and not infringed in any way;
11.5.7. Data Conditions, Reporting
that measures for reporting actual, anticipated or apparent infringement related to data and data administration at Publiks — and attendant principles and provisions for such reporting — are attained, maintained and protected, and not infringed in any way;
11.5.8. Data Conditions, Understanding
with the understanding that the aforementioned and other conditions for data and data administration at Publiks are authorized, administered and adjudicated for compliance solely by the Founder, and executed solely via the Founder’s authorization.
Duties for Data
Section 11.6.0. With respect to duties for data and data administration, you understand and agree to abide by the following:
11.6.1. Data Duties
that, in addition to your Agreement, you fulfill and do not infringe, in any way, the ensuing duties for data and data administration;
11.6.2. Data Duties, Activity
that you have a duty to maintain and not infringe, in any way, the data and data administration of an act or activity of Publiks;
11.6.3. Data Duties, Agent
that you have a duty to maintain and not infringe, in any way, the data and data administration of an agent, party, or other person of Publiks;
11.6.4. Data Duties, Arrangement
that you have a duty to maintain and not infringe, in any way, the data and data administration of an arrangement of Publiks;
11.6.5. Data Duties, Conduct, Service
that you have a duty to maintain and not infringe, in any way, the data and data administration of a conduct or service of Publiks;
11.6.6. Data Duties, Entity, Organization
that you have a duty to maintain and not infringe, in any way, the data and data administration of Publiks Inc and The Publiks Group, including as proprietary and protective organizations and as entities of proprietary and protective administration;
11.6.7. Data Duties, Expectation
that you have a duty to consider and not infringe, in any way, an expectation pertaining to data and data administration at Publiks that is meaningful and reasonable;
11.6.8. Data Duties, Material
that you have a duty to maintain and not infringe, in any way, the data and data administration of a material of Publiks;
11.6.9. Data Duties, Matter
that you have a duty to maintain and not infringe, in any way, the data and data administration of a matter of Publiks;
11.6.10. Data Duties, Procedure
that you have a duty to maintain and not infringe, in any way, the data and data administration of a procedure, proceeding, or process of Publiks;
11.6.11. Data Duties, Relation
that you have a duty to maintain and not infringe, in any way, the data and data administration of a relation or relationship of Publiks;
11.6.12. Data Duties, Request
that you have a duty to consider and not infringe, in any way, a request pertaining to data and data administration at Publiks that is meaningful and reasonable;
11.6.13. Data Duties, Understanding
with the understanding that your sole means of fulfilling the aforementioned and other duties for data and data administration is by refraining from and reporting — via fully informing communication directly to the Founder — any infringement of data and data administration, and furthermore, not in any way diminishing or hindering the Founder’s sole discretion and powers to adjudicate and remedy such infringements.
Rights for Data
Section 11.7.0. With respect to rights for data and data administration, you understand and agree to abide by the following:
11.7.1. Data Rights
that, in addition to your Agreement, you respect and do not infringe, in any way, the ensuing rights for data and data administration;
11.7.2. Data Rights, Civil
that you respect and do not infringe, in any way, rights for data and data administration accorded to persons at Publiks by their applicable state or territorial governments;
11.7.3. Data Rights, Legal
that you respect and do not infringe, in any way, rights for data and data administration accorded to persons at Publiks by applicable law and regulation;
11.7.4. Data Rights, Entity, Organization
that you respect and do not infringe, in any way, rights for data and data administration of Publiks, including rights of data and data administration accorded to Publiks Inc and The Publiks Group, as proprietary and protective organizations and entities of proprietary and protective administration, via the Codes and Policies;
11.7.5. Data Rights, Human
that you respect and do not infringe, in any way, human and natural rights for data and data administration accorded to natural persons at Publiks via the Codes and Policies, including absolute rights for data and data administration of a human’s inner being, body, brain, as well as inner self, soul, spirit;
11.7.6. Data Rights, Understanding
with the understanding that your sole means of respecting the aforementioned and other rights for data and data administration is by refraining from and reporting — via fully informing communication directly to the Founder — any infringement of data and data administration, and furthermore, not in any way diminishing or hindering the Founder’s sole discretion and powers to adjudicate and remedy such infringements.
Safeguards for Data
Section 11.8.0. With respect to safeguards for data and data administration, you understand and agree to abide by the following:
11.8.1. Data Safeguards
that, in addition to your Agreement, you maintain and do not infringe, in any way, the ensuing safeguards for data and data administration;
11.8.2. Data Safeguards, Activity
that you maintain and not infringe, in any way, practices, processes, protections, and other provisions to safeguard the data and data administration of an act or activity of Publiks;
11.8.3. Data Safeguards, Agent
that you maintain and not infringe, in any way, practices, processes, protections, and other provisions to safeguard the data and data administration of an agent, party, or other person of Publiks;
11.8.4. Data Safeguards, Arrangement
that you maintain and not infringe, in any way, practices, processes, protections, and other provisions to safeguard the data and data administration of an arrangement of Publiks;
11.8.5. Data Safeguards, Conduct, Service
that you maintain and not infringe, in any way, practices, processes, protections, and other provisions to safeguard the data and data administration of a conduct or service of Publiks;
11.8.6. Data Safeguards, Entity, Organization
that you maintain and not infringe, in any way, practices, processes, protections, and other provisions to safeguard the data and data administration of Publiks Inc and The Publiks Group, including as proprietary and protective organizations and as entities of proprietary and protective administration;
11.8.7. Data Safeguards, Expectation
that you consider and not infringe, in any way, an expectation to safeguard data and data administration at Publiks that is meaningful and reasonable;
11.8.8. Data Safeguards, Material
that you maintain and not infringe, in any way, practices, processes, protections, and other provisions to safeguard the data and data administration of a material of Publiks;
11.8.9. Data Safeguards, Matter
that you maintain and not infringe, in any way, practices, processes, protections, and other provisions to safeguard the data and data administration of a matter of Publiks;
11.8.10. Data Safeguards, Procedure
that you maintain and not infringe, in any way, practices, processes, protections, and other provisions to safeguard the data and data administration of a procedure, proceeding, or process of Publiks;
11.8.11. Data Safeguards, Relation
that you maintain and not infringe, in any way, practices, processes, protections, and other provisions to safeguard the data and data administration of a relation or relationship of Publiks;
11.8.12. Data Safeguards, Request
that you consider and not infringe, in any way, a request to safeguard data and data administration at Publiks that is meaningful and reasonable;
11.8.13. Data Safeguards, Rights
that you maintain and not infringe, in any way, practices, processes, protections, and other provisions to safeguard rights for data and data administration, including rights to such safeguards;
11.8.14. Data Safeguards, Understanding
with the understanding that your sole means of maintaining the aforementioned and other safeguards for data and data administration is by refraining from and reporting — via fully informing communication directly to the Founder — any infringement of data and data administration, and furthermore, not in any way diminishing or hindering the Founder’s sole discretion and powers to adjudicate and remedy such infringements.
B — On Information
Conditions for Information
Section 11.9.0. With respect to conditions for information and information administration, you understand and agree to abide by the following:
11.9.1. Information Conditions
that, in addition to your Agreement, you do not infringe, in any way, the ensuing conditions for information and information administration;
11.9.2. Information Conditions, Administration
that the information and information administration of Publiks and provisions attendant to such information and information administration — as conducted solely by the Founder, and executed solely via the Founder’s authorization — are attained, maintained and protected, and not infringed in any way;
11.9.3. Information Conditions, Areas
that information and information administration in areas, offices, parts, properties, sections, and equivalent of Publiks — and attendant principles and provisions for such information and information administration — are attained, maintained and protected, and not infringed in any way;
11.9.4. Information Conditions, Founder
that information and information administration for the Founder and Founder-related activities, administration, conduct, and service — and attendant principles and provisions for such information and information administration — are attained, maintained and protected, and not infringed in any way;
11.9.5. Information Conditions, Ownership
that the information ownership of Publiks and Publiks Administration and the rights attendant to such information ownership — including that providing for and otherwise pertaining to the information interests-, share-, stake- and stock-holding, ownership, and equivalent of Publiks and Publiks Administration, solely and wholly by the Founder, Alvan Azinna Chibuzo Ikoku — are attained, maintained and protected, and not infringed in any way;
11.9.6. Information Conditions, Practices
that practices for ensuring information and information administration at Publiks, including through its conduct and service — and attendant principles and provisions for such practices — are attained, maintained and protected, and not infringed in any way;
11.9.7. Information Conditions, Reporting
that measures for reporting actual, anticipated or apparent infringement related to information and information administration at Publiks — and attendant principles and provisions for such reporting — are attained, maintained and protected, and not infringed in any way;
11.9.8. Information Conditions, Understanding
with the understanding that the aforementioned and other conditions for information and information administration at Publiks are authorized, administered and adjudicated for compliance solely by the Founder, and executed solely via the Founder’s authorization.
Duties for Information
Section 11.10.0. With respect to duties of information and information administration, you understand and agree to abide by the following:
11.10.1. Information Duties
that, in addition to your Agreement, you fulfill and do not infringe, in any way, the ensuing duties for information and information administration;
11.10.2. Information Duties, Activity
that you have a duty to maintain and not infringe, in any way, the information and information administration of an act or activity of Publiks;
11.10.3. Information Duties, Agent
that you have a duty to maintain and not infringe, in any way, the information and information administration of an agent, party, or other person of Publiks;
11.10.4. Information Duties, Arrangement
that you have a duty to maintain and not infringe, in any way, the information and information administration of an arrangement of Publiks;
11.10.5. Information Duties, Conduct, Service
that you have a duty to maintain and not infringe, in any way, the information and information administration of a conduct or service of Publiks;
11.10.6. Information Duties, Entity, Organization
that you have a duty to maintain and not infringe, in any way, the information and information administration of Publiks Inc and The Publiks Group, including as proprietary and protective organizations and as entities of proprietary and protective administration;
11.10.7. Information Duties, Expectation
that you have a duty to consider and not infringe, in any way, an expectation pertaining to information and information administration at Publiks that is meaningful and reasonable;
11.10.8. Information Duties, Material
that you have a duty to maintain and not infringe, in any way, the information and information administration of a material of Publiks;
11.10.9. Information Duties, Matter
that you have a duty to maintain and not infringe, in any way, the information and information administration of a matter of Publiks;
11.10.10. Information Duties, Procedure
that you have a duty to maintain and not infringe, in any way, the information and information administration of a procedure, proceeding, or process of Publiks;
11.10.11. Information Duties, Relation
that you have a duty to maintain and not infringe, in any way, the information and information administration of a relation or relationship of Publiks;
11.10.12. Information Duties, Request
that you have a duty to consider and not infringe, in any way, a request pertaining to information and information administration at Publiks that is meaningful and reasonable;
11.10.13. Information Duties, Understanding
with the understanding that your sole means of fulfilling the aforementioned and other duties for information and information administration is by refraining from and reporting — via fully informing communication directly to the Founder — any infringement of information and information administration, and furthermore, not in any way diminishing or hindering the Founder’s sole discretion and powers to adjudicate and remedy such infringements.
Rights for Information
Section 11.11.0. With respect to rights for information and information administration, you understand and agree to abide by the following:
11.11.1. Information Rights
that, in addition to your Agreement, you respect and do not infringe, in any way, the ensuing rights for information and information administration;
11.11.2. Information Rights, Civil
that you respect and do not infringe, in any way, rights for information and information administration accorded to persons at Publiks by their applicable state or territorial governments;
11.11.3. Information Rights, Legal
that you respect and do not infringe, in any way, rights for information and information administration accorded to persons at Publiks by applicable law and regulation;
11.11.4. Information Rights, Entity, Organization
that you respect and do not infringe, in any way, rights for information and information administration of Publiks, including rights of information and information administration accorded to Publiks Inc and The Publiks Group, as proprietary and protective organizations and entities of proprietary and protective administration, via the Codes and Policies;
11.11.5. Information Rights, Human
that you respect and do not infringe, in any way, human and natural rights for information and information administration accorded to natural persons at Publiks via the Codes and Policies, including absolute rights for information and information administration of a human’s inner being, body, brain, as well as inner self, soul, spirit;
11.11.6. Information Rights, Understanding
with the understanding that your sole means of respecting the aforementioned and other rights for information and information administration is by refraining from and reporting — via fully informing communication directly to the Founder — any infringement of information and information administration, and furthermore, not in any way diminishing or hindering the Founder’s sole discretion and powers to adjudicate and remedy such infringements.
Safeguards for Information
Section 11.12.0. With respect to safeguards for information and information administration, you understand and agree to abide by the following:
11.12.1. Information Safeguards
that, in addition to your Agreement, you maintain and do not infringe, in any way, the ensuing safeguards for information and information administration;
11.12.2. Information Safeguards, Activity
that you maintain and not infringe, in any way, practices, processes, protections, and other provisions to safeguard the information and information administration of an act or activity of Publiks;
11.12.3. Information Safeguards, Agent
that you maintain and not infringe, in any way, practices, processes, protections, and other provisions to safeguard the information and information administration of an agent, party, or other person of Publiks;
11.12.4. Information Safeguards, Arrangement
that you maintain and not infringe, in any way, practices, processes, protections, and other provisions to safeguard the information and information administration of an arrangement of Publiks;
11.12.5. Information Safeguards, Conduct, Service
that you maintain and not infringe, in any way, practices, processes, protections, and other provisions to safeguard the information and information administration of a conduct or service of Publiks;
11.12.6. Information Safeguards, Entity, Organization
that you maintain and not infringe, in any way, practices, processes, protections, and other provisions to safeguard the information and information administration of Publiks Inc and The Publiks Group, including as proprietary and protective organizations and as entities of proprietary and protective administration;
11.12.7. Information Safeguards, Expectation
that you consider and not infringe, in any way, an expectation to safeguard information and information administration at Publiks that is meaningful and reasonable;
11.12.8. Information Safeguards, Material
that you maintain and not infringe, in any way, practices, processes, protections, and other provisions to safeguard the information and information administration of a material of Publiks;
11.12.9. Information Safeguards, Matter
that you maintain and not infringe, in any way, practices, processes, protections, and other provisions to safeguard the information and information administration of a matter of Publiks;
11.12.10. Information Safeguards, Procedure
that you maintain and not infringe, in any way, practices, processes, protections, and other provisions to safeguard the information and information administration of a procedure, proceeding, or process of Publiks;
11.12.11. Information Safeguards, Relation
that you maintain and not infringe, in any way, practices, processes, protections, and other provisions to safeguard the information and information administration of a relation or relationship of Publiks;
11.12.12. Information Safeguards, Request
that you consider and not infringe, in any way, a request to safeguard information and information administration at Publiks that is meaningful and reasonable;
11.12.13. Information Safeguards, Rights
that you maintain and not infringe, in any way, practices, processes, protections, and other provisions to safeguard rights for information and information administration, including rights to such safeguards;
11.12.14. Information Safeguards, Understanding
with the understanding that your sole means of maintaining the aforementioned and other safeguards for information and information administration is by refraining from and reporting — via fully informing communication directly to the Founder — any infringement of information and information administration, and furthermore, not in any way diminishing or hindering the Founder’s sole discretion and powers to adjudicate and remedy such infringements.
C — On Processes
— of Administration
Section 11.13.0. With respect to powers and responsibilities pertaining to personal data and information, their processing, and the administration of both, you understand and agree to abide by the following:
11.13.1. Administration
that Publiks — and specifically the Founder, Alvan Azinna Chibuzo Ikoku — have and retain all powers and responsibilities pertaining to data and information, their processing, and the administration of both, executed solely via the Founder’s authorization, without liability, and with absolute, complete, sole discretion.
11.13.2. Administration, Authorizer
that Publiks — specifically the Founder, Alvan Azinna Chibuzo Ikoku — is the sole authorizer of data and information, their processing, and the administration of both.
11.13.3. Administration, Access, Actions
that Publiks — specifically the Founder, Alvan Azinna Chibuzo Ikoku — is the sole administrator and authorizer of access, actions, activities, conduct, service, and equivalent involving or pertaining to data and information, their processing, and the administration of both.
11.13.4. Administration, Applicability
that Publiks — specifically the Founder, Alvan Azinna Chibuzo Ikoku — is the sole administrator and authorizer with powers and responsibilities to determine and ensure the applicability of the Data and Information Policy to a given conduct or service, including any activity, agent, or arrangement, or involved material or matter.
11.13.5. Administration, Appropriateness
that Publiks — specifically the Founder, Alvan Azinna Chibuzo Ikoku — is the sole administrator and authorizer with powers and responsibilities to determine and ensure the appropriateness of data and information, their processing, and the administration of both.
11.13.6. Administration, Approval
that Publiks — specifically the Founder, Alvan Azinna Chibuzo Ikoku — is the sole administrator and authorizer with powers and responsibilities to determine and ensure adequate approval and certification of a given conduct or service subject to the Data and Information Policy.
11.13.7. Administration, Assignment
that Publiks — specifically the Founder, Alvan Azinna Chibuzo Ikoku — is the sole administrator and authorizer with powers and responsibilities to determine and ensure adequate assignment, delegation, and transfer of data and information, their processing, and the administration of both.
11.13.8. Administration, Care
that Publiks — specifically the Founder, Alvan Azinna Chibuzo Ikoku — is the sole administrator and authorizer with powers and responsibilities to determine and ensure adequate care in data and information, their processing, and the administration of both.
11.13.9. Administration, Categorization
that Publiks — specifically the Founder, Alvan Azinna Chibuzo Ikoku — is the sole administrator and authorizer with powers and responsibilities to determine and ensure adequate categorization and classification of data and information, their processing, and the administration of both.
11.13.10. Administration, Communication
that Publiks — specifically the Founder, Alvan Azinna Chibuzo Ikoku — is the sole administrator and authorizer with powers and responsibilities to determine and ensure adequate communication and notification pertaining to data and information, their processing, and the administration of both.
11.13.11. Administration, Confidentiality
that Publiks — specifically the Founder, Alvan Azinna Chibuzo Ikoku — is the sole administrator and authorizer with powers and responsibilities to determine and ensure adequate confidentiality of data and information, their processing, and the administration of both.
11.13.12. Administration, Consent
that Publiks — specifically the Founder, Alvan Azinna Chibuzo Ikoku — is the sole administrator and authorizer with powers and responsibilities to determine and ensure adequate consent for data and information, their processing, and the administration of both.
11.13.13. Administration, Documentation
that Publiks — specifically the Founder, Alvan Azinna Chibuzo Ikoku — is the sole administrator and authorizer with powers and responsibilities to determine and ensure adequate documentation of data and information, their processing, and the administration of both.
11.13.14. Administration, Infringement
that Publiks — specifically the Founder, Alvan Azinna Chibuzo Ikoku — is the sole administrator and authorizer with powers and responsibilities to determine and ensure adequate mitigation and notification of an infringement of data and information, their processing, or the administration of either.
11.13.15. Administration, Integrity
that Publiks — specifically the Founder, Alvan Azinna Chibuzo Ikoku — is the sole administrator and authorizer with powers and responsibilities to determine and ensure adequate integrity of data and information, their processing, and the administration of both.
11.13.16. Administration, Lawfulness
that Publiks — specifically the Founder, Alvan Azinna Chibuzo Ikoku — is the sole administrator and authorizer with powers and responsibilities to determine and ensure the lawfulness of data and information, their processing, and the administration of both.
11.13.17. Administration, Minimization
that Publiks — specifically the Founder, Alvan Azinna Chibuzo Ikoku — is the sole administrator and authorizer with powers and responsibilities to determine and ensure adequate minimization of data and information, their processing, and the administration of both.
11.13.18. Administration, Necessity
that Publiks — specifically the Founder, Alvan Azinna Chibuzo Ikoku — is the sole administrator and authorizer with powers and responsibilities to determine and ensure adequate necessity of data and information, their processing, and the administration of both.
11.13.19. Administration, Neutrality
that Publiks — specifically the Founder, Alvan Azinna Chibuzo Ikoku — is the sole administrator and authorizer with powers and responsibilities to determine and ensure adequate neutrality of data and information, their processing, and the administration of both.
11.13.20. Administration, Non-Identification
that Publiks — specifically the Founder, Alvan Azinna Chibuzo Ikoku — is the sole administrator and authorizer with powers and responsibilities to determine and ensure adequate non-identification of data and information, their processing, and the administration of both.
11.13.21. Administration, Privacy
that Publiks — specifically the Founder, Alvan Azinna Chibuzo Ikoku — is the sole administrator and authorizer with powers and responsibilities to determine and ensure adequate privacy of data and information, their processing, and the administration of both.
11.13.22. Administration, Protection
that Publiks — specifically the Founder, Alvan Azinna Chibuzo Ikoku — is the sole administrator and authorizer with powers and responsibilities to determine and ensure adequate protection of data and information, their processing, and the administration of both.
11.13.23. Administration, Safety
that Publiks — specifically the Founder, Alvan Azinna Chibuzo Ikoku — is the sole administrator and authorizer with powers and responsibilities to determine and ensure adequate safety of data and information, their processing, and the administration of both.
11.13.24. Administration, Security
that Publiks — specifically the Founder, Alvan Azinna Chibuzo Ikoku — is the sole administrator and authorizer with powers and responsibilities to determine and ensure adequate security of data and information, their processing, and the administration of both.
11.13.25. Administration, Sensitivity
that Publiks — specifically the Founder, Alvan Azinna Chibuzo Ikoku — is the sole administrator and authorizer with powers and responsibilities to determine and ensure adequate sensitivity of data and information, their processing, and the administration of both.
11.13.26. Administration, Standardization
that Publiks — specifically the Founder, Alvan Azinna Chibuzo Ikoku — is the sole administrator and authorizer with powers and responsibilities to determine and ensure adequate standardization of data and information, their processing, and the administration of both.
— of Applicability
Section 11.14.0. With respect to determining and ensuring the applicability of the Data and Information Policy to a given conduct or service, you understand and agree to abide by the following criteria:
11.14.1. Applicability, Distinctions
that the Data and Information Policy is applicable where the conduct or service — including any activity, agent, or arrangement, or involved material or matter — entail, require, or result in distinctions between what is “personal” and what is “non-personal,” as defined in the Codes and Policies.
11.14.2.1. Applicability, Person Concerned
that the Data and Information Policy is applicable where the conduct or service — including any activity, agent, or arrangement, or involved material or matter — specifically relates to a “natural or legal person concerned,” as defined in the Codes and Policies.
11.14.2.2. Applicability, Personal, Data
that the Data and Information Policy is applicable where the conduct or service involves “personal data and information,” as defined in the Codes and Policies.
11.14.2.3. Applicability, Processing
that the Data and Information Policy is applicable where the conduct or service constitutes “processing,” as defined in the Codes and Policies.
11.14.3. Applicability, Specification
and with all of the above met, further specification that the Data and Information Policy applies only to conduct or service relating to an authorized and recognized person, partner, party, research subject, user, visitor, or other consumer or customer of Publiks, narrowly defined, engaging in an activity, area, capacity, and manner authorized solely via the Founder’s authorization.
— of Appropriateness
Section 11.15.0. With respect to determining and ensuring the appropriateness of personal data and information, their processing, and the administration of both, you understand and agree to abide by the following:
11.15.1. Appropriateness, Basis
that the aspects, characteristics, and parameters of personal data and information, their processing, and the administration of both are appropriate and efficacious for their authorized and consented purpose.
11.15.2. Appropriateness, Compliance
that such personal data and information, processing, and administration are appropriately and efficaciously compliant with policies, principles, and protections provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation.
11.15.3. Appropriateness, Content
that the content of personal data and information, their processing, and the administration of both is appropriate and efficacious for their authorized and consented purpose.
11.15.4. Appropriateness, Context
that the context of personal data and information, their processing, and the administration of both — e.g. area, device, office, place, product, service, site, space, and equivalent — is appropriate and efficacious for the authorized and consented data and information, processing, administration, and purpose.
11.15.5. Appropriateness, Means
that the means of personal data and information, their processing, and the administration of both — e.g. administrative, organizational and technical measure, mechanism, method, procedure, system, technology, and equivalent — is appropriate and efficacious for the authorized and consented data and information, processing, administration, and purpose.
11.15.6. Appropriateness, Nature
that the nature of personal data and information, their processing, and the administration of both — e.g. category, form, genre, language, medium, personal or identifying capacity, sensitivity, type, and equivalent — is appropriate and efficacious for the authorized and consented data and information, processing, administration, and purpose.
11.15.7. Appropriateness, Person
that the person relating to personal data and information, their processing, and the administration of both — e.g. agent, conductor, customer, effector, facilitator, processor, provider, recipient, servicer, source, subject, user, visitor, and equivalent — is appropriate and efficacious for the authorized and consented data and information, processing, administration, and purpose.
11.15.8. Appropriateness, Purpose
that the purpose for personal data and information, their processing, and the administration of both — e.g. application, benefit, end, goal, impact, interest, objective, use, and equivalent — is appropriate and efficacious as well as compliant with data and information policies, principles, and protections.
11.15.9. Appropriateness, Quality
that the quality of personal data and information, their processing, and the administration of both — e.g. accuracy, availability, definition, completeness, consistency, integrity, organization, precision, timeliness, uniqueness, validity, and equivalent — is appropriate and efficacious for the authorized and consented data and information, processing, administration, and purpose.
11.15.10. Appropriateness, Scope
that the scope of personal data and information, their processing, and the administration of both — e.g. duration, field, frequency, period, range, scale, size, volume, and equivalent — is appropriate and efficacious for the authorized and consented data and information, processing, administration, and purpose.
— of Approval
Section 11.16.0. With respect to determining and ensuring adequate approval and certification of a given conduct or service subject to the Data and Information Policy, you understand and agree to abide by the following criteria:
11.16.1. Approval, Basis
that the data review board of Publiks (the “DRB”), including the Founder, Alvan Azinna Chibuzo Ikoku, initially then continually or periodically reviews and either approves or disapproves all conduct and service subject to the Data and Information Policy, before, during and after any access or collection of data and information, their processing, and the administration of both.
11.16.2. Approval, Application
that prior to any access or collection of data and information, their processing, and the administration of both, the DRB requires (a) submission of application detailing the aspects, characteristics, and parameters of the aforementioned; (b) where appropriate, modifications in such application to secure approval or compliance; and (c) where appropriate, DRB observation of the consent process and other processes pertaining to the data and information, their processing, and the administration of both.
11.16.3. Approval, Adherence
that the DRB requires the above application to demonstrate adherence to and compliance with the Data and Information Policy, the Codes and Policies, and applicable law and regulation prior to any possible approval.
11.16.4.1. Approval, Assessment, Benefit, Risk
that the DRB assesses for and confirms the actual and anticipated benefits for and risks to you — as the person concerned — of the activity, conduct, or service and the involved data and information, processing, and administration, including, where appropriate and feasible, review and citation of studies involving equivalent conduct, service, persons concerned, and other aspects, characteristics, and parameters of data and information, processing, and administration.
11.16.4.2. Approval, Assessment, Benign
that the DRB assesses for and confirms that any actual, anticipated and proposed activity, conduct, or service as well as involved data and information, processing, and administration are benign, as defined and provided for in the Codes and Policies.
11.16.4.3. Approval, Assessment, Consent
that the DRB assesses for and confirms that your consent is required, with no recourse to assent alone (that is, without your continually and fully informed knowledge, authorization, and attendant consent), and that all policies, principles, and protections for informed consent are fulfilled, as provided for in the Human Subjects Research Policy, the Codes and Policies, and applicable law and regulation.
11.16.4.4. Approval, Assessment, Risk Minimization
that the DRB assesses for means to ensure the actual and anticipated risks to you — as the person concerned — are minimized; and that in evaluating risk minimization, the DRB considers and strongly recommends (even restricts approval to) data and information, processing, and administration that are consistent with protective and sound design, that do not unnecessarily expose you and other persons concerned to risk, and that are necessary for the provision of the given conduct or service under review.
11.16.4.5. Approval, Assessment, Risk Relation
that the DRB assesses for and determines the actual and anticipated risks to you — as the person concerned — are both favorable and reasonable in relation to the actual and anticipated benefits to you.
11.16.4.6. Approval, Assessment, Risk Relation, Specified
that, in evaluating for the benefit-risk relation, the DRB considers only those benefits and risks that may result from the involved data and information, processing, and administration.
11.16.4.7. Approval, Assessment, Risk Relation, Unspecified
that, in evaluating for the benefit-risk relation, the DRB does not consider any possible long-range effects of knowledge (including its application) gained from the involved data and information, processing, and administration as among those benefits and risks that fall within the purview of its responsibility.
11.16.5.1. Approval, Monitoring, Consent
that the DRB assesses for and determines adequate provision for monitoring the consent process to ensure it adequately informs you — as the person concerned — and informed consent is sought from each prospective person concerned, in accordance with the Data and Information Policy, and via such monitoring the DRB confirms appropriate documentation of the consent process and informed consent.
11.16.5.2. Approval, Monitoring, Data
that the DRB assesses for and determines adequate provision for monitoring the involved data and information to ensure adherence to and fulfillment of policies, principles, and protections provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation, with respect to you — as the person concerned.
11.16.5.3. Approval, Monitoring, Data Administration
that the DRB assesses for and determines adequate provision for monitoring the administration of data and information, and their processing, to ensure adherence to and fulfillment of policies, principles, and protections provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation, with respect to you — as the person concerned.
11.16.5.4. Approval, Monitoring, Data Processing
that the DRB assesses for and determines adequate provision for monitoring the processing of data and information to ensure adherence to and fulfillment of policies, principles, and protections provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation, with respect to you — as the person concerned.
11.16.6.1. Approval, Review, Certification
that, where the above criteria are adequately met, any DRB approvals of data and information, their processing, and administration of both are confirmed then certified solely via the Founder’s authorization.
11.16.6.2. Approval, Review, Periodic
that the DRB periodically reviews and has authority to suspend or terminate approval of any data and information, their processing, or administration of either that is not being conducted in accordance with DRB requirements or that has been associated with unexpected serious harm to you or any other person concerned — and any suspension or termination of approval includes a written statement of the reasons for the DRB action and is reported promptly to Publiks, the Founder, and appropriate regulatory officials mandated by applicable law and regulation.
11.16.6.3. Approval, Review, Post
that where appropriate, data and information, their processing, and administration of both approved by the DRB may be subject to further post-DRB review (and approval or disapproval) by authorized official persons of Publiks — including the possibility of a recommended rejection of DRB decisions on grounds of actual or anticipated creation of difficult ethical, legal or policy problems — though such official persons cannot confer approval if the DRB has decided against approval.
— of Assignment
Section 11.17.0. With respect to determining and ensuring adequate assignment, delegation, and transfer of data and information, their processing, and the administration of both, you understand and agree to abide by the following:
11.17.1. Assignment, Authorization
that non-personal and personal data and information, their processing, and administration of both may be assigned, delegated or transferred to authorized and official persons external to Publiks — specifically, third-country and third-party entities, offices, and persons — only with explicit, legitimate and specific instructions and purposes from Publiks, as given via the DRB’s approval and Founder’s authorization.
11.17.2. Assignment, Attestation
that such assignment, delegation, or transfer is accompanied by an authorized and written contract or equivalent legal instrument — between Publiks and the recipient of the assignment, delegation, or transfer (the “assignee,” “delegate,” or “transferee”) — agreed to and signed by all parties and containing all of the following attestations.
11.17.2.1. Assignment, Attestation, Administration, Authorization
agreement and attestation by all parties that Publiks — specifically the Founder, Alvan Azinna Chibuzo Ikoku — is the primary administrator and sole authorizer of the data and information, their processing, and administration of both.
11.17.2.2. Assignment, Attestation, Arrangement, Purposes
agreement and attestation by all parties to (a) the overarching or ongoing arrangement, activity, or relationship under which the assignment, delegation, or transfer is conducted; (b) the authorized, consented, explicit, legitimate and specific purposes for the data and information, their processing, and administration of both; and (c a systematic evaluation of the regulatory environment of the assignee, delegate, or transferee with respect to standards for data and information policies, principles, and protections provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation.
11.17.2.3. Assignment, Attestation, Communication, Notification
agreement and attestation by all parties that the assignee, delegate, or transferee will implement authorized administrative, organizational and technical measures to adequately, appropriately and efficaciously ensure reasonably informing communication and notification pertaining to the data and information, their processing, and administration of both to all persons concerned.
11.17.2.4. Assignment, Attestation, Compliance
agreement and attestation by all parties that the assignee, delegate, or transferee will implement authorized administrative, organizational and technical measures to adequately, appropriately and efficaciously ensure the data and information, their processing, and administration of both are complaint with the policies, principles, and protections provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation.
11.17.2.5. Assignment, Attestation, Instructions, Purposes
agreement and attestation by all parties that the assignee, delegate, or transferee will carry out and fulfill only the explicit, legitimate and specific instructions and purposes delineated and described in the contract or equivalent legal instrument, including but not limited to specifications as to appropriate aspects, characteristics, and parameters of data and information, their processing, and administration of both.
11.17.2.6. Assignment, Attestation, Recipients, Operational
agreement and attestation by all parties that the assignee, delegate, or transferee will follow only documented instructions with respect to operational transfers of the data and information to recipients, categories of recipients, a third party, a third country or an international organization, and ensure the appropriate safeguards.
11.17.2.7. Assignment, Attestation, Recipients, Subsequent
agreement and attestation by all parties that the assignee, delegate, or transferee will not further or subsequently engage — including assign, delegate, or transfer any of the data and information, their processing, or administration of either to — another party, person, or recipient, except where given prior written approval and authorization by Publiks, specifically the Founder, Alvan Azinna Chibuzo Ikoku, as well as an additional written contract or equivalent legal instrument meeting these attestation standards and safeguard measures for principles, principles, and protections provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation.
11.17.2.8. Assignment, Attestation, Recordation
agreement and attestation by all parties that the assignee, delegate, or transferee will implement authorized administrative, organizational and technical measures to adequately, appropriately and efficaciously ensure compliance with and fulfillment of policies, principles, and protections for documentation pertaining to data and information, their processing, and administration of both.
11.17.2.9. Assignment, Attestation, Responsible Persons
the identity and contact information — for all parties involved — of the entities, offices, and persons, or their representatives, responsible for the data and information, their processing, administration of both, as well as their assignment, delegation, or transfer.
11.17.2.10. Assignment, Attestation, Single Action
where the transfer is a single-occurrence action without an ongoing arrangement with Publiks — as in the case of a single fulfillment of a request for data portability or interoperable transfer — agreement and attestation by all parties that the transferee has the informed consent of all persons concerned and will assume all liability for any breach, infringement, or violation of policies, principles, or protections provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation.
11.17.2.11. Assignment, Attestation, Termination
agreement and attestation by all parties that the assignee, delegate, or transferee will, on the decision and request of Publiks, delete, erase, or return all data and information and their copies, upon cessation, completion, end, or termination of the assignment, delegation, or transfer or its attendant contract or relationship.
11.17.2.12. Assignment, Attestation, Validity, Liability
agreement and attestation by all parties that the contract or equivalent legal instrument and the aforementioned conditions will be valid; will legally bind the assignee, delegate, or transferee with respect to Publiks — specifically the Founder, Alvan Azinna Chibuzo Ikoku — including but not limited to liabilities to Publiks; and will continue to be valid and legally bind even where the assignee, delegate, or transferee further assigns, delegates, engages, or transfers to another party, person, or recipient.
— of Aim, Purpose
Section 11.18.0. With respect to determining and ensuring adequate aims and purposes for personal data and information, their processing, and the administration of both, you understand and agree to abide by the following criteria:
11.18.1. Purpose, Basis
that each aim, objective, or purpose for personal data and information, their processing, and the administration of both is appropriate and reasonable to a sufficient degree to serve as the basis of an Agreement between Publiks and you — as the person concerned — as provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation.
11.18.2. Purpose, Consented
that such purpose is consented (or assented) to by you — as the person concerned.
11.18.3. Purpose, Ethical
that such purpose is ethical with respect to you — as the person concerned.
11.18.4. Purpose, Explicit
that such purpose is explicit, that is, clearly explained to you.
11.18.5. Purpose, Harm
that such purpose is not harmful to you — as the person concerned.
11.18.6. Purpose, Humane
that such purpose is humane, and not inhuman or inhumane, with respect to you — as the person concerned.
11.18.7. Purpose, Legal
that such purpose is law-abiding, lawful and legal with respect to you — as the person concerned.
11.18.8. Purpose, Legitimate
that such purpose is legitimate, that is, has a reasonable basis that is clear, expectable, transparent and understandable to you — as the person concerned.
11.18.8.1. Purpose, Legitimate, Activity
with legitimacy satisfied only where the purpose is not deceptive or misleading; not hidden or undisclosed; understood as integral to the activity being conducted or proposed; and thus reasonably clear, expectable, transparent and understandable to you — as the person concerned — given your understanding of the activity, conduct, product, or service.
11.18.8.2. Purpose, Legitimate, Appropriateness
with legitimacy satisfied only where the purpose is, as described above, reasonably clear, expectable, transparent and understandable to you — as the person concerned — given your understanding that such purpose is to be appropriate for the activity, conduct, product, or service.
11.18.8.3. Purpose, Legitimate, Efficacy
with legitimacy satisfied only where the purpose is, as described above, reasonably clear, expectable, transparent and understandable to you — as the person concerned — given your understanding that such purpose is to be efficacious for the activity, conduct, product, or service.
11.18.8.4. Purpose, Legitimate, Necessity
with legitimacy satisfied only where the purpose is, as described above, reasonably clear, expectable, transparent and understandable to you — as the person concerned — given your understanding that such purpose is to be necessary for the activity, conduct, product, or service.
11.18.8.5. Purpose, Legitimate, Proportion
with legitimacy satisfied only where the purpose is, as described above, reasonably clear, expectable, transparent and understandable to you — as the person concerned — given your understanding that such purpose is to be proportionate for the activity, conduct, product, or service.
11.18.8.6. Purpose, Legitimate, Regulation
with legitimacy satisfied only where the purpose is, as described above, reasonably clear, expectable, transparent and understandable to you — as the person concerned — given your understanding that such purpose is to be compliant with the policies, principles, and protections provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation.
11.18.8.7. Purpose, Legitimate, Relation
with legitimacy satisfied only where the purpose is, as described above, reasonably clear, expectable, transparent and understandable to you — as the person concerned — given your relationship to Publiks, for example, as an applicant, customer, employee, partner, third party, user, or visitor.
11.18.8.8. Purpose, Legitimate, Standard
with legitimacy satisfied only where the purpose is acceptable and, as described above, reasonably clear, expectable, transparent and understandable, per the field or industry of knowledge and practice of the activity, conduct, product, or service — given standards established and informed by prior knowledge and practice.
11.18.9. Purpose, Limited
and, where the purpose has been added to or altered from the original purpose, only if such new purpose is also limited, that is, close in nature to the original purpose, compatible and in keeping with your consent, and reasonably expected by you — as the person concerned — who will be informed of, review, and consent (or not consent) to the added or altered purpose as soon as reasonably possible.
11.18.10. Purpose, Protective
that such purpose is protective of and minimally risky to you — as the person concerned.
11.18.11. Purpose, Specific
that such purpose is specific, that is, clearly defined, delineated and specified to you — as the person concerned.
— of Care
Section 11.19.0. With respect to determining and ensuring adequate care in personal data and information, their processing, and the administration of both, you understand and agree to abide by the following criteria:
11.19.1. Care, Basis
that personal data and information, their processing, and the administration of both are conducted in a manner that optimally fulfills the care and ethics principles of beneficence, equipoise, justice, and non-maleficence with respect to you — as the person concerned — and then, where applicable and appropriate, to the community, environs, and field of generalizable knowledge in which such data and information, processing, and administration are conducted.
11.19.2. Care, Beneficence
that personal data and information, their processing, and the administration of both are conducted in a manner that ensures beneficence by providing benefit or utility to you — as the person concerned — via such data and information, processing, or administration.
11.19.2.1. Care, Beneficence, Benefit Priority
that personal data and information, their processing, and the administration of both are conducted in a manner that ensures beneficence by prioritizing provision of benefit or utility to you — as the person concerned — over, where applicable and appropriate, the community, environs, and field of generalizable knowledge in which such data and information, processing, and administration are conducted.
11.19.2.2. Care, Beneficence, Undue Inducement
that personal data and information, their processing, and the administration of both are conducted in a manner that ensures beneficence by avoiding the use, or reducing the effect, of benefits as undue inducement to elicit the consent of you — as the person concerned.
11.19.3. Care, Equipoise
that personal data and information, their processing, and the administration of both are conducted in a manner that ensures equipoise by not subjecting you — as the person concerned — to exploitative, substandard or unfavorable condition, outcome, or treatment via such data and information, processing, or administration.
11.19.3.1. Care, Equipoise, Interest Priority
that personal data and information, their processing, and the administration of both are conducted in a manner that ensures equipoise by prioritizing the interests and welfare of you — as the person concerned — over the interests of, where applicable and appropriate, the community, environs, and field of generalizable knowledge in which such data and information, processing, and administration are conducted.
11.19.3.2. Care, Equipoise, Non-Burden
that personal data and information, their processing, and the administration of both are conducted in a manner that ensures equipoise by refraining from inhumane, undue or unequal burden, treatment, or use on or of you — as the person concerned — via such data and information, processing, or administration.
11.19.3.3. Care, Equipoise, Non-Instrumentality
that personal data and information, their processing, and the administration of both are conducted in a manner that ensures equipoise by refraining from the instrumental use of you — as the person concerned — via such data and information, processing, or administration.
11.19.3.4. Care, Equipoise, Non-Utilitarianism
that personal data and information, their processing, and the administration of both are conducted in a manner that ensures equipoise by refraining from burdening, depriving, harming, imperiling, or sacrificing you — as the person concerned — for the greater good or the increased or maximal gain of a community, field, or state, via such data and information, processing, or administration.
11.19.3.5. Care, Equipoise, Termination
that personal data and information, their processing, and the administration of both are conducted in a manner that ensures equipoise by stopping or terminating wherever there is reason to believe, or even a remote possibility, that such exploitation, instrumentalization, non-prioritization, undue burden, or utilitarian use of you — as the person concerned — will result from such data and information, processing, or administration.
11.19.4. Care, Justice
that personal data and information, their processing, and the administration of both are conducted in a manner that ensures justice by not subjecting you — as the person concerned — to discriminatory or unlawful treatment via such data and information, processing, or administration.
11.19.4.1. Care, Justice, Non-Bias
that personal data and information, their processing, and the administration of both are conducted in a manner that ensures justice by not effecting or facilitating bias, discrimination, marginalization, or stigmatization against you — as the person concerned — via such data and information, processing, or administration.
11.19.4.2. Care, Justice, Non-Expediency
that personal data and information, their processing, and the administration of both are conducted in a manner that ensures justice by not effecting or facilitating inhumane compromise or expediency with respect to you — as the person concerned persons — for politics, profit, or public good, via such data and information, processing, or administration.
11.19.4.3. Care, Justice, Non-Infringement, Law
that personal data and information, their processing, and the administration of both are conducted in a manner that ensures justice by not infringing any data and information principles or protections with respect to you — as the person concerned — as provided for in applicable law and regulation.
11.19.4.4. Care, Justice, Non-Infringement, Policies
that personal data and information, their processing, and the administration of both are conducted in a manner that ensures justice by not infringing any data and information principles or protections with respect to you — as the person concerned — as provided for in the Data and Information Policy and the Codes and Policies.
11.19.4.5. Care, Justice, Non-Infringement, Rights
that personal data and information, their processing, and the administration of both are conducted in a manner that ensures justice by not infringing any civil liberties or rights accorded by your polities to you — as the person concerned — via such data and information, processing, or administration.
11.19.4.6. Care, Justice, Non-Vulnerability
that personal data and information, their processing, and the administration of both are conducted in a manner that ensures justice by assessing for and protecting vulnerable persons — including by accounting for a history of vulnerable populations, and therefore not engaging in, facilitating, or otherwise fostering any data and information conduct or service that is discriminatory, harmful, stigmatizing, unduly burdening, unprotective or otherwise unethical in relation to vulnerable populations.
11.19.5. Care, Non-Maleficence
that personal data and information, their processing, and the administration of both are conducted in a manner that ensures non-maleficence by optimally minimizing harm to you — as the person concerned — via such data and information, processing, or administration.
11.19.5.1. Care, Non-Maleficence, Harm Priority
that personal data and information, their processing, and the administration of both are conducted in a manner that ensures non-maleficence by prioritizing minimization of harm to you — as the person concerned — over, where applicable and appropriate, the community, environs, and field of generalizable knowledge in which such data and information, processing, and administration are conducted.
11.19.5.2. Care, Non-Maleficence, Undue Harm
that personal data and information, their processing, and the administration of both are conducted in a manner that ensures non-maleficence by assessing for and protecting against anticipated, excessive, undue, unexpected, unexplained or unnecessary harm of and to such data and information, processing, administration, and protections with respect to you — as the person concerned — and then, where applicable and appropriate, the community, environs, and field of generalizable knowledge in which such data and information, processing, and administration are conducted.
— of Categorization
Section 11.20.0. With respect to determining and ensuring adequate categorization and classification of personal data and information, their processing, and the administration of both, you understand and agree to abide by the following:
11.20.1. Categorization, Basis
that personal data and information, their processing, and the administration of both are accompanied by an adequate, appropriate and efficacious process of categorization and classification facilitating compliance with and fulfillment of policies, principles, and protections provided for in the Data and Information Policy, the Codes and Polices, and applicable law and regulation.
11.20.2.1. Categories, Data
that personal data and information, their processing, and the administration of both may involve up to six (6) categories and twenty-five (25) subcategories of data and information, personal and non-personal.
11.20.2.2. Categories, Data Sources
that personal data and information, their processing, and the administration of both may involve up to twelve (12) categories and thirty-six (36) subcategories of sources for such data and information, processing, and administration.
11.20.2.3. Categories, Persons
that personal data and information, their processing, and the administration of both may involve up to ten (10) categories of persons concerned, that is, attributable to, identifiable by, or otherwise relating to such data and information, processing, and administration.
11.20.2.4. Categories, Purposes
that personal data and information, their processing, and the administration of both may involve up to ten (10) categories of purposes for such data and information, processing, and administration.
11.20.2.5. Categories, Recipients
that personal data and information, their processing, and the administration of both may involve up to eight (8) categories of recipients of such data and information, processing, and administration.
—— of Categories of Data
Section 11.21.0. With respect to adequate categorization and classification of data and information, both personal and non-personal, you understand and agree to abide by the following:
11.21.1. Biographical —
that personal data and information, their processing, and the administration of both may involve data and information categorized as biographical, including the subcategories below.
11.21.1.1. Biographical, Birth, Life
such biographical data and information relating to your birth, life events, and personal history, including their effect and influences on you and your surroundings.
11.21.1.2. Biographical, Family
such biographical data and information relating to your family events, history, members, relationships, structure, and status changes.
11.21.1.3. Biographical, Personal Communication
such biographical data and information relating to your personal and private communications, conversations, and correspondence.
11.21.1.4. Biographical, Schooling, Training, Work
such biographical data and information relating to your education, schooling, training, and work events, history, and records.
11.21.2. Econographical —
that personal data and information, their processing, and the administration of both may involve data and information categorized as econographical, including the subcategories below.
11.21.2.1. Econographical, Accounts, Cards
such econographical data and information relating to your financial accounts, cards, instruments, and policies information and records.
11.21.2.2. Econographical, Assets, Properties
such econographical data and information relating to assets and intellectual and real properties you currently or previously acquire, borrow, develop, entrust, equip or furnish, insure, invest, lease, license, lien, occupy or reside in, own, pay taxes for, possess, register, rent or rent out, sell, or transact.
11.21.2.3. Econographical, Credit Capacity, Standing
such econographical data and information relating to your borrowing and credit capacity, records, reports, reputation, scores, standing, and worthiness.
11.21.2.4. Econographical, Earnings, Transactions
such econographical data and information relating to your earnings, income, philanthropic, tax and transactional activities, events, habits, history, and records.
11.21.3. Physiographical —
that personal data and information, their processing, and the administration of both may involve data and information categorized as physiographical, including the subcategories below.
11.21.3.1. Physiographical, Bodily, Physical
such physiographical data and information relating to your specific bodily, genetic, phenotypic and physical abilities, aspects, alterations, characteristics, conditions, dimensions, markings, scars, and states.
11.21.3.2. Physiographical, Cultural, Ethnic
such physiographical data and information relating to your cultural, ethnic, political and “racial” heritages, genealogies, identities, languages, lineages, origins, and practices.
11.21.3.3. Physiographical, Demographic, Epidemiological
such physiographical data and information relating to demographic, epidemiological and socioeconomic characteristics, ranges, and traits you share with others in classifications, cohorts, and populations.
11.21.3.4. Physiographical, Health, Medical
such physiographical data and information relating to your health, medical, fitness and wellness care, condition, events, history, information, procedures, records, results, status, and therapies.
11.21.4. Psychographical —
that personal data and information, their processing, and the administration of both may involve data and information categorized as psychographical, including the subcategories below.
11.21.4.1. Psychographical, Abstractions, Ideations
such psychographical data and information relating to your abstractions, apperceptions, conceptualizations, creativities, ideations, imaginations, inventions, narrations, and other conceptual events, relations, and states.
11.21.4.2. Psychographical, Affections, Associations
such psychographical data and information relating to your affections, affinities, associations, and other emotional instances, relations, and states.
11.21.4.3. Psychographical, Aptitudes, Knowledges
such psychographical data and information relating to your cognitive and mental abilities, aptitudes, intelligences, knowledges, learnings, and other epistemic instances, relations, and states.
11.21.4.4. Psychographical, Attentions, Experiences
such psychographical data and information relating to your attentions, awarenesses, experiences, memories, and other attentional events, relations, and states.
11.21.4.5. Psychographical, Attitudes, Intentions
such psychographical data and information relating to your attitudes, beliefs, convictions, dispositions, inclinations, intentions, interests, opinions, perspectives, preferences, proclivities, resolutions, tendencies and other attitudinal instances, relations, and states.
11.21.5. Sociographical —
that personal data and information, their processing, and the administration of both may involve data and information categorized as sociographical, including the subcategories below.
11.21.5.1. Sociographical, Behavioral
such sociographical data and information relating to your behaviors, choices, habits, and other behavioral events, relations, and states.
11.21.5.2. Sociographical, Interpersonal
such sociographical data and information relating to your interpersonal activities, friendships, life, networks, orientation, relationships, and other interpersonal events, relations, and states.
11.21.5.3. Sociographical, Societal
such sociographical data and information relating to your communal, political, public, social and societal activities, engagement, life, practice, service, status, and other societal events, relations, and states.
11.21.5.4. Sociographical, State
such sociographical data and information relating to your governmental and state records of activities, citizenship, identification, offenses, proceedings, registrations, residences, services, statuses, travels, voting, and work.
11.21.6. Technographical —
that personal data and information, their processing, and the administration of both may involve data and information categorized as technographical, including the subcategories below.
11.21.6.1. Technographical, Applications, Devices
such technographical data and information relating to applications, computers, devices, equipments, and other technologies that you specifically use.
11.21.6.2. Technographical, Contacts, Connections
such technographical data and information relating to your contacts, connections and network activities, addresses, events, history, information, records, and status via online, postal, technological, telecommunications and virtual means.
11.21.6.3. Technographical, Location, Motion
such technographical data and information relating to your geo- or positional location, motions, and movements, at any moment and over time, in and across a given area, block, building, city, country, county, distance, GPS coordinates, neighborhood, province, region, room, space, state, street, town, and village.
11.21.6.4. Technographical, Uniquely Identifying
such technographical data and information relating to identifiers that semi-uniquely or uniquely identifies you as part of either (a) private and authenticating activity, most often something only you or one other living person could access, know, or possess at a precise time; or (b) public and identifying activity, such as aliases, names, and usernames; biometric prints and recognition; government or institution-issued identification and numbers, handwriting and signatures, images, pictures, and video.
—— of Categories of Data Sources
Section 11.22.0. With respect to adequate categorization and classification of sources of data and information, both personal and non-personal, you understand and agree to abide by the following:
11.22.1. Account-Derivate —
that personal data and information, their processing, and the administration of both may involve sources of data and information categorized as account-derivative.
11.22.1.1. Account-Derivate, Authenticating
account-derivative authenticators or authenticating data and information (“acc-AUTHs”) that are derived from authentication you enable, engage in, or engender during your access, creation, and other use of accounts, profiles, and equivalent.
11.22.1.2. Account-Derivate, Identifying
account-derivative identifiers or identifying data and information (“acc-IDs”) that are derived from identification you enable, engage in, or engender during your access, creation, and other use of accounts, profiles, and equivalent.
11.22.1.3. Account-Derivate, Specifying
account-derivative specifiers or specifying data and information (“acc-SPECs”) that are derived from personalization and specification — including adjustments and settings — you enable, engage in, or engender during your access and other use of accounts, profiles, and equivalent.
11.22.1.4. Account-Derivate, Tracking
account-derivative trackers or tracking data and information (“acc-TRACs”) that are derived from monitoring and tracking — including beacons, cookies, tracers — you enable, engage in, or engender during your access and other use of accounts, profiles, and equivalent.
11.22.2. Application-Derivate —
that personal data and information, their processing, and the administration of both may involve sources of data and information categorized as app- or application-derivative.
11.22.2.1. Application-Derivate, Authenticating
application-derivative authenticators or authenticating data and information (“app-AUTHs”) that are derived from authentication you enable, engage in, or engender during your access, installation, and other use of applications, browsers, and equivalent.
11.22.2.2. Application-Derivate, Identifying
application-derivative identifiers or identifying data and information (“app-IDs”) that are derived from identification you enable, engage in, or engender during your access, installation, and other use of applications, browsers, and equivalent.
11.22.2.3. Application-Derivate, Specifying
application-derivative specifiers or specifying data and information (“app-SPECs”) that are derived from personalization and specification — including adjustments and settings — you enable, engage in, or engender during your access and other use of applications, browsers, and equivalent.
11.22.2.4. Application-Derivate, Tracking
application-derivative trackers or tracking data and information (“app-TRACs”) that are derived from monitoring and tracking — including beacons, cookies, tracers — you enable, engage in, or engender during your access and other use of applications, browsers, and equivalent.
11.22.3. Body-Derivate —
that personal data and information, their processing, and the administration of both may involve sources of data and information categorized as body-derivative.
11.22.3.1. Body-Derivate, Authenticating
body-derivative authenticators or authenticating data and information (“body-AUTHs”) that are derived from authentication you enable, engage in, or engender during access to or provision from your physical or physiological body.
11.22.3.2. Body-Derivate, Identifying
body-derivative identifiers or identifying data and information (“body-IDs”) that are derived from identification you enable, engage in, or engender during access to or provision from your physical or physiological body.
11.22.3.3. Body-Derivate, Specifying
body-derivative specifiers or specifying data and information (“body-SPECs”) that are derived from personalization and specification — including adjustments and settings — you enable, engage in, or engender during access to or provision from your physical or physiological body.
11.22.3.4. Body-Derivate, Tracking
body-derivative trackers or tracking data and information (“body-TRACs”) that are derived from monitoring and tracking — including beacons, cookies, tracers — you enable, engage in, or engender during access to or provision from your physical or physiological body.
11.22.4. Device-Derivate —
that personal data and information, their processing, and the administration of both may involve sources of data and information categorized as dev- or device-derivative.
11.22.4.1. Device-Derivate, Authenticating
device-derivative authenticators or authenticating data and information (“dev-AUTHs”) that are derived from authentication you enable, engage in, or engender during your access, acquisition, and other use of computers, devices, equipment, and equivalent smart technologies.
11.22.4.2. Device-Derivate, Identifying
device-derivative identifiers or identifying data and information (“dev-IDs”) that are derived from identification you enable, engage in, or engender during your access, acquisition, and other use of computers, devices, equipment, and equivalent smart technologies.
11.22.4.3. Device-Derivate, Specifying
device-derivative specifiers or specifying data and information (“dev-SPECs”) that are derived from personalization and specification — including adjustments and settings — you enable, engage in, or engender during your access and other use of computers, devices, equipment, and equivalent smart technologies.
11.22.4.4. Device-Derivate, Tracking
device-derivative trackers or tracking data and information (“dev-TRACs”) that are derived from monitoring and tracking — including beacons, cookies, tracers — you enable, engage in, or engender during your access and other use of computers, devices, equipment, and equivalent smart technologies.
11.22.5. Government-Derivate —
that personal data and information, their processing, and the administration of both may involve sources of data and information categorized as gov- or government-derivative.
11.22.5.1. Government-Derivate, Authenticating
government-derivative authenticators or authenticating data and information (“gov-AUTHs”) that are derived from authentication you enable, engage in, or engender during your access, recognition by, and other use and visiting of government and state offices, services, and equivalent.
11.22.5.2. Government-Derivate, Identifying
government-derivative identifiers or identifying data and information (“gov-IDs”) that are derived from identification you enable, engage in, or engender during your access, recognition by, and other use and visiting of government and state offices, services, and equivalent.
11.22.5.3. Government-Derivate, Specifying
government-derivative specifiers or specifying data and information (“gov-SPECs”) that are derived from personalization and specification — including adjustments and settings — you enable, engage in, or engender during your access and other use of government and state activities, areas, entities, offices, services, and equivalent.
11.22.5.3. Government-Derivate, Tracking
government-derivative trackers or tracking data and information (“gov-TRACs”) that are derived from monitoring and tracking — including beacons, cookies, tracers — you enable, engage in, or engender during your access and other use of government and state activities, areas, entities, offices, services, and equivalent.
11.22.6. Location-Derivate —
that personal data and information, their processing, and the administration of both may involve sources of data and information categorized as geo- or location-derivative.
11.22.6.1. Location-Derivate, Authenticating
location-derivative authenticators or authenticating data and information (“geo-AUTHs” or “loc-AUTHs”) that are derived from authentication you enable, engage in, or engender during your location, position, motion, movement, and equivalent activity.
11.22.6.2. Location-Derivate, Identifying
location-derivative identifiers or identifying data and information (“geo-IDs” or “loc-IDs”) that are derived from identification you enable, engage in, or engender during your location, position, motion, movement, and equivalent activity.
11.22.6.3. Location-Derivate, Specifying
location-derivative specifiers or specifying data and information (“geo-SPECs” or “loc-SPECs”) that are derived from personalization and specification — including adjustments and settings — you enable, engage in, or engender during your location, position, motion, movement, and equivalent activity.
11.22.6.4. Location-Derivate, Tracking
location-derivative trackers or tracking data and information (“geo-TRACs” or “loc-TRACs”) that are derived from monitoring and tracking — including beacons, cookies, tracers — you enable, engage in, or engender during your location, position, motion, movement, and equivalent activity.
11.22.7. Log-Derivate —
that personal data and information, their processing, and the administration of both may involve sources of data and information categorized as log-derivative.
11.22.7.1. Log-Derivate, Authenticating
log-derivative authenticators or authenticating data and information (“log-AUTHs”) that are derived from authentication you enable, engage in, or engender during activity that generates or produces log files, server logs, temp records, and equivalent.
11.22.7.2. Log-Derivate, Identifying
log-derivative identifiers or identifying data and information (“log-IDs”) that are derived from identification you enable, engage in, or engender during activity that generates or produces log files, server logs, temp records, and equivalent.
11.22.7.3. Log-Derivate, Specifying
log-derivative specifiers or specifying data and information (“log-SPECs”) that are derived from personalization and specification — including adjustments and settings — you enable, engage in, or engender during activity that generates, uses, or otherwise processes log files, server logs, temp records, and equivalent.
11.22.7.4. Log-Derivate, Tracking
log-derivative trackers or tracking data and information (“log-TRACs”) that are derived from monitoring and tracking — including beacons, cookies, tracers — you enable, engage in, or engender during activity that generates, uses, or otherwise processes log files, server logs, temp records, and equivalent.
11.22.8. Party-Derivate —
that personal data and information, their processing, and the administration of both may involve sources of data and information categorized as party-derivative.
11.22.8.1. Party-Derivate, Authenticating
party-derivative authenticators or authenticating data and information (“party-AUTHs”) that are derived from authentication you enable, engage in, or engender during activity via third-party partners, processors, providers, purchases, servicers, vendors, and equivalent.
11.22.8.2. Party-Derivate, Identifying
party-derivative identifiers or identifying data and information (“party-IDs”) that are derived from identification you enable, engage in, or engender during activity via third-party partners, processors, providers, purchases, servicers, vendors, and equivalent.
11.22.8.3. Party-Derivate, Specifying
party-derivative specifiers or specifying data and information (“party-SPECs”) that are derived from personalization and specification — including adjustments and settings — you enable, engage in, or engender during activity via third-party partners, processors, providers, purchases, servicers, vendors, and equivalent.
11.22.8.4. Party-Derivate, Tracking
party-derivative trackers or tracking data and information (“party-TRACs”) that are derived from monitoring and tracking — including beacons, cookies, tracers — you enable, engage in, or engender during activity via third-party partners, processors, providers, purchases, servicers, vendors, and equivalent.
11.22.9. Product-Derivate —
that personal data and information, their processing, and the administration of both may involve sources of data and information categorized as product-derivative.
11.22.9.1. Product-Derivate, Authenticating
product-derivative authenticators or authenticating data and information (“product-AUTHs”) that are derived from authentication you enable, engage in, or engender during your access and other use of products and equivalent.
11.22.9.2. Product-Derivate, Identifying
product-derivative identifiers or identifying data and information (“product-IDs”) that are derived from identification you enable, engage in, or engender during your access and other use of products and equivalent.
11.22.9.3. Product-Derivate, Specifying
product-derivative specifiers or specifying data and information (“product-SPECs”) that are derived from personalization and specification — including adjustments and settings — you enable, engage in, or engender during your access and other use of products and equivalent.
11.22.9.4. Product-Derivate, Tracking
product-derivative trackers or tracking data and information (“product-TRACs”) that are derived from monitoring and tracking — including beacons, cookies, tracers — including adjustments and settings — you enable, engage in, or engender during your access and other use of products and equivalent.
11.22.10. Public-Derivate —
that personal data and information, their processing, and the administration of both may involve sources of data and information categorized as public-derivative or publicly available.
11.22.10.1. Public, Authenticating
public-derivative authenticators or authenticating data and information (“pub-AUTHs” or “public-AUTHs”) that are derived from authentication you enable, engage in, or engender during your access and other use of publicly accessible and available activities, areas, entities, services, sources, and equivalent.
11.22.10.2. Public, Identifying
public-derivative identifiers or identifying data and information (“pub-IDs” or “public-IDs”) that are derived from identification you enable, engage in, or engender during your access and other use of publicly accessible and available activities, areas, entities, services, sources, and equivalent.
11.22.10.3. Public, Specifying
public-derivative specifiers or specifying data and information (“pub-SPECs” or “public-SPECs”) that are derived from personalization and specification — including adjustments and settings — you enable, engage in, or engender during your access and other use of publicly accessible and available activities, areas, entities, services, sources, and equivalent.
11.22.10.4. Public, Tracking
public-derivative trackers or tracking data and information (“pub-TRACs”) that are derived from monitoring and tracking — including beacons, cookies, tracers — including adjustments and settings — you enable, engage in, or engender during your access and other use of publicly accessible and available activities, areas, entities, services, sources, and equivalent.
11.22.11. Service-Derivate —
that personal data and information, their processing, and the administration of both may involve sources of data and information categorized as service-derivative.
11.22.11.1. Service-Derivate, Authenticating
service-derivative authenticators or authenticating data and information (“serv-AUTHs” or “service-AUTHs”) that are derived from authentication you enable, engage in, or engender during your access and other use of services, sites, and equivalent.
11.22.11.2. Service-Derivate, Identifying
service-derivative identifiers or identifying data and information (“serv-IDs” or “service-IDs”) that are derived from identification you enable, engage in, or engender during your access and other use of services, sites, and equivalent.
11.22.11.3. Service-Derivate, Specifying
service-derivative specifiers or specifying data and information (“serv-SPECs” or “service-SPECs”) that are derived from personalization and specification — including adjustments and settings — you enable, engage in, or engender during your access and other use of services, sites, and equivalent.
11.22.11.4. Service-Derivate, Tracking
service-derivative trackers or tracking data and information (“pub-TRACs”) that are derived from monitoring and tracking — including beacons, cookies, tracers — you enable, engage in, or engender during your access and other use of services, sites, and equivalent.
11.22.12. Storage-Derivate —
that personal data and information, their processing, and the administration of both may involve sources of data and information categorized as service-derivative.
11.22.12.1. Storage, Authenticating
storage-derivative authenticators or authenticating data and information (“storage-AUTHs”) that are derived from authentication you enable, engage in, or engender during your access, creation, and other use of caches, datasets, servers, and equivalent storage.
11.22.12.2. Storage, Identifying
storage-derivative identifiers or identifying data and information (“storage-IDs”) that are derived from identification you enable, engage in, or engender during your access, creation, and other use of caches, datasets, servers, and equivalent storage.
11.22.12.3. Storage, Specifying
storage-derivative specifiers or specifying data and information (“storage-SPECs”) that are derived from personalization and specification — including adjustments and settings — you enable, engage in, or engender during your access, creation, and other use of caches, datasets, servers, and equivalent storage.
11.22.12.4. Storage, Tracking
storage-derivative trackers or tracking data and information (“storage-TRACs”) that are derived from monitoring and tracking — including beacons, cookies, tracers — you enable, engage in, or engender during your access, creation, and other use of caches, datasets, servers, and equivalent storage.
—— of Categories of Persons
Section 11.23.0. With respect to adequate categorization and classification of persons concerned regarding data and information, their processing, and the administration of both, you understand and agree to abide by the following:
11.23.1. Account-Attributable
that personal data and information, their processing, and the administration of both may involve persons concerned categorized as account-attributable, that is, those attributable to or identifiable as actual, former or potential holders of accounts, profiles, and equivalent.
11.23.2. Application-Attributable
that personal data and information, their processing, and the administration of both may involve persons concerned categorized as application-attributable, that is, those attributable to or identifiable as actual, former or potential customers or users of applications, browsers, and equivalent.
11.23.3. Device-Attributable
that personal data and information, their processing, and the administration of both may involve persons concerned categorized as device-attributable, that is, those attributable to or identifiable as actual, former or potential customers or users of computers, devices, equipment, and equivalent smart technologies.
11.23.4. Organization-Attributable
that personal data and information, their processing, and the administration of both may involve persons concerned categorized as organization-attributable, that is, those attributable to or identifiable as actual, former or potential official persons of Publiks, including their beneficiaries and emergency contacts.
11.23.5. Party-Attributable
that personal data and information, their processing, and the administration of both may involve persons concerned categorized as party-attributable, that is, those attributable to or identifiable as actual, former or potential third parties of Publiks, including third-county and third-party partners, processors, providers, purchases, servicers, vendors, and equivalent.
11.23.6. Product-Attributable
that personal data and information, their processing, and the administration of both may involve persons concerned categorized as product-attributable, that is, those attributable to or identifiable as actual, former or potential customers or users of goods, products, and equivalent.
11.23.7. Service-Attributable
that personal data and information, their processing, and the administration of both may involve persons concerned categorized as service-attributable, that is, those attributable to or identifiable as actual, former or potential customers or users of services, sites, and equivalent.
11.23.8. Sector-Attributable
that personal data and information, their processing, and the administration of both may involve persons concerned categorized as sector-attributable, that is, those attributable to or identifiable as actual, former or potential members, officials, representatives, workers, or other agents of a field, guild, profession, specialty, or other sector of industry or work, including any relevant certifying, professional, or licensing body, entity, or office.
11.23.9. Socio-Attributable
that personal data and information, their processing, and the administration of both may involve persons concerned categorized as socio-attributable, that is, those attributable to or identifiable as cohorts, communities, groups, members, representatives, samples, and equivalent of the general public, population, or society.
11.23.10. State-Attributable
that personal data and information, their processing, and the administration of both may involve persons concerned categorized as state-attributable, that is, those attributable to or identifiable as actual, former or potential members, officials, representatives, or other agents of governmental, judicial, public, regulatory, territorial and equivalent bodies, entities, offices, or equivalent, and their jurisdictional states.
—— of Categories of Purposes
Section 11.24.0. With respect to adequate categorization and classification of purposes for data and information, their processing, and the administration of both, you understand and agree to abide by the following:
11.24.1. Account-Focused
that personal data and information, their processing, and the administration of both may be for purposes categorized as account-focused, that is, for the purposes of administering, enhancing, as well as offering an account, profile, and equivalent.
11.24.2. Advertising-Focused
that personal data and information, their processing, and the administration of both may be for purposes categorized as ad- or advertising-focused, that is, for the purposes of advertising, marketing, and public relations.
11.24.3. Communication-Focused
that personal data and information, their processing, and the administration of both may be for purposes categorized as communication-focused, that is, for the purposes of communication and notification to persons relating to Publiks.
11.24.4. Compliance-Focused
that personal data and information, their processing, and the administration of both may be for purposes categorized as compliance-focused, that is, for the purposes of fulfilling and responding to compliance requests and requirements, as provided for in the Data and information Policy, the Codes and Policies, and applicable law and regulation.
11.24.5. Development-Focused
that personal data and information, their processing, and the administration of both may be for purposes categorized as development-focused, that is, for the purposes of for the purposes of research, design, and development.
11.24.6. Feedback-Focused
that personal data and information, their processing, and the administration of both may be for purposes categorized as feedback-focused, that is, for the purposes of participation in feedback, focus groups, opinion polls, surveys, and equivalent means of ascertaining awareness, knowledge, and perspectives of persons.
11.24.7. Organization-Focused
that personal data and information, their processing, and the administration of both may be for purposes categorized as organization-focused, that is, for the purposes of administration and fulfillment of the duties, functions, interests, and responsibilities of Publiks.
11.24.8. Product-Focused
that personal data and information, their processing, and the administration of both may be for purposes categorized as product-focused, that is, for the purposes of administering, enhancing, as well as offering the Products to actual, former and potential customers, users, and visitors.
11.24.9. Research-Focused
that personal data and information, their processing, and the administration of both may be for purposes categorized as research-focused, that is, for the purposes of administering, enhancing, as well as offering research about or to actual, former and potential customers, users, and visitors.
11.24.10. Service-Focused
that personal data and information, their processing, and the administration of both may be for purposes categorized as service-focused, that is, for the purposes of administering, enhancing, as well as offering the Services to actual, former and potential customers, users, and visitors.
11.24.11. Support-Focused
that personal data and information, their processing, and the administration of both may be for purposes categorized as support-focused, that is, for the purposes of assistance, maintenance, troubleshooting, updating, and other support for persons relating to the Products and Services and to Publiks.
—— of Categories of Recipients
Section 11.25.0. With respect to adequate categorization and classification of recipients for data and information, their processing, and the administration of both, you understand and agree to abide by the following:
11.25.1. Ikoku Charitable Trusts-Receiving
that personal data and information, their processing, and the administration of both may involve recipients categorized as Ikoku Charitable Trusts-receiving, that is, authorized and recognized as official persons and recipients of The Chinyere and Chinelo Ikoku Charitable Trusts.
11.25.2. Ikoku Foundation-Receiving, C&C
that personal data and information, their processing, and the administration of both may involve recipients categorized as C&C Ikoku Foundation-receiving, that is, authorized and recognized as official persons and recipients of The Chinyere and Chinelo Ikoku Foundation.
11.25.3. Ikoku Foundation-Receiving, Alvan
that personal data and information, their processing, and the administration of both may involve recipients categorized as Alvan Ikoku Foundation-receiving, that is, authorized and recognized as official persons and recipients of The Alvan Azinna Chibuzo Ikoku Foundation.
11.25.4. Ikoku Center-Receiving
that personal data and information, their processing, and the administration of both may involve recipients categorized as Ikoku Center-receiving, that is, authorized and recognized as official persons and recipients of The Alvan Ikoku Center for Ethics.
11.25.5. Ikoku Institute-Receiving
that personal data and information, their processing, and the administration of both may involve recipients categorized as Ikoku Institute-receiving, that is, authorized and recognized as official persons and recipients of The Alvan Ikoku Institute for International Affairs.
11.25.6. Ikoku Philanthropies-Receiving
that personal data and information, their processing, and the administration of both may involve recipients categorized as Ikoku Philanthropies-receiving, that is, authorized and recognized as official persons and recipients of The Alvan Ikoku Philanthropies.
11.25.7. Ikoku University-Receiving
that personal data and information, their processing, and the administration of both may involve recipients categorized as Ikoku University-receiving, that is, authorized and recognized as official persons and recipients of Alvan Ikoku University.
11.25.8. Humana Sancta-Receiving
that personal data and information, their processing, and the administration of both may involve recipients categorized as Humana Sancta-receiving, that is, authorized and recognized as official persons and recipients of Humana Sancta.
11.25.9. Founder-Administering
with all of the aforementioned categories of recipients authorized and administered solely by the Founder, Alvan Azinna Chibuzo Ikoku, as executed solely via the Founder’s authorization.
— of Communication
Section 11.26.0. With respect to determining and ensuring adequate communication and notification pertaining to personal data and information, their processing, and the administration of both, you understand and agree to abide by the following criteria:
11.26.1. Communication, Basis
that personal data and information, their processing, and the administration of both are accompanied by communication and notification that provides to you — as the person concerned — all the key information, in sufficient detail, that a reasonable person would need in order to make an informed decision about whether to permit, rectify, or terminate the personal data and information, their processing, or the administration of either; and so the informing process does not merely provide lists of isolated facts, but is instead organized in a manner most likely to assist you in understanding the reasons why you may or may not decide to permit, rectify, or terminate such data and information, processing, or administration.
11.26.2.1. Communication, Actual, Future, Prior
that such communication or notification explicitly states and explains to you — as the person concerned — whether data and information attributable to, identifying or otherwise relating to you has been, is being or will be accessed or otherwise processed.
11.26.2.2. Communication, Aim, Purpose
that such communication or notification explicitly states and explains to you — as the person concerned — the explicit, legitimate and specific aim or purpose for such personal data and information, processing, and administration.
11.26.2.3. Communication, Benefit
that such communication or notification explicitly states and explains to you — as the person concerned — the ethical, lawful and specific benefit to you of such personal data and information, processing, and administration.
11.26.2.4. Communication, Cost
that such communication or notification explicitly states and explains to you — as the person concerned — the ethical, lawful and specific cost to you of such personal data and information, processing, and administration.
11.26.2.5. Communication, Duration
that such communication or notification explicitly states and explains to you — as the person concerned — the ethical, lawful and specific duration or period of time for such personal data and information, processing, and administration.
11.26.2.6. Communication, Extent, Scope
that such communication or notification explicitly states and explains to you — as the person concerned — the ethical, lawful and specific extent or scope of such personal data and information, processing, and administration.
11.26.2.7. Communication, Manner
that such communication or notification explicitly states and explains to you — as the person concerned — the ethical, lawful and specific manner, means, measures, mechanisms, methods, or modes for such personal data and information, processing, and administration.
11.26.2.7.1. Communication, Manner, Automation
that such communication or notification explicitly states and explains to you — as the person concerned — whether such personal data and information, processing, and administration entail automation and automated methods, including but not limited to an algorithm or equivalent logic, automated individual decision-making, and profiling.
11.26.2.7.2. Communication, Manner, Automation, Absence, Child
that, if so, such communication or notification explicitly confirms and explains to you — as the person concerned — the absence and non-involvement of a child (including, where applicable, yourself) attributable to, identifiable by, or otherwise related to such personal data and information, processing, and administration; and where a child is involved, further confirmation that such data and information, processing, and administration are strictly prohibited, and where applicable, immediately ceased and remedied.
11.26.2.7.3. Communication, Manner, Automation, Absence, Public Areas
that, if so, such communication or notification explicitly states and explains to you — as the person concerned — the absence and non-involvement of publicly accessible areas; and where publicly accessible areas are involved, further confirmation that such data and information, processing, and administration are strictly prohibited, and where applicable, immediately ceased and remedied, unless as provided for under the Principle of Protection.
11.26.2.7.4. Communication, Manner, Automation, Absence, Sensitivity
that, if so, such communication or notification explicitly confirms and explains to you — as the person concerned — the absence and non-involvement of sensitive data and information; and where sensitive data and information are involved, further confirmation that such data and information, processing, and administration are strictly prohibited, and where applicable, immediately ceased and remedied, unless as provided for under the Principles of Protection and Sensitivity.
11.26.2.7.5. Communication, Manner, Automation, Decisions
that, if so, such communication or notification explicitly confirms and explains to you — as the person concerned — the nature of decisions made or reached via the proposed or reported automation or automated methods; and where such automated decision-making is involved, further confirmation of the means for you to challenge any such decisions and, where feasible and reasonable, to request human input or intervention.
11.26.2.7.6. Communication, Manner, Automation, Methods
that, if so, such communication or notification explicitly states and explains to you — as the person concerned — specific details as to the means of proposed or reported processing via automation or automated methods, including meaningful information about the logic, decision-making, profiling, or other methods involved, as well as the actual and envisaged consequences and significant effects for you of employing the specified methods; and if the methods involved are new, further confirmation that such data and information, processing, and administration are prohibited, and where applicable, immediately ceased and remedied, unless as provided for under the Principle of Protection.
11.26.2.7.7. Communication, Manner, Automation, Risks
that, if so, such communication or notification explicitly states and explains to you — as the person concerned — the level and nature of risk to you of using the automation and automated methods; and if high risk, further confirmation that such data and information, processing, and administration are prohibited, and where applicable, immediately ceased and remedied, unless as provided for under the Principle of Protection.
11.26.2.7.8. Communication, Manner, Automation, Scale
that, if so, such communication or notification explicitly states and explains to you — as the person concerned — the scale and size of such data and information, processing, and administration; and if large-scale, further confirmation that such data and information, processing, and administration are prohibited, and where applicable, immediately ceased and remedied, unless as provided for under the Principle of Protection.
11.26.2.7.9. Communication, Manner, Automation, Significance
that, if so, such communication or notification explicitly states and explains to you — as the person concerned — the legal or similarly significant effects of using the automation and automated methods; and if there are such effects, further confirmation that such data and information, processing, and administration are prohibited, unless as provided for under the Principle of Protection.
11.26.2.8. Communication, Material
that such communication or notification explicitly states and explains to you — as the person concerned — the ethical, lawful and specific materials and categories, natures, and types of materials in such personal data and information, processing, and administration.
11.26.2.9. Communication, Matter
that such communication or notification explicitly states and explains to you — as the person concerned — the ethical, lawful and specific matters and categories, natures, and types of matters in such personal data and information, processing, and administration.
11.26.2.10. Communication, Minimization, Necessity
that such communication or notification explicitly states and explains to you — as the person concerned — the ethical, lawful and specific measures for ensuring that such personal data and information, processing, and administration adhere to and fulfill the principles of minimization, necessity, and non-identification, as provided for in the Data and Information Policy and the Codes and Policies.
11.26.2.11. Communication, Non-Identification
that such communication or notification explicitly states and explains to you — as the person concerned — whether and how identifiers will be removed from such personal data and information, processing, and administration; whether or how other processes of non-identification are to be employed, including periodic re-identification, and if so under what circumstances and to what extent; and, whether or not such processes of non-identification are conducted, clearly confirm to you that the still personal data and information will not be involved in any future or other administration or processing, unless with additional informed consent from you.
11.26.2.12. Communication, Non-Personalization
that such communication or notification clearly provides you — as the person concerned — reasonable opportunity to consent to have such personal data and information become and remain non-personal via a combination of irreversible anonymization and further transformation (such as data aggregation), after which such data and information can be used for future or other administration or processing without additional informed consent from you.
11.26.2.13. Communication, Persons
that such communication or notification explicitly states and explains to you — as the person concerned — the ethical, lawful and specific persons and categories of persons involved in such personal data and information, processing, and administration, including any assignments, delegations, or transfers to any recipient, third party, third country or international organization.
11.26.2.14. Communication, Rights
that such communication or notification explicitly states and explains to you — as the person concerned — your rights with respect to such personal data and information, processing, and administration; the means and procedures for exercising your rights in relation to such data and information, processing, administration; and that such data and information, processing, administration do not infringe the locally accorded civil liberties or rights of you or of other persons concerned, including Publiks and the Founder, Alvan Azinna Chibuzo Ikoku.
11.26.2.15. Communication, Risks
that such communication or notification explicitly states and explains to you — as the person concerned — the ethical, lawful and specific risks to you of such personal data and information, processing, and administration.
11.26.2.16. Communication, Safeguards
that such communication or notification explicitly states and explains to you — as the person concerned — policies, principles, and standards for such personal data and information, processing, and administration; the protections and safeguards in relation to such data and information, processing, and administration; and where applicable, further communication or notification reasonably informing you of any confirmed infringement of such protections and safeguards.
11.26.2.17. Communication, Sensitivity
that such communication or notification explicitly states and explains to you — as the person concerned — whether sensitive data and information attributable to, identifying or otherwise relating to you (especially biospecimens) has been, is being, or will be accessed or otherwise processed about or from you; and if so, that such communication also confirms and explains the consent process, protections, and safeguards provided to you specifically for such sensitivity.
11.26.2.18. Communication, Status
that such communication or notification explicitly states and explains to you — as the person concerned — the ethical, lawful and specific procedures of keeping you informed of the status of such personal data and information, processing, and administration, including requests by you for such information, provided that your requests and the responses of Publiks are both feasible and reasonable with respect to cost, frequency, number, proportionate effort, technical limits, and risks to other persons concerned, especially Publiks and the Founder.
11.26.2.19. Communication, Voluntary
that such communication or notification explicitly states and explains to you — as the person concerned — that permission for such personal data and information, processing, and administration is voluntary; that refusal to provide involves no penalty or punishment or loss of benefits to which you are otherwise entitled; and that you are able to discontinue to provide at any time without penalty, punishment, or loss of benefits to which you are otherwise entitled.
11.26.2.20. Communication, Where Compulsory
nevertheless, that such communication or notification explicitly states and explains to you — as the person concerned — whether such personal data and information, processing, and administration is a compulsory, contractual, obligatory or statutory requirement, and the possible consequences of failure to conduct such personal data and information, processing, and administration.
11.26.2.21. Communication, Who Responsible
that such communication or notification explicitly states and explains to you — as the person concerned — the identity and contact information of the entity, office, or person responsible for such personal data and information, processing, and administration, including whom you are to contact for pertinent questions or requests.
11.26.3. Communication, With Opportunities
that such communication or notification explicitly states and provides to you — as the person concerned — sufficient opportunity and period of time to ask questions and discuss concerns, prior to, during and after conduct of such personal data and information, processing, and administration, including the availability to you, upon your request, twice (2) every twelve (12) months, of such reasonably informing communication covering the twelve (12) preceding months.
11.26.3.1. Communication, With Opportunities, Confirmation
that such communication or notification explicitly states and provides to you — as the person concerned — the aforementioned sufficient opportunity to make feasible and reasonable requests to confirm that such personal data and information, processing, and administration do not infringe any provisions of the Data and Information Policy, the Codes and Polices, or applicable law or regulation.
11.26.3.2. Communication, With Opportunities, Copy
that such communication or notification explicitly states and provides to you — as the person concerned — the aforementioned sufficient opportunity to make feasible and reasonable requests for a copy of personal data and information that are appropriately and legally available to you, in a structured, commonly used and machine-readable format, with subsequent actions and decisions clearly confirmed and explained, without unreasonable delay.
11.26.3.3. Communication, With Opportunities, Disagreement
that such communication or notification explicitly states and provides to you — as the person concerned — the aforementioned sufficient opportunity to make feasible and reasonable requests to disagree with, dispute, or object to a particular personal data or information, their processing, or the administration of either, with subsequent actions and decisions clearly confirmed and explained, without unreasonable delay.
11.26.3.4. Communication, With Opportunities, Erasure
that such communication or notification explicitly states and provides to you — as the person concerned — the aforementioned sufficient opportunity to make feasible and reasonable requests to have a particular personal data or information, their processing, or the administration of either deleted or erased, with subsequent actions and decisions clearly confirmed and explained, without unreasonable delay.
11.26.3.5. Communication, With Opportunities, Rectification
that such communication or notification explicitly states and provides to you — as the person concerned — the aforementioned sufficient opportunity to make feasible and reasonable requests to have any discovered inaccuracies, inadequacies, incompleteness, infringements, insufficiencies, or equivalent in a particular personal data or information, their processing, or the administration of either rectified, with subsequent actions and decisions clearly confirmed and explained, without unreasonable delay.
11.26.3.6. Communication, With Opportunities, Restriction
that such communication or notification explicitly states and provides to you — as the person concerned — the aforementioned sufficient opportunity to make feasible and reasonable requests to have a particular personal data or information, their processing, or the administration of either limited or restricted, either permanently or temporarily, with subsequent actions and decisions clearly confirmed and explained, without unreasonable delay.
11.26.3.7. Communication, With Opportunities, Termination
that such communication or notification explicitly states and provides to you — as the person concerned — the aforementioned sufficient opportunity to make feasible and reasonable requests to have a particular personal data or information, their processing, or the administration of either stopped or terminated, with subsequent actions and decisions clearly confirmed and explained, without unreasonable delay.
11.26.3.8. Communication, With Opportunities, Update
that such communication or notification explicitly states and explains to you — as the person concerned — upon any pertinent decision by Publiks to erase, rectify, restrict, or terminate a particular personal data or information, their processing, or the administration of either, the subsequent feasible and reasonable efforts to send sufficiently informing notification to recipients of such personal data or information, processing, or administration.
— of Confidentiality
Section 11.27.0. With respect to determining and ensuring adequate confidentiality of personal data and information, their processing, and the administration of both, you understand and agree to abide by the following criteria:
11.27.1. Confidentiality, Basis
that personal data and information, their processing, and the administration of both maintain confidentiality with respect to you — as the person concerned — as well as Publiks, and do not infringe any policies, principles, or protections for confidentiality, as provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation.
11.27.2.1. Confidentiality, Data
that, where appropriate or required, the personal data and information are confidential with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.27.2.2. Confidentiality, Data Administration
that, where appropriate or required, the administration of personal data and information, and of their processing, is conducted only in a manner that is confidential with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.27.2.3. Confidentiality, Data Processing
that, where appropriate or required, the processing of personal data and information is conducted only in a manner that is confidential with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.27.2.4. Confidentiality, Data Purpose
that, where appropriate or required, such personal data and information, processing, and administration are conducted only for a purpose that is confidential with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.27.3. Confidentiality, Risks
that such personal data and information, processing, and administration account for and protect against risks to confidentiality with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.27.3.1. Confidentiality, Risks Limitation, Data
that the personal data and information account for and protect against risks to confidentiality with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.27.3.2. Confidentiality, Risks Limitation, Data Administration
that the administration of personal data and information, and of their processing, is conducted only in a manner that accounts for and protects against risks to confidentiality with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.27.3.3. Confidentiality, Risks Limitation, Data Processing
that the processing of personal data and information is conducted only in a manner that accounts for and protects against risks to confidentiality with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.27.3.4. Confidentiality, Risks Limitation, Data Purpose
that such personal data and information, processing, and administration are conducted only for a purpose that accounts for and protects against risks to confidentiality with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.27.4.1. Confidentiality, Strict Default
that such personal data and information, processing, and administration, by default, strictly adhere to and fulfill all policies, principles, and protections for confidentiality with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.27.4.2. Confidentiality, Strict Design
that such personal data and information, processing, and administration, by design, strictly adhere to and fulfill all policies, principles, and protections for confidentiality with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.27.5. Confidentiality, Strict Review
that there is monitoring and periodic strict review to ensure the data and information, their processing, and the administration of both are confidential and maintain confidentiality, and where inadequacies or infringements are found, they are addressed and rectified without undue delay.
11.27.6. Confidentiality, Strict Review Period
that appropriate, minimum and necessary time considerations — such as duration, frequency, and length between instances — are established for such periodic and strict review for confidentiality and then for any appropriate and efficacious decision as to continued (or discontinued) administration, processing, rectification, restriction, storage, or termination.
— of Consent
Section 11.28.0. With respect to determining and ensuring adequate consent for personal data and information, their processing, and the administration of both, you understand and agree to abide by the following five-part evaluation:
11.28.1. Consent, Basis
that personal data and information, their processing, and the administration of both are subject to your consent, which is to be decided, given, informed and maintained to a sufficient degree to serve as the basis of an Agreement between Publiks and you — as the person concerned — for the duration of such data and information, processing, and administration.
11.28.1.1. Consent, Basis, Conduct
that such basis requires your consent for any conduct or service you commence or continue relating to Publiks.
11.28.1.2. Consent, Basis, Data
that such basis recognizes the frequent involvement of data and information attributable to, identifying or otherwise relating to you in such conduct or service — and thus requires your consent for such data and information, processing, and administration.
11.28.1.3. Consent, Basis, Decision-Making
that such basis treats each human being as an individual person with decision-making abilities — even where such abilities are diminished and warrant protection — and thus requires adequate communication and opportunity for your informed consent, or assent, as well as safeguards and, at times, non-approval or prohibition of such data and information, processing, and administration.
11.28.2. Consent, Definition
that consent with respect to personal data and information, their processing, and administration of both is adequate only when it is affirmative, clear, freely given, reasonably informed, meaningful, revocable, unambiguous and written by you — as the person concerned — and furthermore expressly indicated for an explicit, legitimate and specific purpose for such data and information, processing, and administration — as this purpose is delineated and explained in an accessible, clear, easily legible and understandable, informing and written form, page, or request.
11.28.3. Consent, Meaningful
that such consent is freely given and meaningful only when and where the consent process involves your free and genuine decision to consent and your ability to refuse or revoke such consent.
11.28.3.1. Consent, Meaningful, Not
that such consent cannot be presumed to be freely given or meaningful (a) where the asker or requester is in a position to compel consent from you; (b) where the obtaining or maintaining of your consent entails coercion, confusion, deception, force, or trickery; (c) where you are presented with no reasonable option other than to give consent; and (d) where you were made to understand that you needed to consent when you did not or such consent was not necessary.
11.28.3.2. Consent, Meaningful, Not Situations
that such consent cannot, therefore, be presumed to be freely given or meaningful — and it is unlikely to suffice as a legally valid basis — (a) if the asker or requester is a government, public, regulatory or state agent, authority, entity, office, official, person or a judiciary representative with a subpoena or warrant; (b) or if the asker or requester presents such consent as necessary or required where it is not; e.g. for the performance of an activity, agreement, contract, conduct, or service; (c) or if you need a legal fiduciary, guardian, next of kin, parent, proxy, representative, or equivalent to take your wishes into account in providing assent; or (d) if the consent is obtained or presumed in a manner that has been determined to not be legally adequate, binding, meaningful, valid or equivalent by an official court or law of California, Delaware, a European Union member state, the United Kingdom, or the United States.
11.28.3.3. Consent, Meaningful, Opportunity
that the consent and informing process, including the form, page, part, or request for consent, clearly discloses and explains to you — as the person concerned — both where consent cannot be freely given or meaningful and the reasons for such a determination, then also provides a good faith opportunity for you to (a) confirm your own understanding of the nature of the consent and the determination; (b) decide whether to proceed with the informing consent process and, perhaps eventually, the data and information, processing, and administration in question; (c) decide not to proceed at all; or (d) opt for any alternative data and information, processing, or administration that may fulfill the same or equivalent purpose and where consent can be freely given and meaningful.
11.28.3.4. Consent, Meaningful, Options
that the consent and informing process, including the form, page, part, or request for consent, clearly indicates, where appropriate, options where you — as the person concerned — could freely and meaningfully give full, partial or no consent to a different purpose or process, and also explains the effect of such consent on your participation in or other use or visit of an authorized activity, agreement, contract, conduct, product, service, or equivalent of Publiks.
11.28.3.5. Consent, Meaningful, Revocation
that the consent and informing process, including the form, page, part, or request for consent, clearly informs you — as the person concerned — of your right to revoke or withdraw consent at any time; the easily accessible, comprehensible and implementable procedure for revoking or withdrawing consent; and the effect of revoking or withdrawing consent on the lawfulness of such data and information, processing, and administration during the period in which your consent was given.
11.28.4. Consent, Informed
that such consent is informed only if the form, page, part, or request for consent provides to you — as the person concerned — all the key information, in sufficient detail, that a reasonable person would need in order to make an informed decision about whether to permit such data and information, processing, and administration; and so only if the informing process does not merely provide lists of isolated facts, but is instead organized in a manner most likely to assist you in understanding the reasons why you may or may not decide to permit such data and information, processing, and administration, fulfilling each requirement delineated under the Principle of Communication.
11.28.5. Consent, Process
that such consent is asked for, informed and otherwise processed via a process that meets the additional requirements below.
11.28.5.1. Consent, Process, Authorized Parties
that the consent and informing process is between an accurately, appropriately, clearly, correctly and securely authorized and identified official person or part of Publiks and an accurately, appropriately, clearly, correctly and securely identified person concerned who is attributable to, identifiable by, a subject of, or otherwise specifically related to the data and information, processing, and administration.
11.28.5.2. Consent, Process, Accessible, Understandable
that the consent and informing process, including the form, page, part, or request for consent, is easily accessible and easy to understand for you — as the person concerned — is in writing, including where appropriate in electronic form, and is in clear, plain and written language, with, where appropriate, additional, assistive and clear visualization or vocalization.
11.28.5.3. Consent, Process, Affirmative, Clear, Unambiguous
that the consent and informing process, including the form, page, part, or request for consent, offers a means by which you — as the person concerned — can provide an affirmative, clear and unambiguous indication of your consent decisions pertaining to the data and information, processing, and administration — for example, clicking a button, signing on a line, ticking a box, updating privacy or technical settings for a product or service — with the clear understanding that inactivity, inference, pre-selected or -ticked boxes, presumption, silence, sound, or other ambiguous, unclear or unintended communication or language does not constitute consent.
11.28.5.4. Consent, Process, Attestation, Identity
that the consent and informing process, including the form, page, part, or request for consent, offers a means by which you — as the person concerned — can accurately, clearly and unambiguously attest to and confirm your identity and ability and authorization to give, review, or revoke consent.
11.28.5.5. Consent, Process, Attestation, Informed
that the consent and informing process, including the form, page, part, or request for consent, offers a means by which you — as the person concerned — can accurately, clearly and unambiguously attest to and confirm your being reasonably informed of the consent process and the terms of giving, reviewing, and revoking consent.
11.28.5.6. Consent, Process, Attestation, Meaningful
that the consent and informing process, including the form, page, part, or request for consent, offers a means by which you — as the person concerned — can accurately, clearly and unambiguously attest to and confirm the fact that any consent you provide is freely given, meaningful and revocable.
11.28.5.7. Consent, Process, Attestation, Understanding
that the consent and informing process, including the form, page, part, or request for consent, offers a means by which you — as the person concerned — can accurately, clearly and unambiguously attest to and confirm your understanding of the consent process and the terms of giving, reviewing, and revoking consent.
11.28.5.8. Consent, Process, Documentable
that the consent and informing process, including the form, page, part, or request for consent, is documentable or preservable as part of the records of Publiks, to be later reproducible in legible, physical and written form wherever there is need to demonstrate the actions and decisions of the consent process.
11.28.5.9. Consent, Process, Protective
that the consent and informing process, including the form, page, part, or request for consent, does not infringe any policies, principles, or protections provided for in the Data and Information Policy, the Codes and Policies, or applicable law or regulation.
11.28.5.10. Consent, Process, Written
that the consent and informing process, including the form, page, part, or request for consent, is in writing, via written communication and instrument, and not acceptable as consent — or informing — if indicated, provided, received or otherwise processed orally, vocally or via any form other than written.
—— of Consent via Assent
Section 11.29.0. With respect to determining and ensuring adequate assent for personal data and information, their processing, and the administration of both, you understand and agree to abide by the following:
11.29.1. Assent, Basis
that where the consent you indicate cannot be considered freely given and meaningful, or you may not be able to properly give consent at all, the consent process still treats you as a deciding human being and individual as much as possible, and fulfills the ensuing informed assent process.
11.29.2. Assent, Determination
that there is a legally valid determination that you — as the person concerned — do not have sufficient decision-making capacity to consent for the data and information, their processing, and the administration of both; that you are promptly informed of such determination via written communication; and that you are presented with adequate and ample opportunity to appeal such determination, including in a court of applicable law and regulation, prior to such data and information, processing, or administration and any associated conduct or service.
11.29.3. Assent, Informed
that any assent process fulfill all requirements and standards for informed consent via written communication directly to you — as the person concerned — as well as to any other person determined to be included or required in the assent process (e.g. a legal fiduciary, guardian, next of kin, parent, proxy, or representative), as provided for in the Data and Information Policy and the Codes and Policies.
11.29.4.1. Assent, Necessary, Vital Interests
that such assent process is limited to such data and information, processing, and administration determined to be necessary for the purposes of protecting vital interests for you — as the person concerned — that are imminently essential to your life, with the standard being a medically-proven and imminently life-saving measure, procedure, or treatment.
11.29.4.2. Assent, Necessary, Vital Rights
that such assent process is limited to such data and information, processing, and administration determined to be necessary for the purposes of protecting vital rights for you — as the person concerned — that are imminently essential to your life, with the standard being a life-associated right accorded to you by applicable law or regulation.
11.29.5.1. Assent, Protection, High Evidentiary Basis
that there is a rigorous DRB assessment and confirmation that establishes a high evidentiary basis for the rationale for recourse to assent and a high evidentiary basis for each activity, conduct, service, or involved measure or method conducted pursuant to assent, with the standard being that developed for evidence-based medicine.
11.29.5.2. Assent, Protection, Highly Favorable Ratio
that there is a rigorous DRB assessment and confirmation that establishes that the ratio or relation between benefit and risk to you — as the person concerned — of such data and information, processing, and administration is highly favorable and highly protective.
11.29.5.3. Assent, Protection, Strict Risk Elimination
that there is a rigorous DRB assessment and confirmation that such data and information, processing, and administration are conducted in a manner that eliminates any disclosure that would place you — as the person concerned — at risk of adverse effect or impact, including civil or criminal liability or damage to your educational advancement, employability, financial standing, or reputation; with such a strict standard requiring rigorous fulfillment of the policies, principles, and protections of minimization, necessity, non-identification, and sensitivity.
11.29.6. Assent, Sufficiency
that any resulting assent with respect to personal data and information, their processing, and administration of both is adequate and legally sufficient only when it is affirmative, clear, freely given, reasonably informed, meaningful, revocable, unambiguous and written by you — as the person concerned — and by the additional person involved in the assent process, and furthermore expressly indicated for an explicit, legitimate and specific purpose for such data and information, processing, and administration — as this purpose is delineated and explained in an accessible, clear, easily legible and understandable, informing and written form, page, or request.
— of Documentation
Section 11.30.0. With respect to determining and ensuring adequate documentation pertaining to personal data and information, their processing, and the administration of both, you understand and agree to abide by the following:
11.30.1. Documentation, Basis
that books, documents, files, records, and equivalent pertaining to personal data and information, their processing, and the administration of both are created, maintained, safeguarded, and, where applicable, transmitted in a manner that ensures compliance with and fulfillment of policies, principles, and protections provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation.
11.30.2. Documentation, Approval
that such adequate books, documents, files, and records are created, maintained and safeguarded in fulfillment and service of DRB approval and authorization processes, including before, during and, where appropriate, subsequent to such processes.
11.30.3. Documentation, Assignment
that such adequate books, documents, files, and records are created, maintained and safeguarded in fulfillment and service of assignment, delegation and transfer processes, including before, during and, where appropriate, subsequent to such processes.
11.30.4. Documentation, Communication
that such adequate books, documents, files, and records are created, maintained and safeguarded in fulfillment and service of communication and notification processes, including before, during and, where appropriate, subsequent to such processes — and that such documentation remains compliant with policies, principles, and protections for informing communication and notification.
11.30.5. Documentation, Confidentiality
that, where reasonable or required, such adequate books, documents, files, and records are confidential, maintain confidentiality before, during and subsequent to confidential processes, and remain compliant with policies, principles, and protections for confidentiality.
11.30.6. Documentation, Consent
that such adequate books, documents, files, and records are created, maintained and safeguarded in fulfillment and service of consent processes, including before, during and, where appropriate, subsequent to such processes — and that such documentation remains compliant with policies, principles, and protections for informed consent.
11.30.7. Documentation, Infringement
that such adequate books, documents, files, and records are created, maintained and safeguarded in fulfillment and service of infringement detection, evaluation, mitigation and notification processes, including before, during and, where appropriate, subsequent to such processes.
11.30.8. Documentation, Integrity
that such adequate books, documents, files, and records are and remain accurate, available, complete, consistent, intact, and resilient with, where applicable and appropriate, verification from you — as the person concerned — in fulfillment and service of policies, principles, and protections for integrity.
11.30.9. Documentation, Privacy
that, where reasonable or required, such adequate books, documents, files, and records are private, maintain privacy before, during and subsequent to private processes, and remain compliant with policies, principles, and protections for privacy.
11.30.10. Documentation, Protection
that such adequate books, documents, files, and records are both protected and protective, confer and maintain protection throughout their creation, maintenance, safekeeping, and where applicable, transmission — including in service and fulfillment of policies, principles, and procedures for protection.
11.30.11. Documentation, Safety
that such adequate books, documents, files, and records are safe, confer and maintain safety throughout their creation, maintenance, safekeeping, and where applicable, transmission — including in service and fulfillment of policies, principles, and procedures for safety.
11.30.12. Documentation, Security
that such adequate books, documents, files, and records are both secure, confer and maintain security throughout their creation, maintenance, safekeeping, and where applicable, transmission — including in service and fulfillment of policies, principles, and procedures for security.
11.30.13. Documentation, Sensitivity
that, where applicable and required, such adequate books, documents, files, and records are treated as sensitive, maintain sensitivity before, during and subsequent to sensitive processes, and remain compliant with policies, principles, and protections for sensitivity.
11.30.14. Documentation, Transmission
that, where applicable and authorized, such adequate books, documents, files, and records are transmitted — primarily for administrative purposes internal to Publiks — in a limited and restricted manner that ensures compliance with and fulfillment of policies, principles, and protections provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation.
11.30.15. Documentation, Transparency
that, where authorized and required, such adequate books, documents, files, and records are limitedly consulted, disclosed, reproduced, transmitted or otherwise made available by, for and to an entity, office or person external to Publiks, upon mandatory and reasonable request, specifically for transparency with respect to compliance with and fulfillment of the aforementioned policies, principles, and protections.
11.30.15.1. Documentation, Transparency, Non-Identifying
that, where such transparency is feasible and reasonable, it is conducted in a limited and restricted manner that ensures compliance with and fulfillment of the aforementioned policies, principles, and protections, with any disclosed or transmitted records being strictly non-identifying in nature and effect, revealing only the details below.
11.30.15.2. Documentation, Transparency, Non-Identifying, Categories, Data
the categories of personal data and information.
11.30.15.3. Documentation, Transparency, Non-Identifying, Categories, Data Processing
the categories of processing of the personal data and information.
11.30.15.4. Documentation, Transparency, Non-Identifying, Categories, Data Sources
the categories of sources of the personal data and information.
11.30.15.5. Documentation, Transparency, Non-Identifying, Categories, Persons
the categories of persons concerned, with respect to such personal data and information, processing, and administration.
11.30.15.6. Documentation, Transparency, Non-Identifying, Categories, Purposes
the categories of purposes for such personal data and information, processing, and administration.
11.30.15.7. Documentation, Transparency, Non-Identifying, Categories, Recipients
the categories of recipients of the personal data and information, their processing, or the administration of either, including, where applicable, any assignment, delegation, or transfer to a third country, third party, or international organization.
11.30.15.8. Documentation, Transparency, Non-Identifying, Erasure
where feasible and reasonable, the envisaged time limits for erasure of the aforementioned categories details.
11.30.15.9. Documentation, Transparency, Non-Identifying, Protection
where feasible and reasonable, a general description of the administrative, organizational and technical measures taken to ensure the protection of such personal data and information, processing, and administration.
11.30.15.10. Documentation, Transparency, Non-Identifying, Transmission
the context, reason, and time of transparency request, response, and transmission.
11.30.15.11. Documentation, Transparency, Non-Identifying, Transmitter
the contact information of the office or persons at Publiks responsible for such personal data and information, processing, and administration; the authorizer and transmitter of the transparency response and transmission; and the disclosees and recipients of the transparency response and transmission.
— of Infringement
Section 11.31.0. With respect to determining and ensuring adequate mitigation and notification of an infringement of personal data and information, their processing, or the administration of either, you understand and agree to abide by the following:
11.31.1. Infringement, Assessment
that the detection of a breach, infringement, or violation pertaining to data and information, their processing, or the administration of either is promptly followed by a rigorous assessment determining whether the infringement results in an adverse effect on or risk to you — and any other persons concerned — on the basis of an objective evaluation that establishes the likelihood, number, origin, and severity of effects or risks and whether the infringement involves (a-i) no effect; (a-ii) low, minimal or unlikely effect; or (a-iii) high or significant effect and (b-i) no risk; (b-ii) low, minimal or unlikely risk; or (b-iii) high or significant risk.
11.31.2. Infringement, Mitigation
that such assessment is promptly followed by developing and implementing adequate, appropriate and efficacious measures for mitigating effects or risks identified, including best practices methods with respect to factors for, likelihood, number, origin, and severity of effects or risks and with respect to the aspects, characteristics, and parameters of the data and information, processing, administration, and their infringement.
11.31.3.1. Infringement, Notify
that such assessment is promptly followed by a decision whether to notify any persons concerned and any applicable regulatory authority; with the understanding that (a) if no effect or risk, Publiks may decide not to notify, (b) if low, minimal or unlikely effect or risk, Publiks may decide not to notify you only if it promptly conducts mitigation measures, and (c) if high or significant effect or risk, Publiks is to notify you and promptly conduct mitigation measures.
11.31.3.2. Infringement, Notify, Adherence
that any such notification adheres to and fulfills policies, principles, and protections provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation.
11.31.3.3. Infringement, Notify, Description
that any such notification communicates to any persons concerned and any applicable regulatory authority a reasonably informing description of the infringement, including where possible, details as to its characteristics, nature, and the categories and approximate number of both persons concerned and personal data and information records.
11.31.3.4. Infringement, Notify, Effects
that any such notification communicates to any persons concerned and any applicable regulatory authority a reasonably informing description of the adverse effects, consequences, and risks of the infringement.
11.31.3.5. Infringement, Notify, Measures, Official
that any such notification communicates to any persons concerned and any applicable regulatory authority a reasonably informing description of the measures Publiks has conducted or proposed to address the infringement, including, where appropriate, measures to mitigate the adverse effects or risks.
11.31.3.6. Infringement, Notify, Measures, Personal
that any such notification communicates to any persons concerned and any applicable regulatory authority a reasonably informing description of the recommended measures that you — as the person concerned — should promptly take to prevent and reduce any possible adverse effects or risks that could arise from the infringement.
11.31.3.7. Infringement, Notify, Time
that any such notification is sent to any person concerned and any applicable regulatory authority within seventy-two (72) hours of detecting any infringement with high or significant effect or risk.
11.31.3.8. Infringement, Notify, Time Delay
that where such notification above is sent after seventy-two (72) hours of infringement detection, it is accompanied by explanation of reasons for the delay, with full required details, either all at once, in phases without further unreasonable delay, or where such a delay was due to reasonable time requested for necessary investigation, including in coordination with law enforcement, as much detail it can first in phases, then without undue delay after the investigation period is completed.
11.31.4. Infringement, Records
that documentation and records of the infringement and associated notification are created, maintained and safeguarded in a manner that ensures their limited availability, disclosure, and reproducibility, upon mandatory and reasonable request, specifically for demonstration of compliance with policies, principles, and protections provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation.
— of Integrity
Section 11.32.0. With respect to determining and ensuring adequate integrity of personal data and information, their processing, and the administration of both, you understand and agree to abide by the following criteria:
11.32.1. Integrity, Basis
that personal data and information, their processing, and the administration of both maintain integrity with respect to you — as the person concerned — as well as Publiks, and do not infringe any policies, principles, or protections for integrity, as provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation.
11.32.2.1. Integrity, Data
that the personal data and information are accurate, available, complete, consistent, intact, and resilient with, where applicable and appropriate, verification from you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.32.2.2. Integrity, Data Administration
that the administration of personal data and information, and of their processing, is conducted only in a manner that is accurate, available, complete, consistent, intact, and resilient with, where applicable and appropriate, verification from you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.32.2.3. Integrity, Data Processing
that the processing of personal data and information is conducted only in a manner that is accurate, available, complete, consistent, intact, and resilient with, where applicable and appropriate, verification from you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.32.2.4. Integrity, Data Purpose
that such personal data and information, processing, and administration are conducted only for a purpose that maintains integrity with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.32.3. Integrity, Risks
that such personal data and information, processing, and administration account for and protect against risks to confidentiality with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.32.3.1. Integrity, Risks Limitation, Data
that the personal data and information account for and protect against risks to integrity with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.32.3.2. Integrity, Risks Limitation, Data Administration
that the administration of personal data and information, and of their processing, is conducted only in a manner that accounts for and protects against risks to integrity with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.32.3.3. Integrity, Risks Limitation, Data Processing
that the processing of personal data and information is conducted only in a manner that accounts for and protects against risks to integrity with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.32.3.4. Integrity, Risks Limitation, Data Purpose
that such personal data and information, processing, and administration are conducted only for a purpose that accounts for and protects against risks to integrity with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.32.4.1. Integrity, Strict Default
that such personal data and information, processing, and administration, by default, strictly adhere to and fulfill all policies, principles, and protections for integrity with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.32.4.2. Integrity, Strict Design
that such personal data and information, processing, and administration, by design, strictly adhere to and fulfill all policies, principles, and protections for integrity with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.32.5. Integrity, Strict Review
that there is monitoring and periodic strict review to ensure the data and information, their processing, and the administration of both are accurate, available, complete, consistent, intact, and resilient and maintain integrity, and where inadequacies or infringements are found, they are addressed and rectified without undue delay.
11.32.6. Integrity, Strict Review Period
that appropriate, minimum and necessary time considerations — such as duration, frequency, and length between instances — are established for such periodic and strict review for integrity and then for any appropriate and efficacious decision as to continued (or discontinued) administration, processing, rectification, restriction, storage, or termination.
— of Lawfulness
Section 11.33.0. With respect to determining and ensuring the lawfulness of personal data and information, their processing, and the administration of both, you understand and agree to abide by the following criteria:
11.33.1. Lawfulness, Basis
that personal data and information, their processing, and the administration of both are lawful and legal to a sufficient degree to serve as the basis of an Agreement between Publiks and you — as the person concerned — as provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation.
11.33.2. Lawfulness, Communication
that personal data and information, their processing, and the administration of both are accompanied by communication and notification reasonably informing you — as the person concerned — in accordance with policies, principles, and protections for informing communication and notification.
11.33.3. Lawfulness, Consent
that personal data and information, their processing, and the administration of both are accompanied by informed consent (or assent) given and unrevoked by you — as the person concerned — in accordance with policies, principles, and protections for informed consent.
11.33.4. Lawfulness, Ethics
that personal data and information, their processing, and the administration of both are ethical with respect to you — as the person concerned — in accordance with policies, principles, and protections for ethics and ethical conduct and service.
11.33.5. Lawfulness, Law
that personal data and information, their processing, and the administration of both are law-abiding with respect to you — as the person concerned — in accordance with applicable law or regulation.
11.33.5.1. Lawfulness, Law, Illegal
with law-abiding lawfulness satisfied only where such personal data and information, processing, and administration do not — in any way and in any jurisdiction — effect or facilitate a criminal or illegal act, breach, infringement, violation, or equivalent relating to data and information or any associated interests, protections, or rights, especially those pertaining to confidentiality and privacy, as determined or provided for in any official court or law of Canada, a European Union member state, the United Kingdom, or the United States.
11.33.5.2. Lawfulness, Law, Illiberal
with law-abiding lawfulness satisfied only where such personal data and information, processing, and administration do not — in any way and in any jurisdiction — effect or facilitate a civil or illiberal breach, infringement, violation, or equivalent relating to data and information and associated civil liberties or rights, especially those pertaining to confidentiality and privacy, as determined or provided for in any official court or law of Canada, a European Union member state, the United Kingdom, or the United States.
11.33.5.3. Lawfulness, Law, Unconstitutional
with law-abiding lawfulness satisfied only where such personal data and information, processing, and administration do not — in any way and in any jurisdiction — effect or facilitate an unconstitutional act, breach, infringement, violation, or equivalent relating to data and information or any associated interests, protections, or rights, especially those pertaining to confidentiality and privacy, as determined or provided for in any official court or law of Canada, a European Union member state, the United Kingdom, or the United States.
11.33.5.4. Lawfulness, Law, Unlawful
with law-abiding lawfulness satisfied only where such personal data and information, processing, and administration do not — in any way and in any jurisdiction — effect or facilitate an “unlawful disclosure,” “unlawful gathering,” “unlawful processing,” or “wrongful collection” of data and information, or equivalent, as determined or provided for in any official court or law of Canada, a European Union member state, the United Kingdom, or the United States.
11.33.6. Lawfulness, Purpose
that personal data and information, their processing, and the administration of both are appropriate, efficacious, necessary and proportionate for fulfilling the explained, explicit, legitimate and specific purpose consented (or assented) to by you — as the person concerned.
— of Minimization
Section 11.34.0. With respect to determining and ensuring adequate minimization of personal data and information, their processing, and the administration of both, you understand and agree to abide by the following criteria:
11.34.1. Minimization, Basis
that the personal data and information, their processing, and the administration of both are minimized to that which carries “minimal risk” to you — as the person concerned — as well as that which is minimally necessary to fulfill an explained, explicit, legitimate and specific purpose consented (or assented) to by you.
11.34.2. Minimization, As Necessary
that such personal data and information, processing, and administration are necessary, as provided for under the Principle of Necessity and in the Data and Information Policy.
11.34.3.1. Minimization, Data
that the personal data and information are, in quantity and range, minimally necessary to fulfill the purpose consented (or assented) to by you — as the person concerned.
11.34.3.2. Minimization, Data Administration
that the administration of data and information, and their processing, is conducted in a manner, including extent and frequency, minimally necessary to fulfill the purpose consented (or assented) to by you — as the person concerned.
11.34.3.3. Minimization, Data Processing
that the processing of data and information is conducted in a manner, including extent and frequency, minimally necessary to fulfill the purpose consented (or assented) to by you — as the person concerned.
11.34.3.4. Minimization, Data Retention
that the personal data and information are administered, processed and retained only for a time that is limited to what is minimally necessary to fulfill the purpose consented (or assented) to by you — as the person concerned.
11.34.4.1. Minimization, Minimal Risk
that where appropriate and possible, prior and periodic administration and processing — of data and information sets equivalent in aspects, characteristics, and parameters — are consulted to assess anticipated risks, and to ascertain measures that would ensure “minimal risk” for you — as the person concerned.
11.34.4.2. Minimization, Minimal Risk, Data
that the personal data and information carry only the “minimal risk” necessary to fulfill the purpose consented (or assented) to by you — as the person concerned.
11.34.4.3. Minimization, Minimal Risk, Data Administration
that the administration of personal data and information, and of their processing, is conducted in a manner that carries only the “minimal risk” necessary to fulfill the purpose consented (or assented) to by you — as the person concerned.
11.34.4.4. Minimization, Minimal Risk, Data Processing
that the processing of personal data and information is conducted in a manner that carries only the “minimal risk” necessary to fulfill the purpose consented (or assented) to by you — as the person concerned.
11.34.4.5. Minimization, Minimal Risk, Data Retention
that the personal data and information are administered, processed and retained only for a time that carries only the “minimal risk” necessary to fulfill the purpose consented (or assented) to by you — as the person concerned.
11.34.5. Minimization, Strict Review
that there is monitoring and periodic strict review to ensure the data and information, their processing, and the administration of both are minimal and maintain minimization, and where inadequacies or infringements are found, they are addressed and rectified without undue delay.
11.34.6. Minimization, Strict Review Period
that appropriate, minimum and necessary time considerations — such as duration, frequency, and length between instances — are established for such periodic and strict review for minimization and then for any appropriate and efficacious decision as to continued (or discontinued) administration, processing, rectification, restriction, storage, or termination.
— of Necessity
Section 11.35.0. With respect to determining and ensuring adequate necessity of personal data and information, their processing, and the administration of both, you understand and agree to abide by the following criteria:
11.35.1. Necessity, Basis
that the personal data and information, their processing, and the administration of both are necessary to fulfill an explained, explicit, legitimate and specific purpose consented (or assented) to by you — as the person concerned.
11.35.2.1. Necessity, Alternative, Data
that prior and periodic assessment is done to ensure such consented purpose can reasonably be fulfilled only by personal data and information attributable to, identifying or otherwise relating to you — as the person concerned — and not by any alternative data and information, preferably non-personal.
11.35.2.2. Necessity, Alternative, Data Administration
that prior and periodic assessment is done to ensure such consented purpose can reasonably be fulfilled only by a manner of data and information administration that identifies or otherwise relates specifically to you — as the person concerned — and not by any alternative manner of data and information administration, preferably non-personal.
11.35.2.3. Necessity, Alternative, Data Processing
that prior and periodic assessment is done to ensure such consented purpose can reasonably be fulfilled only by a manner of data and information processing that identifies or otherwise relates specifically to you — as the person concerned — and not by any alternative manner of data and information processing, preferably non-personal.
11.35.3.1. Necessity, Limitation, Data
that the personal data and information are limited to what is necessary to fulfill the purpose consented (or assented) to by you — as the person concerned.
11.35.3.2. Necessity, Limitation, Data Administration
that the administration of data and information, and of their processing, is conducted only in a manner that is limited to what is necessary to fulfill the purpose consented (or assented) to by you — as the person concerned.
11.35.3.3. Necessity, Limitation, Data Processing
that the processing of data and information is conducted only in a manner that is limited to what is necessary to fulfill the purpose consented (or assented) to by you — as the person concerned.
11.35.3.4. Necessity, Limitation, Data Purpose
that such personal data and information, processing, and administration are not further conducted for purposes other than the purpose consented (or assented) to by you.
11.35.3.5. Necessity, Limitation, Data Retention
that the personal data and information are administered, processed and retained only for a time that is limited to what is necessary to fulfill the purpose consented (or assented) to by you — as the person concerned.
11.35.4. Necessity, Strict Review
that there is monitoring and periodic strict review to ensure the data and information, their processing, and the administration of both are necessary and maintain necessity, and where inadequacies or infringements are found, they are addressed and rectified without undue delay.
11.35.5. Necessity, Strict Review Period
that appropriate, minimum and necessary time considerations — such as duration, frequency, and length between instances — are established for such periodic and strict review for necessity and then for any appropriate and efficacious decision as to continued (or discontinued) administration, processing, rectification, restriction, storage, or termination.
— of Neutrality
Section 11.36.0. With respect to determining and ensuring adequate neutrality of personal data and information, their processing, and the administration of both, you understand and agree to abide by the following criteria:
11.36.1. Neutrality, Basis
that the personal data and information, their processing, and the administration of both confer, as an effect, fulfillment of data and information policies, principles, and protections with respect to you — as the person concerned — that is neutral, i.e., ensured to an equivalent or same extent, across feasible and reasonable options for data and information, their processing, and the administration of both.
11.36.2.1. Neutrality, Data
that the administration and processing of personal data and information are conducted in manner conferring such protective effect to you — as the person concerned — that is data neutral, i.e., ensured to an equivalent or same extent, across feasible and reasonable options for data and information.
11.36.2.2. Neutrality, Data Administration
that the administration of personal data and information, and of their processing, is conducted in manner conferring protective effect to you — as the person concerned — that is administration neutral, i.e., ensured to an equivalent and same extent, across feasible and reasonable options for administering data and information and their processing.
11.36.2.3. Neutrality, Data Processing
that the processing of personal data and information is conducted in manner conferring protective effect to you — as the person concerned — that is processing neutral, i.e., ensured to an equivalent and same extent, across feasible and reasonable options for processing data and information.
11.36.2.4. Neutrality, Data Purpose
that the administration and processing of personal data and information are conducted in manner conferring such protective effect to you — as the person concerned — that is purpose neutral, i.e., ensured to an equivalent or same extent, across feasible and reasonable options for purposes of data and information, their processing, and administration of both.
11.36.3. Neutrality, Evaluative Review
that where appropriate and possible, prior and periodic administration and processing — of data and information sets equivalent and dissimilar in aspects, characteristics, and parameters — are consulted to evaluate protective effects and measures that would ensure neutrality for you — as the person concerned.
11.36.4. Neutrality, Strict Review
that there is monitoring and periodic strict review to ensure the data and information, their processing, and the administration of both are neutral and maintain neutrality, and where inadequacies or infringements are found, they are addressed and rectified without undue delay.
11.36.5. Neutrality, Strict Review Period
that appropriate, minimum and necessary time considerations — such as duration, frequency, and length between instances — are established for such periodic and strict review for neutrality and then for any appropriate and efficacious decision as to continued (or discontinued) administration, processing, rectification, restriction, storage, or termination.
— of Non-Identification
Section 11.37.0. With respect to determining and ensuring adequate non-identification of personal data and information, their processing, and the administration of both, you understand and agree to abide by the following two-part evaluation:
11.37.1. Non-Identification, Basis
that where appropriate, feasible and reasonable — and certainly where necessary or required — data and information, their processing, and the administration of both do not permit or require attributing to, identifying or otherwise relating to you or any other person.
11.37.2.1. Non-Identification, Design, Data
that, where reasonable or required, data and information are accessed, collected or otherwise processed in a manner that — by design — generates data and information that are non-identifying in nature or effect, for instance, initially anonymous or non-personal data and information or subsequent processes of de-identification, pseudonymization, pseudo-anonymization, anonymization, and irreversible anonymization.
11.37.2.2. Non-Identification, Design, Data Administration
that, where reasonable or required, the administration of personal data and information is conducted in a manner that — by design — is non-identifying in nature or effect, for instance, absolute approaches to anonymous or non-personal administration, including encryption, and product-limited, service-limited and task-limited administration of de- and re-identified personal data and information.
11.37.2.3. Non-Identification, Design, Data Processing
that, where reasonable or required, the processing of personal data and information is conducted in a manner that — by design — is non-identifying in nature or effect, for instance, absolute approaches to anonymous or non-personal processing, including encryption, and device-limited, task-limited and user-limited processing of de- and re-identified personal data and information.
11.37.2.4. Non-Identification, Design, Protection
that the above is and remains critical for attaining and maintaining standards for data and information protection by design.
11.37.3.1. Non-Identification, Default
that where any personal data and information, their processing, or the administration of either are non-identifying with respect to you — as the (supposed) person concerned — Publiks maintains a normative default position of refraining from accessing, maintaining, or otherwise processing any additional data and information attributable to, identifying or otherwise relating to you or another person.
11.37.3.2. Non-Identification, Default, Exception
that the default position will be rigorously maintained, except where Publiks receives a consented request from you — as the (supposed) person concerned — that meets the requirements below.
11.37.3.3. Non-Identification, Default, Exception, Additional Data
that, as part of the consented request, you — as the (supposed) person concerned — provide additional data and information identifying you and connecting you to the non-identifying personal data and information.
11.37.3.4. Non-Identification, Default, Exception, Authenticating Data
that such additional data and information include authenticating and matching credentials for digital or electronic identification and security mechanisms, for example, answers to identity or security questions, biometric data, login credentials, one-time codes for multi-factor or two-factor authentication, passkeys, or physical security keys.
11.37.3.5. Non-Identification, Default, Protection
that the above position and strict requirements for exception are and remain critical for attaining and maintaining standards for data and information protection by default.
11.37.4.1. Non-Identification, Process, At Origin, Onset
that, where reasonable or required, data and information are accessed, collected and otherwise processed in a manner that originates non-personal forms and states at or from the beginning, onset, origin, or source, with no ability or possibility of attributing to, identifying or otherwise relating to any person.
11.37.4.2. Non-Identification, Process, Early, Proximate
that, where reasonable or required, data and information are accessed, collected and otherwise processed in a manner that results in non-personal forms and states early in processing, immediately after or proximate to the beginning, onset, origin, or source, with no ability or possibility of attributing to, identifying or otherwise relating to any person.
11.37.4.3. Non-Identification, Process, Further, Subsequent
that, where reasonable or required, data and information are further accessed, collected and otherwise processed in a manner that results in non-personal forms and states subsequent to earlier processing, including further aggregation of non-personal data and information with multiple equivalently non-personal datasets in order to ensure the non-personal state; where all non-identification conditions are irreversibly met, such data and information may be safely treated as non-personal.
11.37.4.4. Non-Identification, Process, Irreversization
that previously personal data and information are to be treated as non-personal only if and to the extent that such further processing includes successful irreversible anonymization combined with aggregation (“irreversization” or “irreversibilization”), i.e. aggregation of newly anonymized data and information with multiple equivalently anonymized datasets to attain and ensure the non-personal state; where all such conditions are irreversibly met, such data and information may be safely treated as non-personal.
11.37.4.5. Non-Identification, Process, Preventive Aggregation
that the decision to safely treat de-identified or anonymized personal data and information as non-personal is based primarily on the possibility of re-identification, i.e. the ability to combine or cross-reference with any other identifying data and information that renders the anonymized or de-identified data and information effectively attributable to, identifying or otherwise directly relating to you or another person; currently, the best protection against such possibility is the processes of data summary and data transformation entailed in aggregation.
11.37.5.1. Non-Identification, Purposes
that, where reasonable or required, non-identifying and non-personal data and information, if priorly consented and in irreversibly anonymized and aggregated form, may be treated as non-personal data and information not further subject to the policies, principles, and protections for personal data and information, solely for purposes below.
11.37.5.2. Non-Identification, Purposes, Consented
for an explicit, legitimate and specific purpose consented to by you — as the person initially and supposedly concerned.
11.37.5.3. Non-Identification, Purposes, Organization
for consented, explicit, legitimate and specific purposes of administering as well as fulfilling the duties, functions, interests, legal obligations, policies, principles, protections, and responsibilities of Publiks, as an organizational entity, including as provided for in the Data and Information Policy and the Codes and Policies.
11.37.5.4. Non-Identification, Purposes, Personalization, None
for consented, explicit, legitimate and specific purposes of administering, engaging in, or offering a conduct or service in a manner that is non-personalized.
11.37.5.5. Non-Identification, Purposes, Personalization, Pseudo
for consented, explicit, legitimate and specific purposes of administering, engaging in, or offering experiences, instances, or versions of a conduct or service that are pseudo-personalized, that is, tailored to categories of persons via a non-identifying overlap of non-identifying data and information.
11.37.5.6. Non-Identification, Purposes, Personalization, Real
for consented, explicit, legitimate and specific purposes of administering, engaging in, or offering experiences, instances, or versions of a conduct or service that are really or truly personalized, that is, tailored to specific persons via a re-identifying authentication or overlap of previously non-identifying data and information.
11.37.6.1. Non-Identification, Re-Identification
that you consent to re-identification whenever you permit the combination of previously anonymized, de-identified or non-identifying data and information with re-identifying data and information — in this case, such temporarily combined data and information is treated as personal for the duration, and thus subject to the policies, principles, and protections of personal data and information, until the combined form is reversed.
11.37.6.2. Non-Identification, Re-Identification, Authentication
that you are to take re-identification as a serious matter, endeavoring to protect yourself while partaking of any conduct or service involving data and information by, first, being thoughtful about your informed consent and the consent process, and second, making sure you are developing, protecting, and using Privately and Uniquely and Authenticating Data, as described below.
11.37.6.3. Non-Identification, Re-Identification, Only-You-Could-Know
making sure you are authenticating yourself with something only you or one other living person could access, know, or possess at any given and precise time.
11.37.6.4. Non-Identification, Re-Identification, Rarely Used, Written
where necessary, making sure that any names, pseudonyms, or usernames you offer or use to authenticate yourself are themselves rarely used, relatively undocumented and well-protected — for instance, given or taken during private rites or equivalently undocumented activities or events.
11.37.6.5. Non-Identification, Re-Identification, Well-Constructed, Changed
making sure you are authenticating yourself with passcodes and passwords that are also well-constructed (that is, gobbledygook and nonsensical), well-protected and regularly changed.
11.37.6.6. Non-Identification, Re-Identification, Well-Protected Answers
making sure you are authenticating yourself with answers to security clues, hints, or questions that are also hard to find or guess, not obvious, rarely used and well-protected.
11.37.6.7. Non-Identification, Re-Identification,With Passcode Authenticator
wherever it is possible, making sure you are also authenticating yourself with a well-protected authenticator device that generates a single-use and time-limited code to enter after you have inputted your passcode or password.
11.37.6.8. Non-Identification, Re-Identification, With Password Management
always and in every instance, making sure you are also authenticating yourself with passcodes and passwords kept in a highly privacy-preserving passcode and password management system, certainly those that use encryption and preferably those that do not require backup to another organization’s central server.
11.37.6.9. Non-Identification, Re-Identification, With Physically Inserted Key
wherever it is possible, making sure you are also authenticating yourself with a physical authenticating key that you must have in hand and insert to proceed with sensitive activity.
11.37.7.1. Non-Identification, Treatment, Personal
that, therefore, to the extent that data and information can be combined or cross-referenced to identify any person (also even by deduction or inference) or be reversibly de-anonymized, such de-identified, non-identifying or anonymized data and information are and remain personal at Publiks and are subject to requirements for fulfilling the policies, principles, and protections of personal data and information, to be treated as such (even confidential, private and sensitive) till their deletion, erasure, or irreversible destruction, if possible.
11.37.7.2. Non-Identification, Treatment, Personal, Temporary
that wherever non-personal data and information are combined with those that are personal the result is a combined form to be appropriately treated as personal, for as long as the combination remains intact.
11.37.8. Non-Identification, Strict Review
that there is monitoring and periodic strict review to ensure the data and information, their processing, and the administration of both are non-identifying and maintain non-identification, and where inadequacies or infringements are found, they are addressed and rectified without undue delay.
11.37.9. Non-Identification, Strict Review Period
that appropriate, minimum and necessary time considerations — such as duration, frequency, and length between instances — are established for such periodic and strict review for non-identification and then for any appropriate and efficacious decision as to continued (or discontinued) administration, processing, rectification, restriction, storage, or termination.
— of Privacy
Section 11.38.0. With respect to determining and ensuring adequate privacy of personal data and information, their processing, and the administration of both, you understand and agree to abide by the following criteria:
11.38.1. Privacy, Basis
that personal data and information, their processing, and the administration of both maintain privacy with respect to you — as the person concerned — as well as Publiks, and do not infringe any policies, principles, or protections for privacy, as provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation.
11.38.2.1. Privacy, Data
that, where appropriate or required, the personal data and information are private with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.38.2.2. Privacy, Data Administration
that, where appropriate or required, the administration of personal data and information, and of their processing, is conducted only in a manner that is private with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.38.2.3. Privacy, Data Processing
that, where appropriate or required, the processing of personal data and information is conducted only in a manner that is private with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.38.2.4. Privacy, Data Purpose
that, where appropriate or required, such personal data and information, processing, and administration are conducted only for a purpose that is private with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.38.3. Privacy, Risks
that such personal data and information, processing, and administration account for and protect against risks to privacy with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.38.3.1. Privacy, Risks Limitation, Data
that the personal data and information account for and protect against risks to privacy with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.38.3.2. Privacy, Risks Limitation, Data Administration
that the administration of personal data and information, and of their processing, is conducted only in a manner that accounts for and protects against risks to privacy with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.38.3.3. Privacy, Risks Limitation, Data Processing
that the processing of personal data and information is conducted only in a manner that accounts for and protects against risks to privacy with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.38.3.4. Privacy, Risks Limitation, Data Purpose
that such personal data and information, processing, and administration are conducted only for a purpose that accounts for and protects against risks to privacy with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.38.4.1. Privacy, Strict Default
that such personal data and information, processing, and administration, by default, strictly adhere to and fulfill all policies, principles, and protections for privacy with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.38.4.2. Privacy, Strict Design
that such personal data and information, processing, and administration, by design, strictly adhere to and fulfill all policies, principles, and protections for privacy with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.38.5. Privacy, Strict Review
that there is monitoring and periodic strict review to ensure the data and information, their processing, and the administration of both are private and maintain privacy, and where inadequacies or infringements are found, they are addressed and rectified without undue delay.
11.38.6. Privacy, Strict Review Period
that appropriate, minimum and necessary time considerations — such as duration, frequency, and length between instances — are established for such periodic and strict review for privacy and then for any appropriate and efficacious decision as to continued (or discontinued) administration, processing, rectification, restriction, storage, or termination.
— of Protection
Section 11.39.0. With respect to determining and ensuring adequate protection of personal data and information, their processing, and the administration of both, you understand and agree to abide by the following criteria:
11.39.1. Protection, Basis
that personal data and information, their processing, and the administration of both confer adequate protective effect with respect to you — as the person concerned — as provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation.
11.39.1.1. Protection, Basis, Bias
with the understanding that such protective effect entails the mitigation of and protection against bias, discrimination, marginalization, or stigmatization against you — as the person concerned — to the most feasible and reasonable extent.
11.39.1.2. Protection, Basis, Harm
with the understanding that such protective effect entail the mitigation of and protection against harm, injury, or equivalent of you — as the person concerned — to the most feasible and reasonable extent.
11.39.1.3. Protection, Basis, Infringement, Data
with the understanding that such protective effect entails the mitigation of and protection against infringement of such personal data and information, processing, and administration.
11.39.1.4. Protection, Basis, Infringement, Organization
with the understanding that such protective effect entails the mitigation of and protection against infringement of Publiks, as an organizational entity, and the administrative powers and responsibilities of the Founder, Alvan Azinna Chibuzo Ikoku.
11.39.1.5. Protection, Basis, Infringement, Policies
with the understanding that such protective effect entails the mitigation of and protection against infringement of polices, principles, and protections provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation.
11.39.1.6. Protection, Basis, Infringement, Rights
with the understanding that such protective effect entails the mitigation of and protection against infringement of civil liberties or rights accorded by your polities to you — as the person concerned — to the most feasible and reasonable extent.
11.39.1.7. Protection, Basis, Resulting Effect
with the understanding that such protective effect entails the mitigation of and protection against adverse effects on you — as the person concerned — resulting from any of the aforementioned, to the most feasible and reasonable extent.
11.39.1.8. Protection, Basis, Risks
with the understanding that such protective effect entails the mitigation of and protection against risks to you — as the person concerned — of any of the aforementioned occurring, to the most feasible and reasonable extent.
11.39.2.1. Protection, Data
that the processing of personal data and information is conducted only on data and information that are protective with respect to you — as the person concerned — to the most feasible and reasonable extent.
11.39.2.2. Protection, Data Administration
that the administration of personal data and information, and of their processing, is conducted only in a manner that is protective with respect to you — as the person concerned — to the most feasible and reasonable extent.
11.39.2.3. Protection, Data Processing
that the processing of personal data and information is conducted only in a manner that is protective with respect to you — as the person concerned — to the most feasible and reasonable extent.
11.39.2.4. Protection, Data Purpose
that personal data and information, their processing, and the administration of both are conducted only for a purpose that is protective with respect to you — as the person concerned — to the most feasible and reasonable extent.
11.39.3. Protection, Risks
that personal data and information, their processing, and the administration of both ascertain, assess, and protect against risks to you — as the person concerned — to the most feasible and reasonable extent.
iv. Protection, Risks, Ascertainment
that personal data and information, their processing, and the administration of both is accompanied by a data and information risk ascertainment that conducts an objective evaluation detecting and defining actual and anticipated adverse effects and risks with respect to you — as the person concerned — and to the data and information.
11.39.4.1. Protection, Risks, Ascertainment, Definition
that, where adverse effects or risks are detected, such data and information risk ascertainment defines their characteristics, including the factors leading to, likelihood, number, origin, and severity of adverse effects or risks with respect to you — as the person concerned — and to the data and information.
11.39.4.2. Protection, Risks, Ascertainment, Definition, Data Aspects
that such data and information risk ascertainment defines such characteristics while accounting for and informing determinations as to the appropriate aspects, characteristics, and parameters of data and information, their processing, and the administration of both, as provided for in the Data and Information Policy, under the Principle of Appropriateness.
11.39.4.3. Protection, Risks, Ascertainment, Establishment
that, subsequent to the definition of characteristics, such data and information risk ascertainment establishes whether the personal data and information, their processing, or the administration of either involves (a) no effect; low, minimal or unlikely effect; or high or significant effect and (b) no risk; low, minimal or unlikely risk; or high or significant risk.
11.39.4.4. Protection, Risks, Ascertainment, Mitigation
that, subsequent to the establishment of adverse effects and risks, such data and information risk ascertainment entails early implementation of adequate, appropriate and efficacious measures for mitigating adverse effects and risks identified, including best practices methods for the characteristics of adverse effects and risks and for the aspects, characteristics, and parameters of data and information, their processing, and the administration of both.
11.39.4.5. Protection, Risks, Ascertainment, Relation
that, subsequent to the early mitigation of adverse effects and risks, such data and information risk ascertainment entails the determination of relation between benefit and risk with respect to you — as the person concerned — of data and information, their processing, and the administration of both.
11.39.5. Protection, Risks, Assessment
that personal data and information, their processing, and the administration of both is accompanied by a data and information risk assessment where any of the following indications are found.
11.39.5.1. Protection, Risks, Assessment, Indication, High Risk
that, where the data and information ascertainment establishes a high or significant effect or risk, a subsequent data and information risk assessment is indicated and is conducted.
11.39.5.2. Protection, Risks, Assessment, Indication, Method, Automated
that, where the data and information ascertainment identifies administration or processing involvement of automation or automated methods, including automated individual decision-making and profiling, a subsequent data and information risk assessment is indicated and is conducted.
11.39.5.3. Protection, Risks, Assessment, Indication, Method, Large Scale
that, where the data and information ascertainment identifies administration or processing on a large scale, thus potentially affecting large numbers of persons who may not easily exercise their civil liberties or rights, a subsequent data and information risk assessment is indicated and is conducted.
11.39.5.4. Protection, Risks, Assessment, Indication, Method, New
that, where the data and information ascertainment identifies administration or processing via new methods or technologies, a subsequent data and information risk assessment is indicated and is conducted.
11.39.5.5. Protection, Risks, Assessment, Indication, Method, Publicly Accessible Area
that, where the data and information ascertainment identifies administration or processing involvement — including collection and systematic monitoring — of a publicly accessible area, a subsequent data and information risk assessment is indicated and is conducted.
11.39.5.6. Protection, Risks, Assessment, Indication, Sensitive Data
that, where the data and information ascertainment identifies the involvement of sensitive personal data and information, a subsequent data and information risk assessment is indicated and is conducted.
11.39.5.7. Protection, Risks, Assessment, Description
that, where indicated, the subsequent data and information risk assessment systematically describes and explains such personal data and information, processing, and administration, including their aspects, characteristics, and parameters.
11.39.5.8. Protection, Risks, Assessment, Necessity
that, where indicated, the subsequent data and information risk assessment systematically assesses and ensures the appropriateness, minimization, necessity, and non-identification of such personal data and information, processing, and administration.
11.39.5.9. Protection, Risks, Assessment, Review, Data
that, where indicated, the subsequent data and information risk assessment systematically reviews and ensures the use of adequate, appropriate and efficacious administrative, organizational and technical measures — for or on the personal data and information — to mitigate and protect against actual and anticipated adverse effects and risks resulting from such data and information.
11.39.5.10. Protection, Risks, Assessment, Review, Data Administration
that, where indicated, the subsequent data and information risk assessment systematically reviews and ensures the use of adequate, appropriate and efficacious administrative, organizational and technical measures — for the administration of the personal data and information and of their processing — to mitigate and protect against actual and anticipated adverse effects and risks resulting from such administration.
11.39.5.11. Protection, Risks, Assessment, Review, Data Processing
that, where indicated, the subsequent data and information risk assessment systematically reviews and ensures the use of adequate, appropriate and efficacious administrative, organizational and technical measures — for the processing of the personal data and information — to mitigate and protect against actual and anticipated adverse effects and risks resulting from such processing.
11.39.5.12. Protection, Risks, Assessment, Review, Decision-Making
that, where automated decision-making and methods are involved, the subsequent data and information risk assessment systematically reviews and ensures the use of adequate, appropriate and efficacious administrative, organizational and technical measures — including computational, logical, mathematical, profiling and statistical methods or procedures — to mitigate and protect against actual and anticipated adverse effects and risks resulting from such decision-making.
11.39.5.13. Protection, Risks, Assessment, Similar Sets
that, where indicated, the subsequent data and information risk assessment systematically draws careful and selective insights from highly similar samples and sets of personal data and information, their processing, and the administration of both — with degree of similarity based on data and information aspects, characteristics, and parameters and on characteristics of adverse effects and risks.
11.39.6.1. Protection, Risks Limitation, Data
that the processing of personal data and information is conducted only on data and information that account and assess for, avoid, and protect against anticipated, excessive, unexpected, unexplained or unnecessary risks, as well as standard threats, with respect to you — as the person concerned.
11.39.6.2. Protection, Risks Limitation, Processing
that the processing of personal data and information is conducted only in a manner that accounts and assesses for, avoid, and protects against anticipated, excessive, unexpected, unexplained or unnecessary risks, as well as standard threats, with respect to you — as the person concerned.
11.39.6.3. Protection, Risks Limitation, Purpose
that the processing of personal data and information is conducted only for purposes that account and assess for, avoid, and protect against anticipated, excessive, unexpected, unexplained or unnecessary risks, as well as standard threats, with respect to you — as the person concerned.
11.39.7.1. Protection, Strict Default
that the processing of personal data and information is strictly protective, by default, with respect to you — as the person concerned.
11.39.7.2. Protection, Strict Design
that the processing of personal data and information is strictly protective, by design, with respect to you — as the person concerned.
11.39.8. Protection, Strict Review
that there is monitoring and periodic strict review to ensure the data and information, their processing, and the administration of both are protective and maintain protection, and where inadequacies or infringements are found, they are addressed and rectified without undue delay.
11.39.9. Protection, Strict Review Period
that appropriate, minimum and necessary time considerations — such as duration, frequency, and length between instances — are established for such periodic and strict review for protection and then for any appropriate and efficacious decision as to continued (or discontinued) administration, processing, rectification, restriction, storage, or termination.
— of Safety
Section 11.40.0. With respect to determining and ensuring adequate safety of personal data and information, their processing, and the administration of both, you understand and agree to abide by the following criteria:
11.40.1. Safety, Basis
that personal data and information, their processing, and the administration of both maintain safety with respect to you — as the person concerned — as well as Publiks, and do not infringe any policies, principles, or protections for safety, as provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation.
11.40.2.1. Safety, Data
that the personal data and information are safe with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.40.2.2. Safety, Data Administration
that the administration of personal data and information, and of their processing, is conducted only in a manner that is safe with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.40.2.3. Safety, Data Processing
that the processing of personal data and information is conducted only in a manner that is safe with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.40.2.4. Safety, Data Purpose
that such personal data and information, processing, and administration are conducted only for a purpose that is safe with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.40.3. Safety, Risks
that such personal data and information, processing, and administration account for and protect against risks to safety with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.40.3.1. Safety, Risks Limitation, Data
that the personal data and information account for and protect against risks to safety with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.40.3.2. Safety, Risks Limitation, Data Administration
that the administration of personal data and information, and of their processing, is conducted only in a manner that accounts for and protects against risks to safety with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.40.3.3. Safety, Risks Limitation, Data Processing
that the processing of personal data and information is conducted only in a manner that accounts for and protects against risks to safety with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.40.3.4. Safety, Risks Limitation, Data Purpose
that such personal data and information, processing, and administration are conducted only for a purpose that accounts for and protects against risks to safety with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.40.4.1. Safety, Strict Default
that such personal data and information, processing, and administration, by default, strictly adhere to and fulfill all policies, principles, and protections for safety with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.40.4.2. Safety, Strict Design
that such personal data and information, processing, and administration, by design, strictly adhere to and fulfill all policies, principles, and protections for safety with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.40.5. Safety, Strict Review
that there is monitoring and periodic strict review to ensure the data and information, their processing, and the administration of both are safe and maintain safety, and where inadequacies or infringements are found, they are addressed and rectified without undue delay.
11.40.6. Safety, Strict Review Period
that appropriate, minimum and necessary time considerations — such as duration, frequency, and length between instances — are established for such periodic and strict review for safety and then for any appropriate and efficacious decision as to continued (or discontinued) administration, processing, rectification, restriction, storage, or termination.
— of Security
Section 11.41.0. With respect to determining and ensuring adequate security of personal data and information, their processing, and the administration of both, you understand and agree to abide by the following criteria:
11.41.1. Security, Basis
that personal data and information, their processing, and the administration of both maintain security with respect to you — as the person concerned — as well as Publiks, and do not infringe any policies, principles, or protections for safety, as provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation.
11.41.2.1. Security, Data
that the personal data and information are secure with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.41.2.2. Security, Data Administration
that the administration of personal data and information, and of their processing, is conducted only in a manner that is secure with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.41.2.3. Security, Data Processing
that the processing of personal data and information is conducted only in a manner that is secure with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.41.2.4. Security, Data Purpose
that such personal data and information, processing, and administration are conducted only for a purpose that is secure with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.41.3. Security, Risks
that such personal data and information, processing, and administration account for and protect against risks to security with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.41.3.1. Security, Risks Limitation, Data
that the personal data and information account for and protect against risks to security with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.41.3.2. Security, Risks Limitation, Data Administration
that the administration of personal data and information, and of their processing, is conducted only in a manner that accounts for and protects against risks to security with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.41.3.3. Security, Risks Limitation, Data Processing
that the processing of personal data and information is conducted only in a manner that accounts for and protects against risks to security with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.41.3.4. Security, Risks Limitation, Data Purpose
that such personal data and information, processing, and administration are conducted only for a purpose that accounts for and protects against risks to security with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.41.4.1. Security, Strict Default
that such personal data and information, processing, and administration, by default, strictly adhere to and fulfill all policies, principles, and protections for security with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.41.4.2. Security, Strict Design
that such personal data and information, processing, and administration, by design, strictly adhere to and fulfill all policies, principles, and protections for security with respect to you — as the person concerned — as well as Publiks, to the most feasible and reasonable extent.
11.41.5. Security, Strict Review
that there is monitoring and periodic strict review to ensure the data and information, their processing, and the administration of both are secure and maintain security, and where inadequacies or infringements are found, they are addressed and rectified without undue delay.
11.41.6. Security, Strict Review Period
that appropriate, minimum and necessary time considerations — such as duration, frequency, and length between instances — are established for such periodic and strict review for security and then for any appropriate and efficacious decision as to continued (or discontinued) administration, processing, rectification, restriction, storage, or termination.
— of Sensitivity
Section 11.42.0. With respect to determining and ensuring adequate sensitivity of sensitive data and information, their processing, and the administration of both, you understand and agree to abide by the following criteria:
11.42.1. Sensitivity, Basis
that sensitive data and information, their processing, and the administration of both maintain sensitivity with respect to you — as the person concerned — and do not infringe any policies, principles, or protections for sensitivity, as provided for in the Data and Information Policy, the Codes and Policies, and applicable law and regulation.
11.42.2.1. Sensitivity, Design, Data
that, where reasonable or required, data and information are accessed, collected or otherwise processed in a manner that — by design — generates data and information that are not sensitive in nature or effect.
11.42.2.2. Sensitivity, Design, Data Administration
that, where reasonable or required, the administration of personal data and information is conducted in a manner that — by design — is not sensitive in nature or effect.
11.42.2.3. Sensitivity, Design, Data Processing
that, where reasonable or required, the processing of personal data and information is conducted in a manner that — by design — is not sensitive in nature or effect.
11.42.2.4. Sensitivity, Design, Protection
that the above is critical for attaining and maintaining standards for sensitivity protection by design.
11.42.3.1. Sensitivity, Default, Data
that where any personal data and information may be sensitive with respect to you — as the (supposed) person concerned — Publiks maintains a normative default position of refraining from accessing, maintaining, or obtaining any such data and information.
11.42.3.2. Sensitivity, Default, Data Administration
that where any administration of personal data and information may be sensitive with respect to you — as the (supposed) person concerned — Publiks maintains a normative default position of refraining from such administration.
11.42.3.3. Sensitivity, Default, Data Processing
that where any processing of personal data and information may be sensitive with respect to you — as the (supposed) person concerned — Publiks maintains a normative default position of refraining from such processing.
11.42.3.4. Sensitivity, Default, Exception
that the default position will be rigorously maintained, except where Publiks receives a consented request from you — as the (supposed) person concerned — that meets the requirements below.
11.42.3.5. Sensitivity, Default, Exception, Compliance
that there is a guarantee from you and Publiks that all policies, principles, and protections for personal data and information are and will remain fulfilled.
11.42.3.6. Sensitivity, Default, Exception, Consent
that there is no applicable law or regulation prohibiting you — as the person concerned — from giving your consent to the processing of the sensitive data and information, for the explicit, legitimate, specific purpose for which your consent is being asked or renewed.
11.42.3.7. Sensitivity, Default, Exception, Non-Identification
that the sensitive data and information obtained are accessed and otherwise processed in a manner that rigorously fulfills the principle of non-identification — with irreversible anonymization and aggregation preferred — so your identity cannot be ascertained, directly or indirectly through identifiers linked to you.
11.42.3.8. Sensitivity, Default, Exception, Re-Identification
that whenever the sensitive data and information are accessed or otherwise processed in such a manner that your identity can be ascertained, directly or indirectly through identifiers, Publiks rigorously adheres to protective protocols reviewed by the DRB specifically for the processing prior to its approval.
11.42.3.9. Sensitivity, Default, Exception, Risks
that there is rigorous assessment of actual and anticipated risks, then protections implemented to ensure, as much as possible, minimal risk to you — person concerned — as well as mitigation and protection against such adverse risks.
11.42.3.10. Sensitivity, Default, Exception, Risks, Coercion
that there is rigorous assessment of actual and anticipated risks of undue coercion or inducement, then protections implemented to eliminate or minimize the prospect of offering direct or indirect benefits of such a magnitude as to impair your ability to weigh the risks against the benefits with respect to you — as the person concerned.
11.42.3.11. Sensitivity, Default, Exception, Risks, Disclosure
that there is rigorous assessment of actual and anticipated risks, then protections implemented to minimize any harms upon breach or disclosure, including those which place you — as the person concerned — at risk of civil or criminal liability, damage to your educational advancement, employability, financial standing or reputation, or ostracization or stigmatization.
11.42.3.12. Sensitivity, Default, Exception, Risks Limitation, Data
that the processing of personal data and information is conducted only on data and information that account for and protect against risks of such sensitivity with respect to you — as the person concerned.
11.42.3.13. Sensitivity, Default, Exception, Risks Limitation, Data Administration
that the administration of personal data and information, and of their processing, is conducted only in a manner that accounts for and protects against risks of such sensitivity with respect to you — as the person concerned.
11.42.3.14. Sensitivity, Default, Exception, Risks Limitation, Data Processing
that the processing of personal data and information is conducted only in a manner that accounts for and protects against risks of such sensitivity with respect to you — as the person concerned.
11.42.3.15. Sensitivity, Default, Exception, Risks Limitation, Data Purpose
that the processing of personal data and information is conducted only for purposes that account for and protect against of such sensitivity with respect to you — as the person concerned.
11.42.3.16. Sensitivity, Default, Exception, Restricted Uses
that the sensitive personal data and information are expressly and manifestly made accessible or public by you — as the person concerned — only for your own consented, explicit and sole benefit, purposes, and uses.
11.42.3.17. Sensitivity, Default, Non-Exception, Where Academia
that where an academic argument, interest, need, or purpose is the overriding or primary purpose for the processing,
11.42.3.18. Sensitivity, Default, Non-Exception, Where Journalism
and where a news or journalism or broad or specific public argument, interest, need, or purpose is the overriding or primary purpose for the processing,
11.42.3.19. Sensitivity, Default, Non-Exception, Where Public Benefit
and where a broad or specific public benefit argument, interest, need, or purpose is the overriding or primary purpose for the processing,
11.42.3.20. Sensitivity, Default, Non-Exception, Where Public Health
and where a public health argument, benefit, interest, need, or purpose is the overriding or primary purpose for the processing,
11.42.3.21. Sensitivity, Default, Non-Exception, Where Research
and where health, medical or scientific research is the overriding or primary purpose for the processing,
11.42.3.22. Sensitivity, Default, Non-Exception, Where Service, Care
and where care, health or medical services is the overriding or primary purpose for the processing,
11.42.3.23. Sensitivity, Default, Non-Exception, Where Service, Legal, Social
and where legal or social work or service is the overriding or primary purpose for the processing,
11.42.3.24. Sensitivity, Default, Non-Exception, Where Services, Liberties, Rights
and where nonprofit civic liberties and rights service is the overriding or primary purpose for the processing,
11.42.3.25. Sensitivity, Default, Non-Exception, Where There is Agreement Expectation
and where there is an expectation or request for an agreement, arrangement, contract, employment, volunteering, or equivalent to be considered, made or offered,
11.42.3.26. Sensitivity, Default, Non-Exception, Where Therefore Prohibited
in the aforementioned circumstances, Publiks will determine that the aforementioned argumentation, benefit, interests, needs, and purposes cannot themselves be considered lawful or legitimate and so cannot override the consent (or assent) decisions, interests, processes, or protections for you — as the person concerned — and Publiks therefore strictly prohibits any processing of personal data and information, as well as funding or supporting such processing, for solely such purposes. Publiks further strongly urges — on successful review and consent under any of the aforementioned circumstances — that every possible measure be taken to make and request such consideration without recourse to accessing or otherwise processing sensitive data and information, and where such access or other processing proves necessary, to meet additional and more restrictive requirements via federally-mandated ethical or institutional review board policies, processes, and practices that the Founder, Alvan Azinna Ikoku, and Publiks will develop, authorize, and provide.
11.42.4. Sensitivity, Default, Protection
that the above position and strict requirements for exception are critical for attaining and maintaining standards for sensitivity protection by default.
11.42.5. Sensitivity, Strict Review
that there is monitoring and periodic strict review to ensure the data and information, their processing, and the administration of both are sensitively handled and maintain sensitivity, and where inadequacies or infringements are found, they are addressed and rectified without undue delay.
11.42.6. Sensitivity, Strict Review Period
that appropriate, minimum and necessary time considerations — such as duration, frequency, and length between instances — are established for such periodic and strict review for sensitivity and then for any appropriate and efficacious decision as to continued (or discontinued) administration, processing, rectification, restriction, storage, or termination.
— of Standardization
Section 11.43.0. With respect to determining and ensuring adequate standardization of data and information, their processing, and the administration of both, you understand and agree to abide by the following criteria:
11.43.1. Standardization, Basis
that there is monitoring and periodic review of the personal data and information, their processing, and the administration of both to ensure centrality, commensurability and case resolution, compliance, and coordinated harmonization across activities, areas, and systems, and by these means, to standardize expectations and practices for data and information policies, principles, and protections to the most feasible and reasonable extent.
11.43.2. Standardization, Centrality
that such monitoring and review — including, where appropriate, administrative, organizational and technical measures — specifically ensures such personal data and information, processing, and administration are conducted in a manner that maintains the centrality and unity as well as independence and integrity of Publiks, including the Founder, as provided for in the Codes and Policies.
11.43.3. Standardization, Commensurability
that there is a commensurability and conflict resolution process providing a common basis and rubric for adjudicating data and information policies, principles, or protections that seem in competition, conflict, or tension, or incommensurable, when they are not.
11.43.3.1. Standardization, Commensurability, Agreement
that such commensurability and conflict resolution process have as its starting point confirmation of a legally binding agreement on the part of every person concerned to Publiks Conduct and Service Agreement, as provided for in the Codes and Policies, especially the Conditions of Founding and the Conditions of Governance, and where discovered, any inadequacies are prioritized and remedied, with binding Agreement being determinative.
11.43.3.2. Standardization, Commensurability, Applicability
that, as a subsequent step, there is confirmation of an understanding among all persons concerned that the applicability of such process is limited to conduct or service narrowly subject to the Data and Information Policy — and does not entail other claims, matters, properties, remedies, or rights, and where discovered, any inadequacies are prioritized and remedied, with narrow applicability being determinative.
11.43.3.3. Standardization, Commensurability, Authorization
that, as a subsequent step, there is confirmation that every aspect of such process — including the conduct or service, the data and information, or their processing under review — have and maintain the Founder’s authorization and be conducted under the Founder’s administration, with the Founder’s decision and discretion being determinative.
11.43.3.4. Standardization, Commensurability, Communication
that, as a subsequent step, there is confirmation that there is informing communication and notification regarding every aspect of such process — including the conduct or service, the data and information, or their processing under review — to and from all persons concerned, and where discovered, any inadequacies are prioritized and remedied to the most feasible and reasonable extent.
11.43.3.5. Standardization, Commensurability, Confidentiality, Privacy
that, as a subsequent step, there is confirmation that every aspect of such process — including the conduct or service, the data and information, or their processing under review — has maintained and protected confidentiality and privacy with respect to all persons concerned, and where discovered, any inadequacies are prioritized and remedied to the most feasible and reasonable extent, with absolute or adequate confidentiality and privacy being determinative.
11.43.3.6. Standardization, Commensurability, Consent
that, as a subsequent step, there is confirmation that every aspect of such process — including the conduct or service, the data and information, or their processing under review — has obtained and maintained informed consent (or assent) by all persons concerned, and where discovered, any inadequacies are prioritized and remedied to the most feasible and reasonable extent, with meaningful consent being determinative.
11.43.3.7. Standardization, Commensurability, Harm
that, as a subsequent step, there is confirmation that every aspect of such process — including the conduct or service, the data and information, or their processing under review — has not effected or facilitated imminent harm or injury, of physical or psychological nature, to any of the persons concerned, and where discovered, any instances are prioritized and remedied to the most feasible and reasonable extent, with possibility or presence of imminent harm being determinative.
11.43.3.8. Standardization, Commensurability, Infringement
that, as a subsequent step, there is confirmation that every aspect of such process — including the conduct or service under review — has not effected or facilitated an infringement of the data and information, their processing, or their protections, with respect to any of the persons concerned, and where discovered, any inadequacies are prioritized and remedied to the most feasible and reasonable extent, with integrity and protection of the data and information and their processing being determinative.
11.43.3.9. Standardization, Commensurability, Infringement, Intentional
that, as a subsequent step, there is confirmation that every aspect of such process — including the conduct or service, the data and information, or their processing under review — has not effected or facilitated an intentional infringement of the Data and Information Policy, the Codes and Policies, or applicable law or regulation, with respect to any of the persons concerned, and where discovered, any inadequacies are prioritized and remedied to the most feasible and reasonable extent, with intent as well as infringement being determinative.
11.43.3.10. Standardization, Commensurability, Infringement, Unintentional
that, as a subsequent step, there is confirmation that every aspect of such process — including the conduct or service, the data and information, or their processing under review — has not effected or facilitated an unintentional infringement of the Data and Information Policy, the Codes and Policies, or applicable law or regulation, with respect to any of the persons concerned, and where discovered, any inadequacies are prioritized and remedied to the most feasible and reasonable extent, with mishandling, mistake, or misunderstanding as well as infringement being determinative.
11.43.3.11. Standardization, Commensurability, Property
that, as a subsequent step, there is confirmation that every aspect of such process — including the conduct or service, the data and information, or their processing under review — has not effected or facilitated an infringement or violation of property or proprietariness with respect to any of the persons concerned, and where discovered, any inadequacies are prioritized and remedied to the most feasible and reasonable extent, with respected property attendant to data and information being determinative.
11.43.3.12. Standardization, Commensurability, Rights
that, as a subsequent step, there is confirmation that every aspect of such process — including the conduct or service, the data and information, or their processing under review — has not effected or facilitated an infringement or violation of civil liberties or rights with respect to any of the persons concerned, and where discovered, any inadequacies are prioritized and remedied to the most feasible and reasonable extent, with respected rights attendant to data and information being determinative.
11.43.3.13. Standardization, Commensurability, Resolution Order
that, where inadequacies are discovered, remedying them involves prioritized attention to historical order of occurrence in combination with the aforementioned stepwise sequence of review, with, to the most feasible and reasonable extent, application of the “fruit of the poisonous tree” concept and depositing of any involved material or property, as well as any benefits accrued via such inadequacies, with Publiks and the Founder, Alvan Azinna Chibuzo Ikoku, for resolution via adjudicating decision at his absolute, complete and sole discretion.
11.43.4. Standardization, Compliance
that there is a compliance process — including, where appropriate, administrative, organizational and technical measures — specifically ensuring such personal data and information, processing, and administration are conducted in a manner that adheres to and fulfills policies, principles, and protections as delineated in the DRB approval and provided for in the Data and Information Policy, the Codes and Polices, and applicable law and regulation.
11.43.5. Standardization, Coordinated Harmonization
that there is a coordination and harmonization process specifically ensuring such personal data and information, processing, and administration are optimally adequate, appropriate, efficacious and protective — across activities, areas, and systems — including, where appropriate, assessing, evaluating, testing, and updating administrative, organizational and technical measures and processes so that they meet best practices standards to the most feasible and reasonable extent.
D — On Protections
For Specific Persons
— For Entity
Section 11.44.0. With respect to data and information protections for Publiks as an entity, you understand and agree to abide by the following:
11.44.1. Protections, Entity
that Publiks holds protecting data and information for Publiks Inc and The Publiks Group as organizations to be a basic purpose and right of their establishment and existence as entities, thus of high importance;
11.44.2. Protections, Entity, Administration
that Publiks holds protecting such organizational data and information to be important to its formation, governance, and overall administration;
11.44.3. Protections, Entity, Areas
that Publiks holds protecting such organizational data and information to include that of its official areas, offices, parts, properties, sections, and equivalent, as well as any involved act, activity, agent, arrangement, asset, or material or matter;
11.44.4. Protections, Entity, Conduct, Service
that Publiks holds protecting such organizational data and information to include that of its official conduct and service, as well as any involved act, activity, agent, arrangement, asset, or material or matter;
11.44.5. Protections, Entity, Mission
that Publiks holds protecting such organizational data and information to be important to the fulfillment of its mission and purposes, and so enforces and fulfills attendant policies, principles, requirements, and rights to the fullest extent possible;
11.44.6. Protections, Entity, Non-Infringement
that you maintain and not infringe, in any way, such organizational data and information, as provided for in the Codes and Policies and applicable law and regulation;
11.44.7. Protections, Entity, Understanding
with the understanding that your primary means of maintaining such organizational data and information is to refrain from and report — via fully informing communication directly to the Founder — any actual, anticipated or apparent infringement of the Codes and Policies or applicable law or regulation.
— For Founder
Section 11.45.0. With respect to data and information protections for the Founder of Publiks, Alvan Azinna Chibuzo Ikoku, you understand and agree to abide by the following:
11.45.1. Protections, Founder
that Publiks holds protecting data and information for the Founder to be a basic purpose and right of its establishment and existence as an entity, thus of high importance;
11.45.2. Protections, Founder, Administration
that Publiks holds protecting such Founder data and information to be important to its formation, governance, and overall administration;
11.45.3. Protections, Founder, Areas
that Publiks holds protecting such Founder data and information to include the Founder’s official areas, offices, parts, properties, sections, and equivalent, as well as any involved act, activity, agent, arrangement, asset, material or matter;
11.45.4. Protections, Founder, Conduct, Service
that Publiks holds protecting such Founder data and information to include the Founder’s official conduct and service, as well as any involved act, activity, agent, arrangement, asset, material or matter;
11.45.5. Protections, Founder, Mission
that Publiks holds protecting such Founder data and information to be important to the fulfillment of its mission and purposes, and so enforces and fulfills attendant policies, principles, requirements, and rights to the fullest extent possible;
11.45.6. Protections, Founder, Non-Infringement
that you maintain and not infringe, in any way, such Founder data and information, as provided for in the Codes and Policies and applicable law and regulation;
11.45.7. Protections, Founder, Understanding
with the understanding that your primary means of maintaining such Founder data and information is to refrain from and report — via fully informing communication directly to the Founder — any actual, anticipated or apparent infringement of the Codes and Policies or applicable law or regulation.
— For Humans
Section 11.46.0. With respect to data and information protections for human beings, as individuals, you understand and agree to abide by the following:
11.46.1. Protections, Humans
that Publiks holds protecting data and information for humans, as individuals, at Publiks to be a basic purpose and right of its establishment and existence as an entity, thus of high importance;
11.46.2. Protections, Humans, Administration
that Publiks holds protecting such human data and information to be important to its formation, governance, and overall administration;
11.46.3. Protections, Humans, Areas
that Publiks holds protecting such human data and information to include individual-related areas, offices, parts, properties, sections, and equivalent, as well as any involved act, activity, agent, arrangement, asset, material or matter;
11.46.4. Protections, Humans, Being
that Publiks holds protecting such human data and information to include that pertaining to an individual’s inner being, body, and brain, as well as inner self, soul, and spirit;
11.46.5. Protections, Humans, Conduct, Service
that Publiks holds protecting such human data and information to include individual-related conduct and service, as well as any involved act, activity, agent, arrangement, asset, material or matter;
11.46.6. Protections, Humans, Mission
that Publiks holds protecting such human data and information to be important to the fulfillment of its mission and purposes, and so enforces and fulfills attendant policies, principles, requirements, and rights to the fullest extent possible;
11.46.7. Protections, Humans, Non-Infringement
that you maintain and not infringe, in any way, such human data and information, as provided for in the Codes and Policies and applicable law and regulation;
11.46.8. Protections, Humans, Understanding
with the understanding that your primary means of maintaining such human data and information is to refrain from and report — via fully informing communication directly to the Founder — any actual, anticipated or apparent infringement of the Codes and Policies or applicable law or regulation.
From Risks, Threats
— From Specific Risks
Section 11.47.0. With respect to protections of data and information from specific risks and threats, you understand and agree to abide by the following:
11.47.1. Protections, Cooptation
that Publiks protects itself and the Founder, as first priorities, then where reasonable, other natural persons from specifically relevant risks and threats to data and information resulting from attempts to coopt, takeover, or otherwise usurp the Founder’s administration, management, operation, ownership, or equivalent of Publiks, including attempts that are collectivist, communal, communist, cooperative, governmental, judicial, regulatory, socialist or statist, as provided for in the Codes and Policies and applicable law and regulation;
11.47.2. Protections, Disclosure
that Publiks protects itself and the Founder, as first priorities, then where reasonable, other natural persons from specifically relevant risks and threats to data and information resulting from infringing access, communication, data and information, disclosure, exposure, identification, leak, publicity, transparency, or equivalent, as provided for in the Codes and Policies and applicable law and regulation;
11.47.3. Protections, Non-Consent
that Publiks protects itself and the Founder, as first priorities, then where reasonable, other natural persons from specifically relevant risks and threats to data and information resulting from inadequacy, insufficiency, or other infringement of consent, as provided for in the Codes and Policies and applicable law and regulation;
11.47.4. Protections, Non-Provision
that Publiks protects itself and the Founder, as first priorities, then where reasonable, other natural persons from specifically relevant risks and threats to data and information resulting from non-provision of required and standard data and information administration, measure, practice, procedure, or equivalent, as provided for in the Codes and Policies and applicable law and regulation;
11.47.5. Protections, Understanding
with the understanding that the aforementioned determinations of specifically relevant risks and threats, and protections against them, are to be made solely by the Founder and executed solely via the Founder’s authorization.
— From Standard Risks
Section 11.48.0. With respect to protections of data and information from standard risks and threats, you understand and agree to abide by the following:
11.48.1. Protections, Incompatibility
that Publiks protects itself and the Founder, as first priorities, then where reasonable, other natural persons from standard risks and threats to data and information resulting from any incompatibility relating to Publiks, as provided for in the Codes and Policies;
11.48.2. Protections, Inconsistency
that Publiks protects itself and the Founder, as first priorities, then where reasonable, other natural persons from standard risks and threats to data and information resulting from any inconsistency relating to Publiks, as provided for in the Codes and Policies;
11.48.3. Protections, Infringement
that Publiks protects itself and the Founder, as first priorities, then where reasonable, other natural persons from standard risks and threats to data and information resulting from any infringement relating to Publiks, as provided for in the Codes and Policies;
11.48.4. Protections, Insecurity
that Publiks protects itself and the Founder, as first priorities, then where reasonable, other natural persons from standard risks and threats to data and information resulting from any insecurity relating to Publiks, as provided for in the Codes and Policies;
11.48.5. Protections, Interference
that Publiks protects itself and the Founder, as first priorities, then where reasonable, other natural persons from standard risks and threats to data and information resulting from any interference relating to Publiks, as provided for in the Codes and Policies;
11.48.6. Protections, Intrusion
that Publiks protects itself and the Founder, as first priorities, then where reasonable, other natural persons from standard risks and threats to data and information resulting from any intrusion relating to Publiks, as provided for in the Codes and Policies;
11.48.7. Protections, Invalidation
that Publiks protects itself and the Founder, as first priorities, then where reasonable, other natural persons from standard risks and threats to data and information resulting from any effective invalidation relating to Publiks, as provided for in the Codes and Policies;
11.48.8. Protections, Understanding
with the understanding that the aforementioned determinations of standard risks and threats, and protections against them, are to be made solely by the Founder and executed solely via the Founder’s authorization.
Policies
Provision
As stated earlier, the governance of Publiks Inc and The Publiks Group is, in important part, conducted via the Codes and Policies below:
Publiks Group Agreement
The Publiks Conduct and Service Agreement, which
Collectively Governing
consists of several Codes and Policies that collectively govern all conduct and service in any way relating to Publiks Inc and The Publiks Group.
Collectively Including
collectively include the Basic Policies — the Conditions and Terms of Founding, the Conditions and Terms of Governance, the Conditions and Terms of Conduct and Service, and the Founding and Governing Code of Ethics — as well as all other codes and policies, associated as the Correlative Policies.
Available Below
are made available further below.
Conditions of Founding
Conditions and Terms of Founding of Publiks (HTML)
Conditions of Governance
Conditions and Terms of Governance of Publiks (HTML)
Conditions of Service
Conditions and Terms of Conduct and Service (HTML)
Founding Ethics
Founding and Governing Code of Ethics (HTML)
All Policies
All Policies (HTML)
Conclusion
— Collectively, the Policy
— All of the aforementioned in this section constitutes the Policy on Data and Information of Publiks Inc and The Publiks Group (the “Data and Information Policy”) and forms an integral part of the Codes and Policies of Publiks Inc and The Publiks Group as well as the Publiks Conduct and Service Agreement you may enter into with Publiks Inc and The Publiks Group.
— Concerns and Questions
— Please report any concerns about code or policy violations, and send any questions you may have regarding the Policy on Data and Information or the Publiks Conduct and Service Agreement, to policies@publiks.org.
— Concluding
— And as a concluding aviso and proviso, you are informed as well as reminded that by commencing or continuing any conduct or service relating to Publiks Inc or The Publiks Group — in any way, either directly or indirectly, and via any manner, means, method, or mode — you enter into the Publiks Conduct and Service Agreement and agree to abide by and be legally bound by the Policy conditions, principles, protections, and terms described above, and the Codes and Policies, in their entirety without modification or severability, as amended from time to time solely by the Founder.
Also at the Division
Publiks Inc and its partner, The Ikoku Group, are dedicated to developing, providing and safekeeping ideas and solutions — with the mission to foster care and creativity, culture and communities, ethics and innovation in lives and societies. And so in accordance with the above, The Ikoku Group and Publiks provide the following:
I.
A Company of Care and Community
A company and divisions committed to developing and ultimately providing ideas, practices, and products fostering care and community — for the benefit and service of people coexisting in local and global communities.
II.
A Company of Culture and Creativity
A company and divisions committed to developing and ultimately providing ideas, practices, and products fostering culture and creativity — for the benefit and enjoyment of people engaging in and with local and global communities.
III.
A Company of Ethics and Innovation
A company and divisions committed to developing and ultimately providing innovation that abides by ethics principles and protections — for the benefit and humane use of people employing our solutions for local and global concerns.