malware and other corruptants, in each case, except as would not reasonably be expected to, individually or in the aggregate, have a Material Adverse Effect. The Company and its subsidiaries have implemented and maintained commercially reasonable controls, policies, procedures and safeguards, designed to maintain and protect the operation, redundancy and security of all IT Systems, and there have been no compromises, malfunctions, failures, breaches, misuses, destructions, losses, disablements, outages, or unauthorized uses, modifications or disclosures of, or accesses to, the same; in each case, except as would not reasonably be expected to, individually or in the aggregate, have a Material Adverse Effect.
(gg) Data Protection. With regard to the Companys and its subsidiaries receipt, collection, handling, processing, sharing, transfer, usage, import, export, disclosure, interception, storage and disposal of any and all personal, personally identifiable, or other similar regulated data (collectively, Personal Data), (i) the Company and its subsidiaries currently comply with, and have implemented commercially reasonable policies and procedures designed to ensure compliance with, all applicable laws, statutes, regulations, rules, judgments, orders, internal and external policies and binding contractual obligations relating to the foregoing actions in respect of Personal Data (including, to the extent applicable, the California Consumer Privacy Act and the European Union General Data Protection Regulation) (collectively, Privacy Legal Obligations); (ii) the Company and its subsidiaries require all third parties to which they provide any Personal Data to maintain the privacy and security of such Personal Data and to comply with applicable Privacy Legal Obligations, including by contractually requiring such third parties to protect such Personal Data from unauthorized access, use and/or disclosure; (iii) the Company and its subsidiaries maintain reasonable data security policies and procedures designed to protect the confidentiality and security of Personal Data and to prevent unauthorized use of and access to Personal Data; (iv) except as described in the Registration Statement, the Pricing Disclosure Package and the Prospectus, to the knowledge of the Company, there has been no unauthorized access to, or use or disclosure of, any Personal Data (or other information or data) collected, maintained, handled, stored, transferred, used, disclosed or otherwise processed by or for the Company or any of its subsidiaries, including any that have resulted in any obligation to notify any third parties; (v) neither the Company nor any of its subsidiaries have received in writing any notification of or complaint regarding non-compliance with any Privacy Legal Obligation; and (vi) there is no pending, or to the Companys knowledge, threatened action, suit, investigation, proceeding or claim by or before any court or governmental agency, authority or body alleging non-compliance by the Company or any of its subsidiaries with any Privacy Legal Obligation; except, in the case of clauses (i) through (vi), as would not reasonably be expected to, individually or in the aggregate, have a Material Adverse Effect.
(hh) No Unlawful Payments. Neither the Company nor any of its subsidiaries or affiliates, nor any director, officer or employee thereof nor, to the knowledge of the Company, any agent, affiliate or other person associated with or acting on behalf of the Company or any of its subsidiaries has (i) used any corporate funds for any unlawful contribution, gift, entertainment or other unlawful expense relating to political activity; (ii) made or taken an act in furtherance of an offer, promise or authorization of any direct or indirect unlawful payment or benefit to any foreign or domestic government official or employee, including of any government-owned or controlled entity or of a public international organization, or any person acting in an official capacity for or on behalf of any of the foregoing, or any political party or party official or candidate for political office; (iii) violated or is in violation of any provision of the Foreign Corrupt Practices Act of 1977, as amended, or any applicable law or regulation implementing the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, or committed an offence under the Bribery Act 2010 of the United Kingdom or any other applicable anti-bribery or anti-corruption law; or (iv) made, offered, agreed, requested or taken an act in furtherance of any unlawful bribe or other unlawful benefit, including, without limitation, any rebate, payoff, influence payment, kickback or other unlawful or improper payment or benefit. The Company and its subsidiaries have instituted, maintain and enforce, and will continue to maintain and enforce policies and procedures designed to promote and ensure compliance with all applicable anti-bribery and anti-corruption laws. Neither the Company nor any of its subsidiaries will use, directly or indirectly, the proceeds of the offering in furtherance of an offer, payment, promise to pay, or authorization of the payment or giving of money, or anything else of value, to any person in violation of any applicable anti-bribery or anti-corruption laws.