definiens: means a written info rmation security program that complies with Data Protection Requirements, that is consistent wi th industry best practices at least as stringent as one or more relevant industry standards and that includes : ( i ) policies and procedures regarding Personal Data, an d the Processing thereof ; ( ii ) administrative, technical and physical safeguards that are consistent with in dustry best practices and designed to protect the security, con fidentiality, and integrity of any Personal Data ow ned, controlled, maintained, held, or Processed by the G roup Companies or any third party operating on beha lf of or at the direction of the Group Companies ; ( iii ) disa ster recovery, business continuity, incident respon se, data retention and deletion, and security plans, procedu res and facilities and ( iv ) protections against Dat a Breaches, Malicious Code, and against loss, misuse or unautho rized access to and Processing of Company Data, the Information Technology Systems and the systems of a ny third party service providers that Process Compa ny Data or access the Information Technology Systems