Privacy Policy

Last modified: 8 July 2026

Data Controller

Drilldown s.r.l. – Viale Isonzo 8, 20135 Milano

Owner’s email address: info@tuduu.it

Types of Data We Collect

Among the Personal Data collected by this Website, independently or through third parties, are:

  • name
  • Last name
  • Company name
  • email
  • Usage data
  • Tracking Tools
  • Number of Users
  • session statistics
  • browsing history
  • click
  • Page view

Full details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or through specific explanatory notices displayed prior to the collection of the Data.

Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically while using this Website.

Unless otherwise specified, all Data requested by this Website are mandatory. If the User refuses to provide them, it may be impossible for this Website to provide the Service. In cases where this Website indicates certain Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or on its operation.

Users who are unsure which Data is mandatory are encouraged to contact the Controller.

The possible use of Cookies — or other tracking tools — by this Website or by the owners of third-party services used by this Website is intended to provide the Service requested by the User, as well as the additional purposes described in this document and in the Cookie Policy.

The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Website.

Methods and place of processing of the collected Data

Processing mode

The Data Controller adopts appropriate security measures designed to prevent unauthorized access, disclosure, alteration, or destruction of Personal Data.

The processing is carried out using IT and/or telematic tools, with organizational methods and logic strictly related to the purposes indicated. In addition to the Controller, in some cases, other parties involved in the organization of this Website may have access to the Data (administrative, commercial, marketing, legal, system administrators) or external parties (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies), also appointed, if necessary, as Data Processors by the Controller. The updated list of Data Processors may always be requested from the Data Controller.

Location

The Data are processed at the Data Controller’s operating offices and in any other place where the parties involved in the processing are located. For further information, contact the Data Controller.

The User's Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information about the place of processing, the User can refer to the section concerning the details of the processing of Personal Data.

Storage period

Unless otherwise specified in this document, Personal Data are processed and stored for the time required by the purpose for which they were collected and may be retained for a longer period due to any legal obligations or on the basis of Users’ consent.

Purpose of the Processing of Collected Data

User Data is collected to enable the Controller to provide the Service, comply with legal obligations, respond to requests or enforcement actions, protect its rights and interests (or those of Users or third parties), detect any malicious or fraudulent activity, as well as for the following purposes:

  • Contact the User
  • Contact management and message sending
  • Statistics
  • User Database Management
  • Tag management
  • Advertising
  • Display of content from external platforms

Personal Data Processing Details

Contact the User

Contact form

By filling out the contact form with their own data, the User authorizes this Website to use this information to respond to requests (such as quotes and any other inquiries).

  • Personal Data processed: surname, Usage Data, email, first name, company name.

Contact management and message sending

This type of service enables the management of a database of email contacts, telephone contacts, or contacts of any other type used to communicate with the User. These services may also allow the collection of data relating to the date and time messages are viewed by the User, as well as the User’s interaction with them, such as information on clicks on links included in the messages.

Brevo email (SendinBlue SAS)

Brevo email is an address management and email sending service provided by SendinBlue SAS.

  • Company: SendinBlue SAS
  • Processing location: France
  • Personal Data processed: Usage data, email, Tracking Tools.
  • Service provided by: SendinBlue SAS (France).

User Database Management

These services allow the Data Controller to build user profiles by starting from an email address, a name, or any other information the User provides to this Website, as well as to track the User's activities through analytics features. This Personal Data may also be cross-referenced with publicly available information about the User (such as social network profiles) and used to build private profiles that the Data Controller can view and use to improve this Website. Some of these services may also allow the scheduled sending of messages to the User, such as emails based on specific actions taken on this Website.

Brevo marketing automation (SendinBlue SAS)

Brevo marketing automation is a User database management service provided by SendinBlue SAS.

  • Company: SendinBlue SAS
  • Place of processing: France
  • Personal Data processed: Usage Data, email, Tracking Tools.
  • Service provided by: SendinBlue SAS (France).

Tag management

This type of service allows the Owner to manage the tags or scripts needed on this Website in a centralized way. As a result, User Data may be processed by these services, with the possibility that they may be retained.

Google Tag Manager (Google Ireland Limited)

Google Tag Manager is a tag management service provided by Google Ireland Limited. To learn about Google's use of Data, consult their partner policy and their Business Data page.

  • Company: Google Ireland Limited
  • Processing location: Ireland
  • Personal Data processed: Usage Data, Tracking Tools.
  • Service provided by: Google Ireland Limited (Ireland).

Advertising

This type of service allows the User Data to be used for commercial communication purposes. These communications are displayed on this Website in the form of banners and other advertising formats, including in relation to the User’s interests. This does not mean that all Personal Data are used for this purpose. Data and terms of use are indicated below.

Some of the services listed below may use Tracking Tools to identify the User, or use behavioral retargeting techniques, i.e. display personalized advertisements based on the User's interests and behavior, or measure ad performance. For more information on this, we suggest checking the privacy policies of the respective services.

Services of this kind usually allow Users to opt out of such tracking. Users can learn how to opt out of interest-based advertising by visiting the relevant opt-out section in this document.

Google Ads conversion tracking (Google Ireland Limited)

Google Ads conversion tracking is a statistics service provided by Google Ireland Limited that links data from the Google Ads advertising network with actions performed within this Website. To learn about Google's use of Data, please consult their partner policy and their Business Data page.

  • Company: Google Ireland Limited
  • Place of processing: Ireland
  • Personal Data processed: Usage Data, Tracking Tools.
  • Service provided by: Google Ireland Limited (Ireland).

Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of the User's behavior.

Google Analytics 4 (Google Ireland Limited)

Google Analytics is a statistics service provided by Google Ireland Limited ("Google"). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Website, compiling reports and sharing them with other services developed by Google. Google may use the Personal Data to contextualize and personalize the ads of its advertising network. In Google Analytics 4, IP addresses are used at the time of collection and then deleted before the data is recorded in any data center or server. To learn more, you can consult Google's official documentation. To understand how Google uses the Data, please consult their partner policy and their Business Data page.

  • Company: Google Ireland Limited
  • Treatment location: Ireland
  • Personal Data processed: Usage Data, number of Users, session statistics, Tracking Tools.
  • Service provided by: Google Ireland Limited (Ireland). An opt-out function is available.

Meta Events Manager (Meta Platforms, Inc.)

Meta Events Manager is a statistical service provided by Meta Platforms, Inc. By integrating the Meta pixel, Meta Events Manager can provide the Controller with information about traffic and interactions on this Website.

  • Company: Meta Platforms, Inc.
  • Processing location: United States
  • Personal Data processed: clicks, browsing history, Usage Data, pageviews, Tracking Tools.
  • Service provided by: Meta Platforms, Inc. (United States). An opt-out function is available.

Displaying content from external platforms

These types of services allow content hosted on external platforms to be viewed directly from this Website’s pages and to interact with it. Such services are often referred to as widgets, that is, small elements embedded in a website or application. They provide specific information or perform a particular function and often allow interaction with the user. This type of service may still collect web traffic data related to the pages where the service is installed, even when users do not use it.

Google Fonts (Google Ireland Limited)

Google Fonts is a font style display service managed by Google Ireland Limited that allows this Website to integrate such content into its pages.

  • Company: Google Ireland Limited
  • Processing location: Ireland
  • Personal Data processed: Usage Data, Tracking Tools.
  • Service provided by: Google Ireland Limited (Ireland).

Information on how to disable interest-based ads

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more about how to disable interest-based advertising in the relevant section of the Cookie Policy.

Cookie Policy

This Website uses Tracking Tools. To learn more, Users can consult the Cookie Policy.

Additional information for users in the European Union

Legal basis for processing

The Controller processes Personal Data relating to the User if one of the following conditions applies:

  • The User has given consent for one or more specific purposes;
  • the processing is necessary for the performance of a contract with the User and/or for the implementation of pre-contractual measures;
  • the processing is necessary to comply with a legal obligation to which the Controller is subject;
  • the processing is necessary for the performance of a task carried out in the public interest or for the exercise of official authority vested in the Controller;
  • the processing is necessary for the pursuit of the legitimate interest of the Controller or of third parties.

It is still always possible to ask the Data Controller to clarify the specific legal basis of each processing activity and, in particular, to specify whether the processing is based on the law, provided for by a contract, or necessary to enter into a contract.

More information about storage time

Unless otherwise specified in this document, Personal Data are processed and stored for the time required by the purpose for which they were collected and may be retained for a longer period due to any legal obligations or based on Users’ consent.

Therefore:

  • Personal Data collected for purposes connected to the performance of a contract between the Controller and the User will be retained until the performance of such contract has been completed.
  • Personal Data collected for purposes related to the Data Controller's legitimate interest will be retained until such interest is satisfied. The User may obtain further information regarding the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.
  • When the processing is based on the User's consent, the Controller may retain Personal Data for a longer period until such consent is withdrawn. Furthermore, the Controller may be obliged to retain Personal Data for a longer period in order to comply with a legal obligation or by order of an authority.

At the end of the retention period, the Personal Data will be deleted. Therefore, once that period has expired, the rights of access, deletion, rectification, and the right to data portability can no longer be exercised.

User Rights under the General Data Protection Regulation (GDPR)

Users may exercise certain rights with regard to the Data processed by the Controller. In particular, to the extent permitted by law, the User has the right to:

  • withdraw consent at any time. The User may withdraw the previously given consent to the processing of their Personal Data.
  • Object to the processing of their Data. The User may object to the processing of their Data when it is carried out on a legal basis other than consent.
  • access their Data. The User has the right to obtain information about the Data processed by the Controller, certain aspects of the processing, and to receive a copy of the Data processed.
  • verify and request correction. The User may verify the accuracy of their Data and request that it be updated or corrected.
  • obtain restriction of processing. The User may request the restriction of the processing of their Data. In this case, the Data Controller will not process the Data for any purpose other than their storage.
  • obtain the deletion or removal of their Personal Data. The User may request the deletion of their Data by the Controller.
  • receive their Data or have it transferred to another controller. The User has the right to receive their Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transmitted without hindrance to another controller.
  • Submit a complaint. The User may submit a complaint to the competent data protection supervisory authority or take legal action.

Users have the right to obtain information about the legal basis for the transfer of Data abroad, including to any international organization governed by international law or established by two or more countries, such as the UN, as well as about the security measures adopted by the Controller to protect their Data.

Details on the right to object

When Personal Data are processed in the public interest, in the exercise of official authority vested in the Controller, or to pursue a legitimate interest of the Controller, Users have the right to object to the processing on grounds relating to their particular situation.

Users are hereby informed that, where their Data is processed for direct marketing purposes, they may object to such processing at any time, free of charge and without providing any reason. If Users object to the processing for direct marketing purposes, the Personal Data shall no longer be processed for such purposes. To find out whether the Controller processes Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise your rights

Any requests to exercise the User’s rights may be addressed to the Controller through the contact details provided in this document. The request is free of charge and the Controller will respond as soon as possible, and in any case within one month, providing the User with all information required by law. Any rectification, deletion or restriction of processing will be communicated by the Controller to each recipient, if any, to whom the Personal Data have been disclosed, unless this proves impossible or involves disproportionate effort. The Controller shall inform the User of such recipients upon request.

Further information on processing

Legal defense

The User’s Personal Data may be used by the Controller in court or in the preparatory stages leading to its possible establishment for the defense against abuse in the use of this Website or the related Services by the User. The User declares to be aware that the Controller may be obliged to disclose the Data by order of public authorities.

Informative specifications

Upon the User's request, in addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

System and maintenance log

For operation and maintenance purposes, this Website and any third-party services it uses may collect system logs, i.e. files that record interactions and may also contain Personal Data, such as the User’s IP address.

Information not covered in this policy

Further information regarding the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this Website and, where technically and legally feasible, by sending a notification to Users through one of the contact details it has on record. Users are therefore advised to check this page regularly, referring to the date of last modification indicated at the bottom.

If the changes affect processing activities whose legal basis is consent, the Controller will obtain the User’s consent again, if necessary.

Definitions and legal references

Personal Data (or Data)

Any information relating to an identified or identifiable natural person constitutes personal data, directly or indirectly, including in connection with any other information, including a personal identification number.

Usage Data

These are the information collected automatically through this Website (including from third-party applications integrated into this Website), including: the IP addresses or domain names of the computers used by the User connecting with this Website, the URI (Uniform Resource Identifier) notation addresses, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numeric code indicating the status of the response from the server (successful completion, error, etc.), the country of origin, the browser and operating system features used by the visitor, the various temporal aspects of the visit (for example, the time spent on each page), and details relating to the path followed within the Application, with particular reference to the sequence of pages viewed, the parameters relating to the operating system and the User's computer environment.

User

The individual who uses this Website, which, unless otherwise specified, coincides with the Data Subject.

Interested

The natural person to whom the Personal Data refer.

Data Processor (or Processor)

The natural person, legal person, public administration and any other entity that processes personal data on behalf of the Controller, as set out in this privacy policy.

Data Controller (or Controller)

The natural or legal person, public authority, service or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data and the tools adopted, including the security measures relating to the operation and use of this Website. The Data Controller, unless otherwise specified, is the owner of this Website.

This Website (or this Application)

The hardware or software tool by means of which Users’ Personal Data are collected and processed.

Service

The Service provided by this Website as defined in the relevant terms (if any) on this site/application.

European Union (or EU)

Unless otherwise specified, any reference to the European Union in this document is deemed to extend to all current member states of the European Union and the European Economic Area.

Cookie

Cookies are Tracking Tools consisting of small portions of data stored within the User's browser.

Tracking Tool

By Tracking Tool is meant any technology – e.g. Cookie, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that enables Users to be tracked, for example by collecting or storing information on the User’s device.

Legal references

Unless otherwise specified, this policy applies exclusively to this Website.

Useful links