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Privacy Policy

I – INFORMATION RELATING TO THE PRIVACY POLICY OF THE SITE

  1. This section contains information on how to manage win-project.eu the user’s data processing win-project.eu.
  2. The present policy is also valid for the purposes of art. 13 of Legislative Decree no. 196/2003, Code for the protection of personal data, and for the purposes of Article 13 of EU Regulation no. 2016/679, concerning the protection of individuals with regard to the processing of personal data and the free movement of such data, for persons who interact with win-project.eu and can be reached at the address corresponding to the home page: https://win-project.eu
  3. The information is provided only for win-project.eu and not for other websites that may be consulted by the user through links contained therein.
  4. The purpose of this document is to provide guidance on the methods, timing and nature of the information that the data controllers must provide to users when connecting to the web pages of win-project.eu, regardless of the purposes of the connection itself, according to the Italian and European legislation.
  5. The policy can be modified due to the introduction of new rules in this regard, so we invite you to check this page periodically.
  6. If the user is under the age of 16, pursuant to article 8, c.1 EU regulation 2016/679, he / she must legitimize his / her consent through the authorization of his/her parents or guardians.

II – DATA PROCESSING

1 – Data controller

  1. The data controller is the natural or legal person, public authority, service or other bodies that, individually or together with others, determines the purposes and means of processing personal data. He also deals with security profiles.
  2. Regarding this website the data controller is: Altheo Valentini. He can be contacted for any clarification or exercise of the user’s rights at the following email address: info@win-project.eu.

2 – Responsible for data processing

  1. The data processor is the natural or legal person, public authority, service or other bodies that processes personal data on behalf of the data controller.
  2. Pursuant to Article 28 of EU Regulation no. 2016/679, on the appointment of the owner of the data, the person in charge of processing the site win-project.eu is: Altheo Valentini.

3 – Data processing location

  1. The data processing generated by the use of win-project.eu occurs at Via Andrea Vici 8/b – 06034 Foligno (PG) – Italy.
  2. If necessary, the data linked to the newsletter service can be processed by the responsible for data processing or subjects appointed by the responsible for this purpose at their own office.

III – COOKIES

1 – Type of Cookies

  1. win-project.eu uses cookies to make the user’s browsing experience easier and more intuitive: cookies are small strings of text used to store some information that may concern the user, their preferences or their device for accessing the Internet (computer, tablet or mobile phone) and are mainly used to adapt the functioning of the website to the user’s expectations, offering a more personalized browsing experience and memorizing the choices previously made.
  2. A cookie consists of a small amount of data transferred to the user’s browser from a web server and can only be read by the server that transferred the data. This is not an executable code and does not transmit viruses.
  3. Cookies do not record any personal information and any identifiable information will not be stored. If you want, you can prevent the saving of some or all cookies. However, in this case the use of the site and the provided services could be compromised. To proceed without changing the options related to cookies, simply continue browsing.

The types of cookies that the site uses are as follows:

2 – Technical cookies

  1. There are many technologies used to store information on the user’s computer, which are then collected by the sites. Among these, the most known and used is the HTML cookies. They are used for navigation and to facilitate access and use of the site by the user. They are necessary for the transmission of communications on electronic network that is to say, to the supplier to provide the service requested by the customer.
  2. The settings to manage or deactivate cookies may vary depending on the internet browser used. Nevertheless, the user can manage or request the general deactivation or cancellation of cookies by modifying the settings of his internet browser. This deactivation can slow down or prevent access to certain parts of the site.
  3. The use of technical cookies allows the safe and efficient use of the site.
  4. Cookies that are inserted in the browser and transmitted back via Google Analytics or via bloggers’ statistics service or similar are technical only if used directly by the owner of the website for the purpose of optimizing the website itself. The owner can collect information in aggregate form on the number of users and how they visit the site. Under these conditions, the same rules, in terms of information and consent, apply for analytics cookies.
  5. As regards the duration, we can distinguish temporary session cookies, that are deleted automatically at the end of the browsing session and are used to identify the user and thus avoid logging on every page visited from the permanent ones that remain active in the PC until expiry or cancellation by the user.
  6. Session cookies may be installed in order to allow access to the reserved area of the portal as an authenticated user.
  7. They are not stored permanently but only for the duration of the session and they disappear when the browser is closed. Their use is strictly limited to the transmission of session identifiers consisting of random numbers generated by the server, which are necessary to allow the safe and efficient exploration of the site.

3 – Third-party cookies

  1. As regards the origin we distinguish the cookies sent to the browser directly from the website you are visiting from those of third parties sent to the computer from other websites and not from the one you are visiting.
  2. Persistent cookies are often third-party cookies.
  3. The majority of third-party cookies consists of tracking cookies used to identify online behavior, understand the interests and then customize the advertising proposals for users.
  4. Third-party analytical cookies may be installed. They are sent from the domains of the aforementioned third parties external to the site.
  5. Third-party analytical cookies are used to find information on user behavior on win-project.eu. The survey is carried out anonymously, in order to monitor the performance and improve the usability of the site. The third-party profiling cookies are used to create profiles related to users, in order to propose advertising messages in line with the choices expressed by the users themselves.
  6. The use of these cookies is governed by the rules set by the third parties themselves, therefore, users are invited to read the privacy policies and indications to manage or disable the cookies published on their web pages.

IV – DATA PROCESSED

1 – Data processing mode

  1. Like any other websites, this site also makes use of log files in which information are kept. Information are collected in an automated manner during users’ visits and they could be the following:
    • internet protocol (IP) address;
    • type of browser and device parameters used to connect to the site;
    • name of the Internet service provider (ISP);
    • date and time of visit;
    • web page of origin of the visitor (referral) and exit;
    • possibly the number of clicks.
  2. The above information are processed in an automated form and collected in an exclusively aggregated form in order to verify the correct functioning of the site, and for security reasons. Such information will be processed according to the legitimate interests of the owner
  3. For security purposes (spam filters, firewalls, virus detection), the automatically recorded data may possibly also include personal data such as IP address. The IP address could be used, in compliance with applicable laws, in order to block attempts of damaging the site itself or damaging other users, or in any case of harmful or criminal activities. Such data are never used for the identification or user profiling, but only for the protection of the site and its users, such information will be treated according to the legitimate interests of the owner.
  4. If the site allows the insertion of comments, or in case of specific services requested by the user, including the possibility to send the Curriculum Vitae for a possible working relationship, the site automatically detects and records some identification data of the user, including the e-mail address. These data are voluntarily provided by the user when requesting service delivery. By inserting a comment or other information, the user expressly accepts the privacy policy, and in particular agrees that the contents included are freely disseminated to third parties. The data received will be used exclusively for the provision of the service requested and only for the time necessary for the provision of the service.
  5. Information that users of the website will deem to make public through the services and tools made available to them are provided by the user knowingly and voluntarily. Thus this site is exempted from any liability regarding any violation of the law. It is up to the user to verify that they have permission to enter personal data of third parties or contents protected by national and international standards.

2 – Purpose of data processing

  1. The data collected by the site during its operation are used exclusively for the purposes indicated above and kept for the time strictly necessary to carry out the activities specified and in any case no more than 2 years.
  2. The data used for security purposes (block attempts to damage the site) are kept for the time strictly necessary to achieve the previously indicated end.

3 – Data provided by the user

  1. As indicated above, optional, explicit and voluntary sending of e-mails to the indicated addresses on this website entails the subsequent acquisition of the sender’s address, necessary to respond to requests, as well as any other personal data included in the message.
  2. Specific summary information will be progressively reported or displayed on the pages of the website designed for particular services on request.

4 – Support in configuring your browser

  1. The user can manage cookies also through the settings of their browser. However, deleting cookies from your browser may remove the preferences you have set for the website.
  2. For further information and support, you can also visit the specific help page of the web browser you are using:

V. USER RIGHTS

  1. The art. 13, c. 2 of EU Regulation 2016/679 lists the user’s rights.
  2. The site win-project.eu therefore intends to inform the user about the existence of:
    • the right of the interested party to ask the data controller for access to personal data (Article 15 of the EU Regulation), their updating (Article 7, paragraph 3, letter a) of Legislative Decree 196/2003), rectification (Article 16 of the EU Regulation), integration (Article 7, paragraph 3, letter a) of the Legislative Decree 196/2003) or the limitation of the processing that concerns it (Article 18 of the EU Regulation) or to oppose, for legitimate reasons, to their processing (Article 21 EU Regulation), in addition to the right to data portability (Article 20 EU Regulation);
    • the right to request cancellation (Article 17 of the EU Regulation), the transformation into anonymous form or blocking of data processed in violation of the law, including those that do not need to be kept for the purposes for which the data were collected or subsequently processed (Article 7, paragraph 3, letter b) of Legislative Decree 196/2003);
    • the right to obtain the attestation that the operations of updating, rectification, integration of data, cancellation, blocking of data, transformation have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case this fulfillment proves impossible or involves a use of means manifestly disproportionate to the protected right (Article 7, paragraph 3, letter c) of Legislative Decree no. 196/2003);
  • Requests can be sent to the data controller, without formalities or, alternatively, using the model provided by the Guarantor for the Protection of Personal Data, or by sending an email to: info@win-project.eu
  • If the treatment is based on art. 6, paragraph 1, lett. a) – express consent to use – or on art. 9, paragraph 2, lett. a) – express consent to the use of genetic, biometric, health-related data, revealing religious beliefs, philosophical or union membership, revealing racial or ethnic origin, political opinions – the user has the right to revoke the consent at any time without prejudice to the lawfulness of the treatment based on the consent given prior to the revocation.
  • Likewise, in case of violation of the law, the user has the right to lodge a complaint with the Guarantor for the Protection of Personal Data, as the authority responsible for monitoring the processing in the Italian State.
  • For a more in-depth examination of the rights that you are entitled to, see articles 15 and ss. of the 2016/67 EU Regulation and the art. 7 of Legislative Decree 196/2003.

VI. DATA TRANSFER TO EXTRA EU COUNTRIES

  1. This website may share some of the data collected with services located outside the European Union. In particular with Google, Facebook and Microsoft (LinkedIn) through social plugins and the Google Analytics service. The transfer is authorized and strictly regulated by Article 45, paragraph 1 of EU Regulation 2016/679, for which no further consent is required. The companies mentioned above guarantee their adherence to the Privacy Shield.
  2. Data will never be transferred to third countries that do not comply with the conditions set out in Article 45 e ss of the EU Regulation.

VII. SECURITY DATA SUPPLIED

  1. This website processes the data of users in a lawful and correct manner, adopting the appropriate security measures to prevent unauthorized access, disclosure, modification or unauthorized destruction of data. The processing is carried out using IT and / or telematic tools, with organizational methods and with logic strictly related to the purposes indicated.
  2. In some cases, along with the owner, a number of employees, who are involved in the organization of the site (administrative, commercial, marketing, legal, system administrators) or external subjects (as suppliers of third party technical services, couriers, hosting providers, IT companies, communication agencies) may also have access to the data.

VIII. CHANGES TO THIS DOCUMENT

  1. This document, published at: http://www.win-project.eu/privacy-policy/ constitutes the privacy policy of this site.
  2. It may be subject to changes or updates. Users are invited to periodically consult this page to keep up to date with the latest legislative news.
  3. Previous versions of the document will still be available on this page.
  4. The document was updated on 10/01/2025 to comply with the relevant regulations, and in particular in compliance with EU Regulation 2016/679.
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Benefits of neuroinclusive workplaces

What does an organization gain by supporting neurodiversity?

  • Greater innovation through diverse cognitive perspectives and ideas.
  • Higher engagement and sense of belonging, leading to lower employee turnover.
  • A stronger employer brand built on openness, diversity, and empathy.
  • Improved processes and tools by implementing structured task calendars, milestones, and systematic follow-ups.
  • Better talent management through regular feedback, internal mobility, and diversified responsibilities.

Neuroinclusion as an organizational advantage

By placing sensitivity and accessibility at the center of process and workplace design, an organization creates a culture where every employee — regardless of neurological profile — can fully realize their potential.

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Mental Health vs. Neurodiversity

Neurodivergence is often linked to both mental health challenges and academic difficulties. It can also increase the risk of developing secondary conditions such as anxiety or depression. Research suggests that around 60% of individuals with autism or ADHD experience anxiety or depressive episodes at some point.

This overlap happens for two main reasons:

  • Internal factors, such as sensory sensitivity or difficulties with executive functioning
  • External pressures, including social expectations and environmental demands

Identity, Belonging, and Masking

Neurodivergent individuals often face more challenges in building a stable sense of identity. Repeated experiences of feeling different, socially excluded, or misunderstood can:

  • Lower self-esteem
  • Increase feelings of isolation
  • Raise vulnerability to anxiety and depression


To cope, many people develop masking strategies.

Masking involves suppressing natural behaviors or imitating neurotypical ones in order to “fit in.” While this can help with short-term social adaptation, it comes at a cost.

Long-term masking can lead to:

  • Chronic exhaustion
  • Increased stress
  • Reduced learning capacity
  • Difficulty with problem-solving
  • A sense of inauthenticity
  • Burnout


Over time, constantly hiding one’s natural traits can worsen mental health and reduce overall well-being.

The Educational Mismatch

Many of these challenges stem from a mismatch between:

  • Social and environmental demands
  • The way neurodivergent executive functions operate

Standardized teaching methods are typically designed for the majority’s cognitive style. As a result, they may clash with:

  • Sensory sensitivities
  • Attention regulation differences
  • Intense focus on specific interests

Importantly, neurodivergent individuals often have strong intellectual potential. However, difficulties with attention, sensory overload, or highly focused interests can make traditional educational environments harder to navigate.

Creating more flexible and responsive systems can significantly improve both mental health and learning outcomes.

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Intercultural context

It is important to recognize the significance of socio-cultural norms and patterns, that establish the criteria by which we assess an individual’s fit within their environment and highlight the barriers that may hinder the full realization of one’s potential. The contemporary approach to neurodiversity assumes that a critical review of cultural norms and social frameworks is essential for developing support methods that genuinely address the needs of individuals with diverse neurological profiles. As a result, creating adaptable environments becomes a fundamental aspect of fostering more inclusive communities.

Neurodiversity can be understood as an aspect of individual differences primarily shaped by environmental demands – the ease or difficulty of adapting to various circumstances. Furthermore, neurodivergence significantly influences mental health, identity, and overall well-being, shaping how individuals perceive and engage with the world.

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Clinical Model vs. Social Model of Neurodiversity

In discussions about neurodiversity, two main perspectives are used to understand neurological differences: the clinical (medical) model and the social model. While they approach the topic differently, they can work together to create a more complete and supportive understanding.

The Clinical Model
The clinical model is based on formal diagnostic frameworks such as the Diagnostic and Statistical Manual of Mental Disorders (DSM-5) and the International Classification of Diseases (ICD-11).

This approach:

  • Focuses on identifying symptoms, challenges, and functional difficulties
  • Uses structured diagnostic criteria
  • Supports access to therapy, accommodations, and medical care


Why it matters:
In healthcare settings, this model is essential. It helps professionals design targeted interventions and provide appropriate support.

Its limitation:
When used alone, the clinical model can unintentionally reduce neurodivergent individuals to a list of deficits. This perspective may contribute to feelings of helplessness, negative self-image, or lowered self-esteem.

The Social Model
The social model offers a complementary perspective. Rather than focusing primarily on deficits, it emphasizes the role of the environment and society.

This approach:

  • Recognizes neurological differences as natural variations in human diversity
  • Highlights environmental and cultural barriers
  • Views many challenges as a “mismatch” between individuals and their surroundings
  • Focuses on adapting systems and environments, not just individuals


Key idea:
Difficulties are not seen solely as internal traits, but often as the result of structural and social barriers.

The social model does not deny that support needs exist. Instead, it reframes them within the context of accessibility, inclusion, and systemic design. It also emphasizes the strengths and potential that can arise from alternative neurological development.

Why both models matter

Understanding the relationship between the clinical and social models allows for:

  • More inclusive communication
  • Better support strategies
  • Deeper understanding of diverse functioning profiles
  • A balanced view that recognizes both needs and strengths

Together, these models help promote an inclusive approach to neurodiversity — one that acknowledges challenges while also valuing neurological differences as part of natural human variability.

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Neurodivergence

Neurodivergence refers to individuals whose patterns of thinking, communicating, and overall of daily functioning significantly differ from established social and cultural norms. Rather than pathologizing these differences, the term defines alternative neurological developmental pathways and highlights specific adaptive mechanisms and educational needs of those considered as non-normative or atypical*.

Neurodivergent individuals often demonstrate unique qualities, which can result in both challenges and advantages across various domains – from education to professional environments. Recognizing these diverse cognitive profiles allows for the development of inclusive approaches that support and maximize their potential**.

*McLennan, H., Aberdein, R., Saggers, B., Gillett‑Swan, J., & Gillett‑Swan, J. (2025). Thirty years on from Sinclair: A scoping review of neurodiversity definitions and conceptualisations in empirical research. Review Journal of Autism and Developmental Disorders. Advance online publication. https://doi.org/10.1007/s40489-025-00493-2
** Dwyer, P. (2022). The neurodiversity approach(es): What are they and what do they mean for researchers? Human Development, 66(2), 73‑92. https://doi.org/10.1159/000523723

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Neurodiversity

Neurodiversity is an umbrella concept. In its broadest and most universal sense, it refers to the natural range of variations in brain structure and function. It represents an interdisciplinary framework that combines biological, psychological, and social approaches to understanding differences in the functioning of the human nervous system.

This concept emphasizes that variability in information processing, emotional responses, and adaptive strategies is a natural part of human existence. A key aspect of this approach is the belief that neurological diversity should be viewed in the context of individual integrity, rather than solely as a criterion for medical classification. As a result, neurodiversity provides a framework for reinterpreting traditional diagnostic and intervention models, highlighting the importance of integrating scientific knowledge with social needs.

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Responding to Overload or Shutdown

Overload can occur when sensory, emotional, or cognitive demands exceed capacity. A shutdown may look like withdrawal, silence, slowed responses, or difficulty speaking.

When this happens:

  • Stay calm.
  • Reduce immediate demands.
  • Avoid pressing for explanations.
  • Offer space or a short break.
  • Follow up privately later.
  • Do not interpret shutdown as defiance, lack of interest, or incompetence.

Supportive responses strengthen trust. Reactive or public responses can cause long-term harm.

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Burnout Prevention & Wellbeing

Neurodivergent employees may be more vulnerable to burnout when workplaces are unpredictable, overstimulating, or unclear.

Common risk factors include:

  • Constant interruptions
  • Ambiguous expectations
  • Excessive social demands
  • Lack of recovery time
  • High masking effort

 

Burnout prevention includes:

  • Clear priorities
  • Structured workload planning
  • Flexible pacing when possible
  • Predictable meeting culture
  • Respect for breaks and boundaries

 

Wellbeing should be proactive, not reactive. Waiting until someone is overwhelmed is often too late.

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Masking & Its Impact

Masking refers to consciously or unconsciously suppressing natural behaviors in order to appear “typical” or socially acceptable.

Examples include:

  • Forcing eye contact
  • Copying communication styles
  • Hiding sensory discomfort
  • Avoiding asking for clarification

Masking can improve short-term social acceptance but often comes at a significant cognitive and emotional cost.

Long-term masking may contribute to:

  • Chronic exhaustion
  • Increased stress
  • Reduced learning capacity
  • Difficulty with problem-solving
  • A sense of inauthenticity
  • Burnout

A neuroinclusive environment reduces the pressure to mask by accepting different communication and working styles.

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Case Study B

The “Structured Success” Start

Three days before starting, Alex received a “Pre-Arrival Guide” via email. It included a photo of the front door, a map of the office, the name of their “Onboarding Buddy” (Sarah), and a schedule for the first week. It also mentioned that the dress code was “casual/comfortable” and that lunch would be at 1:00 PM in the quiet zone.

On Day One, Sarah met Alex at the entrance. Alex’s desk was located in a quiet corner with clear labels on all the supply cabinets. The manager had already sent an email to the team introducing Alex, so there was no pressure to do a public speech.

Instead of a single marathon session, the training was split into small, manageable steps spread over two weeks. Alex was given a digital folder containing the same info in video format with subtitles and a printable PDF checklist. During their first 1:1, the manager asked: “Are there any adjustments to the workspace or our communication that would help you work best? You don’t need to share any medical details—just let us know what you need.”

Your Task: Identify the “Best Practices” What went well in this scenario? List at least 4 positive actions based on the sources.

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Case Study A

The “Sink or Swim” Start

On Monday morning, Alex arrived at the office but wasn’t sure which entrance to use, as the building had three. After finding the reception, Alex was told their manager was in an emergency meeting and hadn’t left instructions.

Alex was eventually seated in a high-traffic area next to a loud coffee machine and a flickering light. By noon, the manager arrived and immediately took Alex to a “Welcome Circle,” where Alex was asked to stand in front of 30 people and share “three fun facts” about themselves.

The rest of the week was a blur of long, verbal-only training sessions. When Alex asked if there were any written manuals, they were told, “We prefer learning by doing here.” To get a noise-cancelling headset, Alex was informed they would need to submit a formal HR request including a doctor’s note and a private diagnosis.

Your Task: Identify the “Red Flags” What went wrong in this scenario? List at least 4 issues based on the sources.

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Accessibility statement

We are committed to ensuring our website is accessible to everyone.

This website is designed to conform to the Web Content Accessibility Guidelines (WCAG) 2.1, Level AA. We aim to make our content perceivable, operable and understandable for as many users as possible, across different devices and assistive technologies.

We recognize that people interact with digital content in different ways. Our approach to accessibility includes consideration for all users by striving for clear language, consistent navigation, predictable interactions, and reduced unnecessary sensory overload wherever possible. Accessibility is an ongoing process, and we continue to review and improve our design and content choices with inclusivity in mind.

If you experience any difficulty accessing content on this website or have suggestions for improvement, we welcome your feedback. Please contact us at:

Email: accessibility@xxx.com

We will do our best to respond and address accessibility concerns promptly.

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Read more about this approach

This guide is written with Universal Design principles in mind, showing how to adjust physical workspaces and organizational practices to support all employees, with a specific focus on those with neurodivergent profiles. 

You will find here a step-by-step roadmap, covering important elements of the employee lifecycle:

  • Building awareness: Moving from simple compliance to deep education for managers and teams.
  • The physical and digital workspace: Practical adjustments to reduce sensory overwhelm and cognitive friction.
  • Operational shifts: Rethinking how we run meetings, provide feedback, and structure daily communication.


We recognize that every organization is unique. Some solutions suggested here may not be immediately possible due to budget, physical layout, or industry constraints.

Additionally, it is important to remember that there are no two neurodivergent employees with the same needs. What helps one person may be neutral or even distracting to another.

The goal of this guide is not to provide a rigid set of rules, but to help you build the organizational “flexibility muscle”. By creating a culture of openness and transparency, you are doing more than just supporting a specific group – you are preparing your organization for the future.

It’s also important to emphasize that the solutions outlined here don’t benefit only those who face specific barriers – everyone in the organization can gain from them. 

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