Who we are

This Privacy Policy informs the users (“Users”) of this website (“Website”) on the processing of their personal data (“Personal Data”), with respect, for instance, to the categories of Personal Data processed, the purposes of processing and the main safety measuers used to protect the privacy rights of Users.

This Privacy Policy has been drafted pursuant to the EU General Data Protection Regulation N. 2016/679 (GDPR), the Italian Privacy Code and all other applicable laws and regulations.

Users are encouraged to read this Privacy Policy carefully. If they do not approve its content, they should cease browsing the Website without delay.

This shall be without prejudice to the processing, communication and dissemination of Personal Data in accordance with legal provisions and in the further cases permitted by applicable law.

Users with less than 16 years of age are not allowed to consent to the processing of Personal data without parental or guardian authorization.

Personal Data

When Users access or browse the Website, certain categories of Personal Data of the Users and/or other data subjects are automatically collected by the Website.

In particular, the Website collects and processes, in an automatic way, information concerning the interaction with the User’s device: for example, the IP address used for the connection, further information concerning the browser, operating system and type of device used, the pages visited and the searches made on the Website, as well as further information.

In this case, the processing of Personal Data will be necessary to enable User browsing or to make it smoother.

Moreover, the Website expressly requires Users to communicate their Personal Data during the procedure to sign up to the Website and/or to complete a purchase order on the Website. In this case, it is personal data necessary or useful to fulfil contractual obligations and/or provide services to the User.

In other cases, the Site asks Users for their Personal Data in order to send communications of various kinds: for example, for subscribing to newsletters, for taking part in prize competitions or for sending commercial offers, either by itself or by third parties. In such cases, the prior and unambiguous consent of the User is an indispensable condition.

On the basis of its legitimate interest in better developing its relationship with customers, the Website may contact customers by e-mail in order to offer them services and products similar to those previously purchased. Customers may however, at any time, request the interruption of the processing, for example by clicking on a special link included in the commercial e-mail sent by the Website.

In all other cases, it will be indicated from time to time by the Website when the provision of Personal Data by the User is mandatory or optional.

The User’s denial of consent to the processing of Personal Data for purposes other than registration to the Website and/or the completion of orders on the Website will not have any significant consequences.

Personal Data are stored and processed in a manner and for a duration proportionate and appropriate to the purposes for which the Data are collected and further processed. Personal Data are used only where necessary in relation to the purposes for which it was collected and further processed.

Data Controller

The Data Controller of the Personal Data (“Data Controller”) is:
Werking di Andrea Sega, Loc. Are, Vallarsa, 38068,TN, Italia
E-mail address for any communications concerning this Privacy Policy: werkingcycle(a)gmail.com

The Personal Data collected for the purposes set out in the Privacy Policy are processed by staff in charge of the processing in the performance of their duties under the direct authority of the DataController or of suppliers acting as data processors (“Data Processors“).

Browsing data of the User

The IT systems and computer programs used for the operation of the website collect some personal data whose transmission is implied in the use of Internet communication protocols (e.g. the IP addresses or the domain names of computers used by users who connect to the website, the URI -Uniform resource Identifier- addresses of the requested resources, the time of the request, the method used to submit the request to the server, the dimension of the file obtained, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and other parameters related to the operating system and the user’s computing environment). This information is not collected in order to be associated with identified data subjects. This data is used for the sole purpose of obtaining statistical information not associated with any user identification data on the use of the Website and to check the correct operation of the Site and is deleted immediately after processing. This data may also be used for the purposes of investigating liabilities in the event of information crimes committed against the Website. The legal basis of the processing is therefore the legitimate interest in the operation and security of the Website.


The website uses cookies for which there is a reference to the specific information.

Data provided voluntarily by the User of the Website

No personal information of the user is required for the website to be visited. However, any contact with the Controller, or the optional, explicit and spontaneous sending of messages, e-mail or traditional mail, to the contact details of the Controller indicated on the website or the compilation of the fields in the “CONTACTS” section entail the subsequent acquisition of the following personal data: surname, first name, telephone, e-mail of the sender, necessary to reply to requests, as well as any other personal data provided in the related communications. Such data will be processed in the sole purpose of following up on the user’s request and may be communicated to third parties only if this is necessary for this purpose. Such data are stored for the time necessary to give the interested party the answers related to its requests and during the quotation’s validity time, without prejudice to further storage obligations required by law.


The user can subscribe to our newsletter, via the specific section of the Website, by indicating his/her email address to receive periodic information concerning the products and services of the company; in that case, the processing of personal data for this purpose will take place based on the consent of the concerned person, who can withdraw it at any time and the failure to consent or the failure to provide the data will not have any consequence on the possible contractual relationship. With regard to direct marketing, this means also for the sending of the newsletter, the consent (and the related right to withdraw it) constitutes the legal basis also for legal persons. The data will be processed for this purpose until the withdrawal of the consent (newsletter unsubscription) and in any case no more than 36 months from the time in which the consent was given or from its renewal.


It will be possible to purchase products via the e-commerce section SHOP. In that case, the following common personal data will be subject to processing: Surname, name, date and place of birth, residence; fiscal code and/or VAT registration number; telephone number/email address; destination address; order description and purchased product. The data subject to processing are provided by the customer or are resulting from public registers (such as CCIAA or Registry Office).

The data are processed for purposes strictly related to the management of the pre-contractual and contractual relationship, included the administrative formalities and requirements, accounting and fiscal requirements (for example: acquisition of prior information for the conclusion of the contract; carrying out of activities based on obligations derived from the conclusion of the contract) and litigation management (contractual purpose).

There is no obligation to provide the data in the pre-contractual phase, but if they are not conferred it will not be possible to make a quotation or to conclude the contract; when the contract is concluded, the conferral of the further necessary data, or the update of the already conferred ones, is compulsory for all that is required by legal and contractual obligations, therefore any refusal to provide them in whole or in part may configure contractual failure of infringement of the law (if such data are necessary for legal requirements or requirements of the authorities) by the supplier. The legal basis of the processing is the fact that it is necessary: for the execution of the contract of which the person concerned is part or the pre-contractual measures adopted at his/her request; for the fulfilment of a legal obligation to which the Data Controller is subject.

The data may be processed also for marketing purposes, according to the following conditions: The Controller can send to the email address supplied in the context of a former purchase communications related to the direct selling of products and services similar to those already purchased, which is allowed, unless the receiver – adequately informed,- objects such use, initially or during subsequent submissions,; in this last case, the legal basis for the processing is the legitimate interest of the Controller in the marketing activity.

As regards the contractual purpose, the data will be kept for the duration of the contractual relationship, and, after its termination – limited to the data at that point necessary – for the termination of the contractually assumed obligations and for the fulfilment of all the possible legal obligations and for the requirements of protection (also contractual) connected or deriving from it. With regard to marketing purposes, the processing can take place until the objection of the recipient, but in any case, not more than 36 months since the last purchase.

Personal data will be processed by personnel instructed and authorised by the Data Controller using procedures, technical and IT tools suitable for protecting the confidentiality and security of the data.

Disclosure of Personal Data

The Controller discloses part of the Personal Datato other subjects, including third parties, involved in the fulfillment of purchase orders or in the after-sale process. In this circumstance, the communication of Personal Data to suppliers is necessary to fulfill the contractual obligations arising from the conclusion of orders on the Website.

This is without prejudice to the disclosure or dissemination of Personal Data where required by judicial authorities, other public entities for purposes of defense or state security or for the prevention, investigation or suppression of administrative or criminal offenses, and in any event in cases where the disclosure or dissemination ofPersonal Data is prescribed by law.

In all other cases, the disclosure or distribution of Personal Data is subject to Users express and unequivocal consent.

Users may ask the Data Controller for an up-to-date list of Data Processors by emailing the following address: werkingcycle(a)gmail.com.

It is not intended to transfer personal data to countries that are not members of the European Union or to International Organisations. If, for specific technical reasons, the Data Controller transfers to third countries in order to ensure an adequate level of data protection, this is done in accordance with the following conditions: transfer on the basis of an adequacy decision, transfer subject to adequate safeguards, binding corporate rules or application of exemptions provided for specific situations.

It is not intended to transfer personal data to countries that are not members of the European Union or to International Organizations. If, for specific technical reasons, the Data Controller transfers to third countries in order to ensure an adequate level of data protection, this is done in accordance with the following conditions: transfer on the basis of an adequacy decision, transfer subject to adequate safeguards, binding corporate rules or application of exemptions provided for specific situations.

Rights of the Users

Users are entitled to obtain confirmation of the existence or non-existence of Personal Data processed by the Website that concerns them.

Each User has the right to obtain:

  1. the updating, correction or, in case of a legitimate interest, supplementing of Personal Data;
  2. the deletion, anonymisation or blocking of illegally processed Personal Data, including data that does not need to be retained for the purposes for which the data was collected and subsequently processed;
  3. an attestation that the operations mentioned under a. and b. above have been made known, including with respect to their content, to the recipients of the disclosed Data, unless doing so is impossible or requires using means obviously disproportionate to the protected right;
  4. interruption of the Personal Data processing, in the cases provided by law;
  5. the portability of the Personal Data (i.e., the right of Users to receive, in a commonly used and machine-readable structured format, Personal Data supplied to the Controller) to the extent permitted by law;
  6. The revocation of their consent to the processing of Personal data at any time.

The User has the right to oppose, for legitimate reasons, any or all of the processing of the Personal Data, regardless of whether the Personal data are relevant to the purposes for which they were collected or are used for advertising or marketing purposes.

Moreover, the User has the right to submit complaints related to the collection and processing of Personal Data to the Italian Privacy Protection Authority or any other competent supervisory authority.

For all communications and enquiries regarding the processing of their Personal Data and to exercise their own privacy rights, as indicated above, Users may contact the Controller by e-mail at the following address: werkingcycle(a)gmail.com

This Privacy Policy is subject to periodic updating. Users are encouraged to read this Privacy Policy periodically in order to check for any changes.