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Document ID: POL-PRIV-2026-V4.1

1. Introduction and Scope

This Privacy Protocol outlines how Nexia Systems B.V. ("Nexia", "we", "our", or "us") collects, utilizes, and protects data during the authentication process. By accessing the Identity Gateway, you acknowledge that you are entering a secure, monitored environment governed by this policy.

2. Data Collection and Telemetry

To ensure Zero-Trust compliance and defend against unauthorized access, we automatically collect specific telemetry data during your authentication session. This includes, but is not limited to:

• IP Addresses and network routing paths.
• Device posture information (OS version, browser signature, hardware security module status).
• Cryptographic hashes of successful and failed authentication attempts.
• Geolocation data derived from network points of presence.

3. Legal Basis for Processing (GDPR)

Under the General Data Protection Regulation (EU 2016/679), our legal basis for processing this telemetry data is the Legitimate Interest (Art. 6(1)(f) GDPR) of Nexia Systems to maintain network security, prevent fraud, and fulfill our contractual obligations as a Data Processor for our enterprise clients.

4. Security Measures and Certifications

Nexia Systems employs military-grade encryption protocols. All data in transit is secured using TLS 1.3. Data at rest is encrypted using AES-256 block ciphers. Our infrastructure undergoes continuous penetration testing and maintains the following certifications:

• ISO/IEC 27001:2022 (Information Security Management)
• SOC 2 Type II (Security, Availability, and Confidentiality)
• FIPS 140-2 Level 3 (Hardware Security Modules)

5. Data Retention Policy

Authentication logs and session telemetry are stored in a rolling 90-day retention window to facilitate security audits and forensic investigations. After 90 days, data is permanently obfuscated or destroyed, unless required for active legal or security investigations.

6. Cookie Usage (Strictly Necessary)

We do not deploy marketing, advertising, or third-party tracking cookies on the Identity Gateway. We exclusively use Strictly Necessary Cookies required for load balancing, session persistence, and Cross-Site Request Forgery (CSRF) protection. Because these are essential for the technical operation of the service, explicit consent is not required under the ePrivacy Directive.

7. User Rights

Authorized personnel may request access to, or the deletion of, their personal data by submitting a formal request to the Data Protection Officer (DPO) at dpo@nexia-systems.nl. Note that deletion requests may result in the immediate revocation of network access.

Document ID: POL-TOS-2026-V2.8

1. Acceptance of Terms

By interacting with the Nexia Systems Identity Gateway, you enter into a legally binding agreement with Nexia Systems B.V. If you are not an authorized employee, verified contractor, or registered partner, you must disconnect immediately.

2. Authorized Use Only

This system, including all related equipment, networks, and network devices, is provided only for authorized corporate use. Nexia Systems may monitor, record, and audit all usage of this system. Therefore, users should have no explicit expectation of privacy concerning their activities on this gateway.

3. Prohibited Activities

You are strictly prohibited from engaging in any of the following activities:

• Attempting to bypass, disable, or defeat any security or authentication mechanism.
• Conducting unauthorized vulnerability scanning, penetration testing, or port scanning.
• Executing automated credential stuffing or brute-force attacks.
• Reverse-engineering the authentication protocols or API endpoints.

Violation of these terms will result in immediate termination of access and may subject you to civil liability and criminal prosecution under the Dutch Computer Crime Act (Wet computercriminaliteit III).

4. Multi-Factor Authentication (MFA)

Access to the internal network requires cryptographic validation. You are responsible for safeguarding your FIDO2 security keys, authenticator applications, and passwords. Sharing credentials is a direct violation of the Information Security Policy.

5. Limitation of Liability

To the maximum extent permitted by applicable law, Nexia Systems B.V. shall not be liable for any indirect, incidental, special, consequential, or punitive damages, including loss of profits, data, or goodwill, arising from your use or inability to use the authentication gateway.

6. Governing Law and Jurisdiction

These Terms of Access shall be governed by and construed in accordance with the laws of the Netherlands. Any disputes arising out of or in connection with these terms shall be subject to the exclusive jurisdiction of the competent courts in Amsterdam, the Netherlands.

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