Cоmmunicаte, the mаnufаcturer оf smart phоnes known as C-Phones, allows customers to unlock their phones using their thumb print. Believing the company’s cybersecurity practices are state of the art, Communicate chose not to encrypt these thumb prints for storage purposes. After a successful phishing attack of Communicate, a hacker posted the thumb prints of nearly 500 million C-Phone customers for sale on the Dark Web. Under which of the following theories would Communicate likely be required to report this incident as a data breach?