definiens: ( or similar terms such as as defined by applicable Laws ), medic al records, or other records generated in the cours e of providing or paying for health care services ( colle ctively, and such Laws, coll ectively, ) ; and ( iv ) has established, implemen ted, updated, and maintained, and has utilized comm ercially reasonable efforts to enforce, such policies, progr ams, procedures, Contracts and systems with respect to the collection, compilation, use, storage, processing, sharing, safeguarding, disposal, destruction, discl osure or transfer, and other forms of processing of any and all Personal Information ( collectively, ), as are necessary to protect, physically and electronic ally, information and assets from unauthorized disc losure, access, use, dissemination or modification, and as are otherwise necessary to comply with HIPAA and ot her Privacy Laws . Since [ * * * ], there have been no inves tigations by or, to the Company ’s Knowledge, compla ints to, the Office for Civil Rights of the U.S. Department of Health and Human Services with respect to HIPAA compliance by the Company or, to the Company ’s Know ledge, its business associates or subcontractors . T o the Company ’s Knowledge, since [ * * * ], the Company has n ot experienced any : ( A ) breach of security, as defi ned by the Privacy Laws, or other unauthorized access or u se of any of the Company Business Systems with resp ect to Personal Identifiable Information ; ( B ) of as such t erms are defined by HIPAA ; ( C ) as defin ed by HIPAA, except for any Security Incident that has not resulted in, and would not reasonably be expected t o result in, material liability to the Company ; ( D ) other actual breach, misappropriation, or unauthorized disclosur e, access, use, dissemination or modification of an y Personal Information ; or ( E ) breach or violation of any Priv acy Policies except as has not resulted in, and wou ld not reasonably be expected to result in, material liabi lity to the Company . The Company is not a party to or the subject of any pending or, to the Company ’s Knowledge, thre atened, Legal Proceeding involving or relating to a claim against the Company of any breach, misappropriation, unauthorized disclosure, access, use, disseminati on, modification or any similar violation or infringeme nt of Personal Information . To the Company ’s Knowle dge, the transactions contemplated by this Agreement will no t result in any liabilities in connection with any Data Security Requirements