NIEP Privacy Policy

NIEP is an enterprise email security product provided to organizational customers by Neusoft Corporation (referred to as "we," "us," or "our"). We value user privacy and information security. This Privacy Policy (the "Policy") explains to users of NIEP ("you" or "your") how NIEP accesses, uses, stores, shares, protects, retains, and deletes information when connecting to and protecting enterprise mailboxes.
This Policy should be read together with any license agreement, service agreement, data processing agreement, or other commercial agreement entered into between an organizational customer and Neusoft Corporation. If a validly executed agreement contains more specific or stringent provisions concerning the processing and protection of personal information, those provisions will apply. No contractual provision affects any personal information protection rights available to users under applicable law.

This Policy applies to information processing activities arising when organizational customers and their authorized users use NIEP products or services, including when NIEP connects to an email service selected by an organizational customer or to a self-hosted email system and provides email sending, receiving, synchronization, security detection, and administration functions. Provisions specifically concerning Google Accounts, Gmail, or Google Workspace apply only when the relevant connection function is enabled.
We make the personal information processing rules applicable to NIEP available at https://neteye.neusoft.com/jp, where you may review this Policy. If you do not agree to this Policy, do not use or access our products or services.
The data processing activities of enterprise email service providers are outside our control. Please review the applicable provider's privacy policy to understand how it collects and processes your personal information.
For enterprise mailbox data whose purposes and means of processing are determined by the organizational customer and that is stored in a customer-controlled NIEP deployment environment, the organizational customer is generally the relevant data controller or personal information handler, as applicable. Neusoft Corporation provides the product or service in accordance with the organizational customer's lawful configurations and instructions. The organizational customer is responsible for informing its authorized users about the NIEP product or service and the related processing of personal information and, where required by applicable law or Google policies, obtaining the necessary authorization or consent.

On the basis of performing customer contracts and other grounds for processing permitted by applicable data protection laws, and depending on the organizational customer's configuration, your permissions, and the functions you actually enable and use, NIEP may collect, store, and process the following information:

• Account and mailbox identification information, including email address, account identifier, display name, organization, and domain information.
• Email metadata, including sender, recipient, CC recipient, timestamp, subject, email headers, message identifier, folder or label, and transmission status.
• Message bodies, inline content, attachments, URLs, and data required for virus, spam, malicious URL, content security, and email policy detection.
• OAuth authorization information, including access tokens, refresh tokens, authorization status, and scopes. NIEP does not require users to provide their Google passwords to us.
• Product configuration and operational information, including mailbox connection configurations, policy matches, quarantine or disposition results, device or system identifiers, and error and diagnostic information.
• Email security policy information configured by the organizational customer, including recipient allowlists and blocklists, custom spam terms, email samples or features used for custom similar-spam detection, outbound email DLP policies, and the corresponding disposition rules.
• Security and audit logs, including records of sign-in, sign-out, authentication failures, security detection, email operations, configuration changes, administrator operations, authorization changes, policy changes, and security events. These logs may contain user, mailbox, message, and device identifiers; email senders, recipients, and subjects; IP addresses; User-Agent information; operation type, result, and time; necessary security detection results; and error information.
• Cookies, browser session storage, local storage, and Agent local configuration information, including sign-in tokens, language, tenant selection, interface preferences, device identifiers, device names, operating system categories, application versions, IP addresses, and User-Agent information.
• Customer support information, including contact details, issue descriptions, screenshots, logs, and other necessary materials voluntarily provided by an organizational customer or user when making an inquiry, troubleshooting an issue, or requesting service. Please do not provide email content or personal information unrelated to the support matter.

To provide sign-in authentication, session maintenance, language and interface preferences, device binding, connection management, and security auditing, NIEP may use cookies, browser session storage, local storage, or Agent local configurations to process sign-in tokens, language, tenant selection, and interface preferences, as well as information such as device identifiers, device names, operating system categories, application versions, IP addresses, and User-Agent information. Information such as browser type, window dimensions, or pixel density may be used locally only to adapt the interface.
This information may be transmitted to the customer-controlled NIEP deployment environment and to CloudRelay, license verification, or other relevant services necessary to provide enabled functions. We do not use this information for advertising or cross-service tracking. Specific sharing and recipients are addressed in the section of this Policy titled "Storage, Sharing, and Processing Locations."
When a user accesses the Google OAuth authorization page, Google may process cookies, IP addresses, User-Agent information, and other browser information in accordance with its own privacy policy. Cookies used on the Google authorization page are not set or controlled by NIEP.

NIEP obtains access to a mailbox only after a user lawfully authorized to act with respect to that mailbox completes authorization through Google OAuth 2.0. The organizational customer is responsible for managing NIEP permissions and ensuring that the connection and use of the mailbox have been properly authorized. For a shared mailbox, a person authorized to grant access to that mailbox completes Google authorization, after which the organizational customer configures shared-member permissions within NIEP.
NIEP requests the Gmail scope https://mail.google.com/. This is a Google Restricted Scope used by NIEP to connect to Gmail through OAuth 2.0 and the standard IMAP and SMTP protocols to provide email receiving, synchronization, sending, and enterprise email security functions. NIEP does not access email data through the Gmail API.
This scope permits NIEP to read, compose, send, and delete Gmail messages. NIEP uses the scope only to the extent necessary to provide the email services, security detection, customer policy enforcement, and user-requested email operations enabled by the organizational customer or authorized user. It is not used for undisclosed purposes.
When a user deletes a message from a regular mailbox through NIEP, the message is moved to Gmail Trash. A message quarantined or rejected under an organizational customer's security policy may be permanently deleted from the Gmail server without being moved to Gmail Trash and retained in NIEP's quarantine or rejected folder. If an authorized user or administrator later deletes that message in NIEP, the corresponding email data is permanently deleted from NIEP.

1. Establishing and maintaining mailbox connections: processing account and mailbox identification information, OAuth authorization information, and the mailbox connection configurations and other necessary operational information contained in product configuration and operational information.
2. Receiving, sending, and synchronizing email: processing account and mailbox identification information, email metadata, message bodies, inline content, attachments, and OAuth authorization information. Email metadata includes the transmission status necessary to complete these operations.
3. Performing email security detection and enforcing customer policies: processing email metadata, message bodies, inline content, attachments, URLs, and email security policy information configured by the organizational customer, including recipient allowlists and blocklists, custom spam terms, email samples or features used for custom similar-spam detection, outbound email DLP policies, and corresponding disposition rules; and recording policy matches and allow, block, quarantine, reject, approval, notification, or alert results in product configuration and operational information and security and audit logs. Outbound email DLP processes senders, recipients, subjects, message bodies, and attachments to identify sensitive information defined by the organizational customer and apply approval or notification-only policies. To provide email security functions, NIEP analyzes this information using virus detection, spam detection, malicious URL detection, recipient allowlists and blocklists, custom spam terms, similar-spam detection, outbound email DLP, and other functions in accordance with security policies configured or confirmed by the organizational customer, and applies allow, block, quarantine, reject, notify, or submit-for-approval actions under rules preset by the organizational customer. The organizational customer configures or confirms the relevant rules, thresholds, and dispositions. NIEP does not use these functions to profile individuals or to make employment, credit, lending, or other decisions that produce legal or similarly significant effects on individuals. Authorized users or administrators may review detection results and related dispositions using product functions.
4. Providing security investigation, incident response, auditing, compliance, and organizational administration functions: processing account and mailbox identification information; email metadata, message bodies, inline content, attachments, and URLs relevant to the specific matter; product configuration and operational information; email security policy information configured by the organizational customer; and security and audit logs, including administrator operations, authorization changes, policy changes, and security event records.
5. Protecting NIEP, organizational customers, and users against fraud, abuse, attacks, and other security threats: processing account and mailbox identification information, email metadata, message bodies, inline content, attachments, and URLs relevant to the incident, together with product configuration and operational information and security and audit logs.
6. Providing customer support and maintaining and improving the product: processing product configuration and operational information, including error and diagnostic information, security and audit logs, and necessary customer support information. We do not use message bodies, attachments, OAuth tokens, or other Google user data for this purpose to train or improve generalized, non-personalized, or cross-customer artificial intelligence or machine learning models.
7. Complying with legal obligations and responding to legal requests: processing the minimum information necessary and relevant to the specific matter from among the categories listed in Section 2 of this Policy, to the extent required by applicable law, regulatory requirements, or binding legal process.
8. Conducting internal audits and asserting or defending legal rights: processing, from among the categories listed in Section 2 of this Policy, the minimum account and mailbox identification information, product configuration and operational information, and security and audit logs necessary and relevant to the specific audit or legal matter.
9. Providing sign-in authentication, session maintenance, language and interface preferences, device binding, connection management, and security auditing: processing the cookies, browser session storage, local storage, and Agent local configuration information listed in Section 2, including relevant sign-in tokens, language, tenant selection, interface preferences, and necessary device information.

We will not change the purposes for which personal information is used beyond a scope reasonably related to the purposes disclosed in this Policy. If personal information is to be used for a new purpose that is not reasonably related to the original purpose, we will update this Policy and provide the legally required notice. Where applicable law or Google policies require authorization or consent, we will obtain it before beginning the relevant processing.

We process personal information only to the extent necessary to achieve the purposes described in this Policy and adhere to the principle of data minimization. NIEP's use and transfer of Google user data obtained through Google OAuth authorization will comply with the Google API Services User Data Policy, including the Limited Use requirements. Except as necessary to provide the NIEP functions expressly enabled by the current user and organizational customer, we will not:

• 1. Sell Google user data;
• 2. Use Google user data for advertising, user-profile trading, credit assessment, or lending;
• 3. Use Google user data to develop, train, or improve generalized, non-personalized, or cross-customer artificial intelligence or machine learning models; or
• 4. Use Google user data for any other purpose not disclosed in this Policy.

Human access by Neusoft Corporation personnel to Google user data is limited to the specific circumstances expressly identified in the "Information Security Protection" section of this Policy.

Account and mailbox identification information, email metadata, message bodies, inline content and attachments, OAuth authorization information, email security policy configurations, detection and disposition results, and security and audit logs are generally stored in a customer-controlled NIEP deployment environment and processed in accordance with the organizational customer's configuration. The actual deployment plan and the agreements between the parties determine the specific deployment location, scope of storage, and data boundaries.
CloudRelay provides only encrypted forwarding between the relevant NIEP components and does not retain Gmail message bodies, attachments, or OAuth tokens on a long-term basis. The minimum information transmitted to security detection service providers is handled as described under "Sharing" in this section.

We do not sell user data or use it for advertising, user-profile trading, credit assessment, or lending. Except as expressly disclosed in this Policy or permitted by applicable law, we do not provide your personal information to other companies or organizations.

NIEP is deployed, configured, and managed by organizational customers. An organizational customer and its authorized administrators may access and process account information, email data, policy configurations, disposition results, and audit records stored in NIEP within the permissions configured by that organizational customer. The organizational customer must lawfully determine the purposes and means of processing and provide the necessary notices to authorized users.

When an organizational customer or authorized user connects a mailbox or receives, synchronizes, sends, or manages email, NIEP transmits to the email service provider selected by the organizational customer, or to the customer's self-hosted email system, the information necessary to complete the relevant operation. The email service provider processes the information under its own privacy policy and terms of service.

NIEP sales agents may provide sales, pre-sales and after-sales communications, and requirements forwarding services, but this does not give them access to the customer's NIEP deployment environment or allow them to obtain message content, OAuth tokens, device information, or audit logs through NIEP. Customers and users who voluntarily provide support materials to a sales agent should avoid including unnecessary personal information. We do not provide personal information processed through NIEP to other Neusoft Corporation affiliates merely because of the corporate affiliation.

When an organizational customer enables CloudRelay external connectivity, CloudRelay may process device identifiers, device serial numbers, device names, internal and external IP addresses, connection status, and necessary audit records for device registration, connection authentication, encrypted-tunnel routing, security controls, and troubleshooting. CloudRelay performs only the transient encrypted processing of email data necessary for forwarding and does not retain Gmail message bodies, attachments, or OAuth tokens on a long-term basis.
The NIEP licensing service may process device serial numbers, license identifiers, and verification results to confirm product license status. It does not process message bodies, attachments, or OAuth tokens. CloudRelay and the NIEP licensing service are operated and managed by Neusoft Corporation. This processing is performed by us to provide NIEP products or services and does not constitute provision of personal information to another company.

NIEP performs virus detection on the customer's on-premises NIEP device. The virus detection engine runs locally and updates detection signatures locally; it does not upload message bodies, attachments, or detection samples to the detection engine provider.
To provide spam detection, NIEP may send to a third-party detection engine provider the email features necessary for detection, but it does not send actual message bodies or attachments. To provide malicious URL detection, NIEP may send to a third-party detection engine provider URLs, domain names, IP addresses, hash values, or other minimum detection information contained in an email. The third-party detection engine provider may process this information only for the agreed purposes and in accordance with its contract and applicable law, and may not use it for advertising, sale, user profiling, or any other purpose unrelated to security detection.

We may provide the minimum necessary information to the extent permitted by applicable law in the following circumstances:

• 1. To courts, government agencies, or regulatory authorities as required by laws and regulations, regulatory requirements, court orders, or other binding legal process;
• 2. When necessary to protect an individual's life, body, or property and obtaining the individual's consent is difficult;
• 3. When cooperation is necessary for a national government agency, local public body, or a person entrusted by either to perform duties prescribed by law, and obtaining the individual's consent could impede the performance of those duties;
• 4. To attorneys, accountants, or other professional advisers subject to confidentiality obligations, for auditing, compliance, or asserting or defending legal rights; or
• 5. To an entity that succeeds to the relevant business in connection with a merger, acquisition, reorganization, asset transfer, or bankruptcy liquidation, in accordance with applicable law. The successor must continue to process the relevant information under this Policy or requirements no less protective than this Policy. If applicable law requires renewed consent, we will obtain it.

NIEP is primarily provided to organizational customers in Japan. Under the current standard deployment and service model, the customer-controlled NIEP deployment environment, the CloudRelay and licensing servers operated by Neusoft Corporation, and the relevant data processing by third-party spam and URL detection engines are all located in Japan.
The email service provider selected by an organizational customer may process relevant information outside Japan in accordance with its own infrastructure, privacy policy, and terms of service. Such processing is the responsibility of the email service provider, and users should also review that provider's privacy policy.
If we need to transfer personal information outside Japan in the future, we will provide the notices required by applicable law and, where necessary, obtain consent or implement legally required safeguards.

You have the right under applicable law to ask us to confirm whether we process personal information relating to you and, to the extent provided by applicable law, to request disclosure of or access to the relevant personal information, purposes of processing, categories of information, and recipients or categories of recipients.
For information whose purposes and means of processing are determined by the organizational customer and that is stored in a customer-controlled NIEP deployment environment, you should generally submit your request first to your organizational customer. We will provide necessary assistance in accordance with applicable law, the agreements between the parties, and the organizational customer's lawful instructions.
At the product-access level, the organizational customer is responsible for creating and managing NIEP users, configuring roles, and assigning mailbox access permissions. A regular user may access the user's own mailbox and any shared mailbox expressly assigned to that user by the organizational customer. Shared-mailbox members may view and process message content and attachments in the shared mailbox within the scope of their authorization.
Organization Administrators may view or process managed mailboxes within the organizations or sub-organizations under their administration. Super Administrators may view or process all managed mailboxes. Administrator access must be limited to enterprise email security, incident investigation, compliance, and organizational administration purposes approved by the organizational customer and must comply with least-privilege, authentication, access-control, and auditing requirements.
The organizational customer is responsible for ensuring that shared-mailbox and administrator access has a lawful basis, for providing necessary notice to the relevant users, and for obtaining any authorization or consent required by applicable law.

You have the right under applicable law to request correction of inaccurate personal information relating to you and, in light of the purposes of processing, completion of incomplete information. You or an administrator authorized by the organizational customer may correct information that the NIEP product interface permits you to modify, within your respective permissions. For information stored in a customer-controlled NIEP deployment environment that you cannot modify yourself, you should submit a request to your organizational customer or its administrator.
For information processed under the responsibility of Neusoft Corporation, you may request correction by contacting developer@ncloudsecurity.com. We may require verification of the requester's identity and authority and will handle the request to the extent provided by applicable law.

Where provided by applicable law, you have the right to request suspension of processing or deletion of personal information relating to you. For information controlled by the organizational customer and stored in the customer's NIEP deployment environment, you should generally submit your request first to your organizational customer.
When an authorized user or administrator deletes the relevant Gmail mailbox configuration, the organizational customer deactivates the relevant mailbox, or we receive and verify a valid deletion request, NIEP stops accessing the mailbox, revokes the corresponding Google OAuth authorization, deletes stored access and refresh tokens, and deletes the mailbox database records, email files, attachments, related configurations, and synchronization logs. When a mailbox configuration is deleted, NIEP deletes the primary mailbox data and authorization information, except for security, system, and audit logs that must be retained on a limited basis as described in this Policy.

To the extent provided by applicable law, you may object to our processing of personal information relating to you based on your particular circumstances and request that the processing stop. A request may be limited as permitted by applicable law where processing is necessary to enter into or perform a contract, comply with a legal obligation, or where we can demonstrate other lawful grounds to continue the processing.
A Google Account holder or a person with the relevant administrative authority may revoke NIEP's OAuth authorization through the Google Account permissions page at https://myaccount.google.com/permissions. After authorization is revoked, NIEP will stop accessing the relevant Google mailbox. Revoking Google authorization does not itself delete data already stored by NIEP. To delete the related mailbox configuration, messages, attachments, and tokens, follow the procedure described under "Suspension of Use and Deletion" in this Policy.

You may use the mailbox configuration deletion function provided in NIEP or contact developer@ncloudsecurity.com to request access, correction, suspension of use, deletion, objection to processing, or the exercise of other rights granted by applicable law. For information managed by the organizational customer and stored in a customer-controlled NIEP deployment environment, you should generally submit your request first to your organizational customer or its administrator. We may require verification of the requester's identity, authority, and request details and will process or assist with the request within the scope and time limits provided by applicable law.

We implement administrative, technical, and physical security measures appropriate to the risks, including encryption in transit, encryption at rest where appropriate, OAuth token protection, authentication, access controls, separation of privileges, tenant isolation, security auditing, vulnerability management, employee training and supervision, and security incident response.
Neusoft Corporation personnel generally do not access message content or Google user data stored in a customer-controlled NIEP deployment environment. Authorized personnel may have limited access only where necessary in the following circumstances:

• 1. The organizational customer or user expressly authorizes access for a specific support matter;
• 2. Access is necessary to investigate or address a security incident;
• 3. Access is necessary to comply with applicable law or binding legal process; or
• 4. Another limited circumstance permitted by applicable law and Google policies.

All authorized access is subject to authentication, least privilege, access controls, confidentiality obligations, and audit logging.

If personal information is leaked, lost, damaged, or otherwise involved in a personal information security incident, we will promptly take necessary measures to investigate, contain, remediate, and prevent recurrence and, as required by applicable law, report to the Personal Information Protection Commission or other competent authority and notify affected users or their organizations.

No security measure can guarantee absolute security. We will continue to improve our safeguards and handle security incidents in accordance with applicable law and customer agreements.

A NIEP device deployed in a customer environment is owned and controlled by the organizational customer. The organizational customer determines the retention periods and deletion methods for account information, email data, OAuth authorization information, product configurations, policies, detection and disposition results, and audit records stored on the device, based on business needs, internal rules, customer configuration, the agreements between the parties, and applicable law. NIEP performs retention or deletion in accordance with the organizational customer's configuration, authorized-user operations, and the product's preset data management mechanisms.
When an authorized user or administrator deletes a Gmail mailbox configuration, NIEP stops accessing the relevant mailbox, revokes the corresponding authorization, and deletes the OAuth tokens, messages, attachments, mailbox configuration, and other principal related data stored on that NIEP device in accordance with product functionality.

Device, connection, license, and audit information processed by CloudRelay and licensing services operated by Neusoft Corporation is retained and deleted by Neusoft Corporation for the period necessary to provide the relevant services and in accordance with applicable law.
Information stored locally in a user's browser or Agent is deleted when the session ends, the user signs out, the device is unbound, the configuration is cleared, or the relevant function is no longer required, as implemented in the product.

NIEP records necessary security and operational logs to provide security auditing, troubleshooting, abuse prevention, and accountability. These logs may contain user, mailbox, message, and device identifiers; email senders, recipients, and subjects; IP addresses; User-Agent information; and the time, type, and result of an operation, together with necessary security detection results and error information. We do not use these logs for advertising, user profiling, credit assessment, lending, or training generalized, non-personalized, or cross-customer artificial intelligence or machine learning models.
When an authorized user or administrator deletes a Gmail mailbox configuration, NIEP stops accessing the relevant mailbox, revokes the corresponding Google OAuth authorization, and deletes the OAuth tokens, mailbox database records, email files, attachments, related configurations, and synchronization logs stored in NIEP.
To demonstrate that Google OAuth authorization has been revoked and the mailbox connection has been stopped, and to support necessary security auditing and accountability, NIEP retains limited audit records of the relevant operations for 90 days. A background task runs daily to delete records that exceed the retention period. These audit records are not used to continue accessing the Gmail mailbox.
Other security, system, and operational logs are managed under their respective capacity, rotation, or retention policies and may remain after mailbox deletion until the applicable period expires, but only to the extent necessary for security auditing, troubleshooting, compliance, or accountability. For a NIEP device owned and controlled by a customer, the organizational customer manages the relevant logs under the product configuration, internal rules, and applicable law. For services operated by Neusoft Corporation, the relevant logs are deleted or overwritten when they are no longer needed for the processing purpose or when the applicable retention period expires.

NIEP is an enterprise email security product provided to organizational customers and is not designed or marketed directly to minors.
If an organizational customer designates a minor as a NIEP user, the organizational customer must ensure that the relevant account configuration and information processing have a lawful basis, provide appropriate notice to the minor and the minor's guardian, and obtain guardian consent or implement other necessary safeguards where required by applicable law. NIEP will process the relevant information only in accordance with the organizational customer's lawful configurations and instructions.
If we become aware that relevant information is being processed without the necessary authorization or lawful basis, we will cooperate with the organizational customer to suspend processing, delete the information, or take other necessary measures in accordance with applicable law.

We may update this Policy to reflect changes in product functions, data processing practices, laws and regulations, or compliance requirements, and will identify the latest version and effective date on the public page.
If an update has a material effect on user rights or the processing of personal information, we will provide prominent notice before the change takes effect through the public page, product notifications, email, or another method specified in the customer agreement.
If a change materially expands the scope or purpose of access to, use of, or sharing of Google user data, we will provide the notices required by applicable law and Google policies and, where necessary, obtain renewed authorization or consent.

Policy Publisher and NIEP Service Provider: Neusoft Corporation
Website: https://neteye.neusoft.com/en
Privacy and Developer Contact: developer@ncloudsecurity.com
Contact Address:
Tokyo Fashion Town BLDG. EAST 7F,
3-6-11, Ariake, Koutou-Ku, Tokyo 135-8071, Japan
Tel: +81-03-3570-9322