Intrusion Upon Seclusion / Invasion of Privacy  (On behalf of Plaintiff and All Class Members against Defendant PaperlessPay and   on behalf of Plaintiff and all PHM Subclass Members against Defendant PHM)  Plaintiff repeats and re-alleges each and every allegation contained in all  Paragraphs above as if fully set forth herein.  The Restatement (Second) of Torts states:   One who intentionally intrudes, physically or otherwise, upon the solitude  or seclusion of another or her private affairs or concerns, is subject to  liability to the other for invasion of her privacy, if the intrusion would be  highly offensive to a reasonable person.  Restatement (Second) of Torts § 652B (1977)  Plaintiff and Class Members had a reasonable expectation of privacy in the  PII Defendants mishandled. In failing to protect Plaintiff’s and Class Members’ PII, and in  intentionally misusing and/or disclosing their PII, Defendants acted with intentional malice and  oppression and in conscious disregard of Plaintiff’s and Class Members’ rights to have such  information kept confidential and private.  Plaintiff, therefore, seeks an award of damages on  behalf of herself and the Class.  Negligence  (On behalf of Plaintiff and all Class Members against Defendant PaperlessPay)  Plaintiff re-alleges and incorporates by reference all Paragraphs above as if  fully set forth herein.  Plaintiff and Class Members were required to submit  PII in order to obtain  employment or as a condition of their employment.  By collecting and storing this data in PaperlessPay’s computer property,  PaperlessPay had a duty of care to use reasonable means to secure and safeguard its computer  property—and Class Members’ PII held within it—to prevent disclosure of the information, and  to safeguard the information from theft.  Defendant PaperlessPay’s  duty included a responsibility  to implement processes by which it could detect a breach of their security systems in a reasonably  expeditious period of time and to give prompt notice to those affected in the case of a data breach.  Defendant PaperlessPay owed a duty of care to Plaintiff and Class Members  to provide data security consistent with industry standards and other requirements discussed  herein, and to ensure that their systems and networks, and the personnel responsible for them,  adequately protected the PII.  Defendant PaperlessPay’s had duty of care to use reasonable security  measures because it was in a position to ensure that its systems were sufficient to protect against  the foreseeable risk of harm to Class Members from a data breach.  Defendant PaperlessPay’s duty to use reasonable care in protecting  confidential data also arose also because it is bound by industry standards to protect confidential 