Privacy Policy

Last modified: 8 July 2026

Data Controller

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

Data Controller's email address: info@tuduu.it

Types of Data We Collect

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

  • first name
  • last name
  • company name
  • email
  • Usage Data
  • Tracking Tools
  • number of Users
  • session statistics
  • browsing history
  • clicks
  • page views

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or through specific information notices displayed before the Data are collected.

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. Where this Website specifically states that certain Data are not mandatory, Users are free not to provide such Data, without this affecting the availability or operation of the Service.

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

Any use of Cookies – or other tracking tools – by this Website or by the third-party service providers used by this Website is intended to provide the Service requested by the User, in addition to the further 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.

How and Where the Collected Data Are Processed

Processing Methods

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

Processing is carried out using computers and/or telecommunications tools, with organizational procedures and logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other parties involved in the organization of this Website may have access to the Data (administrative, sales, marketing and legal staff, and system administrators), as well as external parties (such as third-party technical service providers, postal couriers, hosting providers, IT companies and communication agencies) who may also be appointed, where necessary, as Data Processors by the Data 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 at any other location 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 location of processing, the User may refer to the section concerning details on the processing of Personal Data.

Data Retention Period

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

Purposes of Processing the Collected Data

The User's Data are collected to enable the Data Controller to provide the Service, comply with legal obligations, respond to requests or enforcement actions, protect its own rights and interests (or those of Users or third parties), identify any malicious or fraudulent activities, and for the following purposes:

  • Contacting the User
  • Contact management and message sending
  • Analytics
  • User database management
  • Tag management
  • Advertising
  • Displaying content from external platforms

Details on the Processing of Personal Data

Contacting the User

Contact form

By completing the contact form with their Data, the User authorizes this Website to use this information to respond to requests (such as quotes and any other requests).

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

Contact management and message sending

This type of service allows email, telephone or any other type of contact database to be managed for communicating with the User. These services may also allow the collection of data relating to the date and time when messages are viewed by the User, as well as the User's interaction with them, such as information about clicks on links included in messages.

Brevo email (SendinBlue SAS)

Brevo email is an email address management and message-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

This type of service allows the Data Controller to build User profiles starting from an email address, name or any other information that the User provides to this Website, as well as to track the User's activities through statistical 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 enable scheduled messages to be sent to the User, such as emails based on specific actions performed 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 address, Tracking Tools.
  • Service provided by: SendinBlue SAS (France).

Tag management

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

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

Advertising

This type of service allows User Data to be used for commercial communication purposes. These communications are displayed on this Website in the form of banners and other forms of advertising, also in relation to the User's interests. This does not mean that all Personal Data is used for this purpose. Data and conditions of use are shown below.

Some of the services listed below may use Tracking Tools to identify the User, or use behavioral retargeting techniques, that is, displaying personalized advertisements based on the User's interests and behavior, or measuring advertisement performance. For more information, we suggest that you check the privacy notices of the respective services.

Services of this type 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 connects data from the Google Ads advertising network with actions taken within this Website. To learn about Google's use of Data, 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 enable the Data Controller to monitor and analyze traffic data and are used to track User 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 to track and examine the use of this Website, compile reports, and share them with other services developed by Google. Google may use Personal Data to contextualize and personalize advertisements from 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 learn about Google's use of Data, consult their partner policy and their Business Data page.

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

Meta Events Manager (Meta Platforms, Inc.)

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

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

Displaying content from external platforms

This type of service allows content hosted on external platforms to be displayed directly on the pages of this Website and interacted with. Such services are often referred to as widgets, meaning 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 nevertheless collect web traffic data relating to the pages where the service is installed, even when users do not use it.

Google Fonts (Google Ireland Limited)

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

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

Information on how to disable interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users can 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 find out more, Users can consult the Cookie Policy.

Further information for users in the European Union

Legal basis for processing

The Data 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 performance of pre-contractual measures;
  • the processing is necessary for compliance with a legal obligation to which the Data Controller is subject;
  • the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller;
  • the processing is necessary for the purposes of the legitimate interest pursued by the Data Controller or by third parties.

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

Further information on the retention period

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

Therefore:

  • Personal Data collected for purposes connected with the performance of a contract between the Data Controller and the User shall be retained until the performance of that contract has been completed.
  • Personal Data collected for purposes related to the legitimate interest of the Data Controller shall be retained until that interest has been satisfied. The User can obtain further information about the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.
  • Where processing is based on the User's consent, the Data Controller may retain the Personal Data for longer until such consent is withdrawn. In addition, the Data Controller may be required to retain the 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 this period has expired, the rights of access, erasure and rectification, as well as 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 Data Controller. In particular, within the limits provided by law, the User has the right to:

  • withdraw consent at any time. The User can withdraw consent to the processing of their Personal Data previously given.
  • object to processing of their Data. The User can object to the processing of their Data when it takes place on a legal basis other than consent.
  • access their Data. The User has the right to obtain information about the Data processed by the Data Controller, certain aspects of the processing and a copy of the Data processed.
  • verify and request rectification. The User can verify the accuracy of their Data and request that it be updated or corrected.
  • obtain restriction of processing. The User can request 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 erasure or removal of their Personal Data. The User can request that their Data be erased by the Data 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 transferred without hindrance to another controller.
  • lodge a complaint. The User can lodge a complaint with 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 organisation governed by international law or established by two or more countries, such as the UN, as well as information about the security measures adopted by the Data Controller to protect their Data.

Details on the right to object

Where Personal Data are processed in the public interest, in the exercise of official authority vested in the Data Controller or for the purposes of the legitimate interest pursued by the Data Controller, Users have the right to object to the processing on grounds relating to their particular situation.

Users are informed that, where their Data are processed for direct marketing purposes, they may object to the processing at any time, free of charge and without providing any justification. If Users object to processing for direct marketing purposes, the Personal Data will no longer be processed for those purposes. To find out whether the Data Controller processes Data for direct marketing purposes, Users can 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 using 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 event within one month, providing the User with all the information required by law. Any rectifications, erasures or restrictions 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 will inform the User of these recipients if the User so requests.

Further information on processing

Defense in legal proceedings

The User's Personal Data may be used by the Controller in legal proceedings or during the preparatory stages leading to their possible initiation, for the defense against abuses in the use of this Website or the related Services by the User. The User acknowledges that the Controller may be required to disclose the Data by order of public authorities.

Specific notices

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

System logs and maintenance

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

Information not contained in this policy

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

Changes to this privacy policy

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

If the changes concern processing activities whose legal basis is consent, the Controller will obtain the User's consent again, where necessary.

Definitions and legal references

Personal Data (or Data)

Personal data means any information that, directly or indirectly, including in connection with any other information, including a personal identification number, identifies or makes identifiable a natural person.

Usage Data

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

User

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

Data Subject

The natural person to whom the Personal Data refer.

Data Processor (or Processor)

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

Data Controller (or Controller)

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

This Website (or this Application)

The hardware or software tool through 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 website or application.

European Union (or EU)

Unless otherwise specified, any reference to the European Union contained 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

A Tracking Tool means any technology, such as Cookies, unique identifiers, web beacons, integrated scripts, e-tags and fingerprinting, that makes it possible to track Users, 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