Last Updated: January 14, 2025  

Introduction

To provide products and services (“Services”) to our customers and carry out our daily business operations, including managing our websites, we collect, use, share, or otherwise process personal data about our customers, authorized users of our customers (“end users”) and their customers, website visitors, and business contacts.

Personal data includes any information that directly identifies you, such as your name and email address, or indirectly identifies you, such as a phone number or a device identifier.

The personal data we may collect and process about you varies depending on our relationship with you. We may have a direct relationship with you because you have created an account or agreed to receive marketing communications from us, or we may have an indirect relationship with you through your relationship with one of our customers; for example, you may be their employee or customer.

We take privacy, data protection, and our legal obligations very seriously. We are committed to being transparent about how we use personal data. This Privacy Policy (“Policy”) aims to describe our privacy practices clearly, accessibly, and understandably and to inform you of how you can exercise your rights regarding your data.

This Policy applies where Dillo processes personal data as a data controller in relation to the Services we provide to our customers and the operation of our business, including our websites. As a data controller, we determine the purpose (why) and means (how) of processing personal data and are ultimately responsible for the proper handling of your data, in compliance with applicable law. This Policy describes our general privacy practices. Depending on how you interact with us or the specific services you use, additional privacy policies may apply. Such additional notices will be provided to you at or before the time of collection of your personal data. These supplemental notices should be read in conjunction with this Policy and are incorporated by reference.

We also process personal data for most of our Services as data processors. As data processors, we process personal data related to employees, end users, and customers of our clients on behalf of our clients to provide them with Services in accordance with their instructions. These instructions are set out in our customer contracts, specific service terms, or through a customer’s use or configuration of a product feature.

Personal Data We Process

The personal data we collect about you depends on your relationship with us and the purposes for which we process such personal data. Below are the types of personal data we have collected and processed for a business purpose in the past 12 months.

Personal Data You Provide Directly to Us

Contact Information – When you register for a Dillo account and use any of our Services, request product information, ask to be contacted by our sales team, or attend events, we ask you to provide your name, company name, business address, phone number, email address, and other contact information. We also ask you to create a password and assign a name to your account (or accounts if you have more than one).

Customer Account Data – We process certain personal data to manage our relationship with you and administer your account or your company’s account. This includes purchase history, names, or contact information of persons authorized to manage the Dillo account on behalf of our customer, and information that enables us to verify your identity for Know Your Customer (KYC) or other identity verification purposes.

Customer Content – We receive and store the content of communications received from you or our customers and other personal data uploaded to the Services or generated for use by our customers as part of the Services, which we may be authorized to use as necessary for specific legitimate business purposes in compliance with applicable law.

Marketing and Contact Preferences – We use information about how you wish to be contacted and your preferences to send you marketing communications.

Payment Information – For paid Services, we ask you to provide our payment processor with your payment method details, such as a credit card or PayPal account and billing address. Our payment processor, acting on our behalf, collects this information to enable us to bill you for using our Services. Our payment processor will share your billing address with Dillo for this purpose.

Professional Information – We process information about your employment or profession, including company, title, email address, phone number, and online business networking profile.

Subscriber Data – For some of our communication products, we may also obtain proof of identity from you or our client, which may include proof of address, name, physical address, or other identifying information.

Support and Feedback – When you interact with us through our websites, including via AI chatbots (e.g., our Help Center Assistant), phone, or email, we process your phone number or email address, the content of your interaction, and the feedback you provide on our Services. You may also provide us with feedback on our Services through surveys and questionnaires. We will inform you if a call is recorded in accordance with applicable law.

Personal Data We Generate or Collect Automatically

Communication Usage Data – When you or our clients use Dillo’s communication products, we collect electronic communication metadata, such as phone numbers, routing information, origin and destination of a communication, device location generated in the context of message delivery, date, time, duration, and type of communication, message status, error data, and traffic logs.

Device Information and IP Addresses – When you use our account portal, we collect your IP address and device information through tracking technologies such as cookies, web beacons, pixels, and similar technologies.

Online Activity Information – When you visit Dillo’s websites, including our web forms, we use tracking technologies to collect data such as device and browser details, time zone settings, visited web pages, products viewed or searched for, page response times, download errors, visit duration, page interaction information, and IP address.

Security Identifiers or SIDs – When you register for an account with Dillo, we automatically assign a unique security ID and generate an API token for each account. We keep a record of these credentials to ensure secure API requests.

Personal Data Collected from Other Sources

Additional Service Data – If you purchase our Services through one of our Partners, they may share your personal data with us to fulfill their contractual obligations. Partners may share your personal data in the form of leads when you download Dillo content from the Partner’s website or participate in events and webinars sponsored by Dillo.

Professional Data – We collect certain personal data, such as employment or professional information, from sources other than you. We may combine these data with other personal data you share with us.

Publicly Available Sources – We may also use publicly available information about you that we have collected through services such as LinkedIn or obtain information about you or your company from third-party providers, including industry sector, company size, and company website URL.

Social Media Data – Social media service providers such as Google, LinkedIn, and Meta may provide us with information about you in accordance with your privacy settings on those sites.

How We Process Personal Data

The purposes for which we process personal data depend on your relationship with us. We use only the personal data necessary to fulfill the specific purposes listed below, as applicable to you and in accordance with applicable data protection laws.

Purposes for Processing Personal Data

Below are the different purposes for which personal data are processed:

• Creating and managing accounts, including verifying the identity of our customers’ end users for Know-Your-Customer (KYC) or identity verification purposes.
• Conducting Dillo’s core business activities, such as account administration, accounting, auditing, compliance, business analysis, tax filings, finance, and forecasting.
• Billing and relationship management.
• Providing, optimizing, and maintaining our Services and platform, including debugging and troubleshooting.
• Preventing, detecting, and investigating security incidents and managing the security of the Dillo platform, services, websites, and accounts.
• Preventing, detecting, or investigating abuses or misuse of the Dillo platform or Services, including spam, fraud, illegal activities, or violations of the Dillo Acceptable Use Policy, or assisting telecommunications providers, regulatory authorities, or law enforcement in combating spam, fraud, or illegal activities.
• Routing and connectivity purposes, including sending messages on behalf of our customers, transmission, distribution, and communication exchange using phone numbers through the public switched telephone network (PSTN) and other communication networks.
• Providing customer support, including responding to your inquiries and communicating with you about your account and use of the services, including suspicious activities or security alerts.
• Sending important notifications about our Services.
• Complying with legal and regulatory obligations, telecommunications service provider requirements, and industry communication codes of conduct.
• Sending marketing communications based on your marketing preferences.
• Analyzing your interest in our Services and conducting targeted marketing campaigns for you.
• Implementing cookies and other tracking technologies according to your online settings.
• Understanding how visitors navigate our websites and monitoring and optimizing the performance of our advertising activities.
• Understanding how customers use our platform and improving the website browsing experience.
• Conducting surveys and questionnaires to improve our Services and provide training to our employees.
• Managing your participation in our events and webinars and ensuring you have access to whitepapers and on-demand resources.
• Developing our business by updating, expanding, and analyzing customer relationship data.
• Identifying potential job candidates.
• Developing or improving our Services, including anonymizing, de-identifying, and aggregating personal data for this purpose.
• As otherwise authorized by you or our customer in specific Service terms or through your or our customer’s use and configuration of product features.
• Ensuring the health and safety of our employees, visitors, and property.
• Protecting the rights and freedoms of individuals, complying with legal or regulatory obligations, including valid court orders, disclosure requests, subpoenas, and other appropriate legal mechanisms.

How We Disclose Personal Data

We disclose personal data to third parties in limited circumstances to provide the Services and otherwise manage our business. Below are different scenarios in which we may disclose your data to third parties.

Telecommunications Service Providers

Dillo’s communication products provide developers with an easier way to create applications that use the public switched telephone network (‘PSTN’) for communications. Therefore, we engage with a global network of telecommunications operators, aggregators, carriers, and other communication service providers (collectively, “telecommunications service providers”) as necessary to route and connect these communications from the sender to the intended recipient. How telecommunications service providers handle these data is generally determined by their own policies and local regulations.

Where telecommunications service providers transmit the content of a communication, they do not act as data controllers or data processors but simply function as a conduit to transmit the content. In cases where telecommunications service providers process personal data for their own purposes, such as communication metadata needed to transmit the message, billing, or fraud prevention, they also act as data controllers.

We may need to share subscriber records with local government authorities or local telecommunications carriers that provide connectivity services. However, we do not share subscriber records for purposes beyond this, and we handle such records with the highest level of confidentiality.

Other Communication Service Providers

To ensure proper routing and connectivity, Dillo also allows communications to be sent or received via communication service providers that do not use the PSTN, referred to as Over-the-Top (“OTT”) communication service providers. If you or our customer choose to use Dillo to send or receive communications through these providers, Dillo will disclose communication content and other data to these providers as necessary to route and connect communications from the sender to the intended recipient. How these OTT communication service providers, acting as data controllers, manage these data is determined by their own policies and local regulations.

Legal Compliance
We may disclose your personal data to third parties if:

• We reasonably believe that disclosure is required by law, regulation, legal process, or government request (including for national security, emergency services, or law enforcement purposes);
• To enforce our agreements and policies;
• To protect the security or integrity of our Services;
• To protect ourselves, our other customers, or the public from harm or illegal activities, including security threats, spam, and fraud; or
• To respond to an emergency that we, in good faith, believe requires data disclosure to help prevent death or serious physical injury.

If Dillo is legally required to disclose personal data about you, we will notify you or our customers of the disclosure obligation to the extent permitted by law and where Dillo determines that such disclosure will not interfere with an ongoing investigation. Additionally, we object to information requests that we believe have not been properly issued.

Business Transfers
In connection with a business sale, merger, reorganization, dissolution, or similar event, personal data about you may be part of the transferred assets or disclosed in connection with due diligence for such a transaction. If required by law, we will notify you before such transfer and provide you with information about any choices you may have regarding your personal data.

Aggregated, Anonymized, or De-Identified Data
Aggregated, anonymized, and de-identified data may be derived from your personal data by Dillo, but such data is generally not considered personal data under data protection law, as it does not directly or indirectly reveal your identity. We may use and disclose de-identified, anonymized, or aggregated data to third parties. We do not disaggregate or re-identify de-identified data.

How We Protect Personal Data

To protect personal data from loss, misuse, unauthorized access, or disclosure, Dillo employs reasonable and appropriate security measures designed to safeguard your personal data both online and offline. These measures vary depending on the sensitivity of the personal data we collect, process, and store and the current state of technology. All systems used to support our business are governed by Dillo’s Information Security Policy and Standards, which are based on industry standards.

How Long We Retain Personal Data

We are committed to retaining personal data in a form that allows the identification of individuals for no longer than necessary for the purposes for which such data is processed. We retain personal data in accordance with Dillo’s record retention policies and guidelines, which are reviewed and updated periodically.
Dillo will retain your Customer Account Data for as long as necessary to provide Services to you or our customer and to manage our business. If you request Dillo to delete specific personal data from your Customer Account Data (see “Your Rights and Choices Regarding Your Data” below), we will honor this request unless deleting such information prevents us from performing necessary business functions, such as invoicing for our services, calculating taxes, or conducting required audits.

Your Rights and Choices Regarding Your Data

Depending on the data protection laws applicable to your case, you may have the following rights regarding your personal data that we process as a data controller:

• To be provided with details about the categories of personal data we collect about you, including how we collect and share them;
• To access and obtain a copy of the personal data we collect about you;
• To update or correct any inaccurate personal data we hold about you;
• To request the deletion of personal data we hold about you;
• To restrict the processing of your personal data;
• To receive your personal data in a structured, commonly used format and, where possible, transmit those data to another controller;
• To object to the processing of your personal data, including profiling;
• To have a simple and free mechanism to object to the use of your personal data for direct marketing purposes;
• Not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects or similarly affects your individual rights;
• To withdraw your consent; and
• To file a complaint with a competent supervisory authority and/or initiate proceedings in a competent court.

Dillo will respect your rights subject to limitations in certain situations, such as when Dillo can demonstrate a legal requirement or legitimate interest to process your data or can lawfully apply an exemption under applicable law.

How to Exercise Your Rights and Choices

Access and Control of Account Data
As part of our Services, we provide you with a set of self-service features at no additional cost within the Dillo console, including the ability to access your data, update incorrect data, download a copy of your data, delete your data, or limit the use of your data. You can make various choices regarding your Customer Account Data through the account portal when you log into your Dillo account or via the marketing preference center. Any other data-related requests that you cannot perform through these self-service tools can be requested by contacting Customer Support.

Closing and Deleting Your Account
To request the closure or deletion of your Dillo account, you can contact Customer Support. Please note that closing or deleting your Dillo account will result in the permanent loss of access to your account and any data contained within it. After your account is closed, some information associated with your account may remain on Dillo’s servers in an aggregated form that does not identify you. Similarly, after you close your account, we will retain data, including personal data, associated with your account that we are required to keep for legal or necessary business purposes (see the section “How Long We Retain Personal Data” above) until they are no longer needed.

Identity Verification
In some cases, we will need to verify your identity before fulfilling your request. We typically verify your identity by requesting personal data related to your recent interactions with us. We will then process your request and inform you of any decisions regarding your request. Additionally, you may exercise your privacy rights through an authorized agent. If we receive your request from an authorized agent, we may require proof that you have given the agent a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent making a request, please contact us at privacy@dillo.cloud.
We will not discriminate against you or change the price of our services if you make a request, but if you ask us to delete your data, this may impact your ability to use our Services.

Communication Preferences
You can opt out of receiving marketing communications from us at any time via your marketing preference page by clicking the “unsubscribe” link at the bottom of any marketing email you receive from Dillo. You can also update your communication preferences using our online form or contact our customer support team to express your opt-out choice. Please note that it may take up to three days to remove your contact information from our marketing communication lists, so you may still receive correspondence from us for a short period after making your request. You will not be able to opt out of service-related emails from us, such as password reset emails, billing emails, or notifications about updates to our terms unless you deactivate your account.

How We Use Cookies and Other Tracking Technologies

Dillo uses common information collection tools, such as cookies, pixels, and other similar tracking technologies, to automatically collect information as you browse our websites, your account, or interact with emails we send you.

Cookies

A cookie is a small text file stored in your browser or elsewhere on your hard drive. Cookies allow Dillo to recognize your device while you browse our websites or your account, making navigation and interaction with our websites or your account more efficient, easy, and meaningful for you.
Dillo uses both session and persistent cookies. Session cookies disappear from your computer or browser when you turn off your computer. Persistent cookies remain on your computer even after you turn it off.

Managing Your Cookie Preferences
Dillo uses a Cookie Consent tool that allows you to customize your cookie preferences. When you first visit our website, a cookie consent banner will appear, prompting you to customize your cookie preferences. Note that essential cookies cannot be disabled, and if you choose to opt out of functional cookies, some features of our websites or your account may be affected. All cookie choices are browser- and/or device-specific. If you delete cookies from your browser on any of your devices, your choices must be reset.

Managing Cookies via Your Browser
In addition to using our Cookie Consent tool, you can use your browser settings to disable Functional Cookies and Advertising Cookies.

Under 18

Our Services are not intended for or directed at minors (under 18 years of age). We do not knowingly allow children to register for a Dillo account. If we become aware that a child has registered an account, we will take reasonable steps to disable the account and remove their personal data from our records as quickly as possible. If you believe a minor has registered for a Dillo account, please contact us at privacy@dillo.cloud with the subject “Under 18”.

How to Contact Us

If you have any questions, concerns, or complaints about this Policy or our data protection practices, please contact our Data Protection Officer by emailing privacy@dillo.cloud

Legal Headquarters

CP Software Nord-Est S.r.l. 

Via Monzermone, 1

42100 Reggio Emilia (RE) – Italia

 

Changes to Our Privacy Policy

We will periodically review this Policy and may update it to meet legal, technical, or business development requirements or to provide clarification. When we make changes to this Policy, the most updated version will be available directly on the website www.dillo.cloud. If we make material changes affecting your rights, we will provide prior notice, such as by posting a message in the Dillo console or sending an email to the address we have on file for you. We will comply with applicable law regarding any changes we make to this Policy and will also seek your consent for material changes where required by applicable law.