1. Introduction
1.1 In accordance with Article 13 of EU Regulation 2016/679 (GDPR) and Italian Legislative Degree no. 196/2003, as amended by Legislative Decree no. 101/2018, we inform you about the processing of your personal data. We value your privacy and are committed to safeguarding your personal data.
1.2 With this Privacy Policy, Ryan Winegan, established in the Italian Republic (Repubblica Italiana) in the European Economic Area (EEA) and with VAT number (Partita IVA) IT05534710263, also describes the legal bases of processing personal data, the consequences of failure to provide personal information, and other provisions related to our Privacy Policy. To better describe your rights, we have also specified if and when a certain processing of personal data is not carried out.
1.3 This Privacy Policy also applies to information we collect:
(a) on the Website;
(b) in email, text, and other electronic messages between you and the Website;
(c) from publicly available sources; and
(d) if applicable in the future, through our advertising, third-party advertising displayed on the Website, and any third-party applications or services that reference this Privacy Policy with our prior authorization.
2. Reference to Terms and Conditions
2.1 This Privacy Policy is governed by, and should be read in conjunction with, the Website's Terms and Conditions, Disclaimer and Disclosure, Cookie Policy, and other applicable legal documents and guidelines, as they apply to your use of this Website.
3. Data Controller
3.1 For the purposes of the GDPR and other applicable data protection laws and regulations where the concepts of "controller" and "processor" are defined, Ryan Winegan is the "Data Controller" of the personal data described in this Privacy Policy. The Data Controller determines the purposes, procedures, and means of processing personal data and website cookies.
3.2 The Data Controller has not appointed a Data Protection Officer (DPO). Therefore, you may send any inquiries you have to the Data Controller.
4. Third-Party Data Submission
4.1 For the purposes of this Privacy Policy and in accordance with the GDPR, a “third party” is any natural or legal person, public authority, agency, or body other than the data subject, the data controller, the data processor, and persons authorized to process personal data under the direct authority or the controller or processor.
4.2 On this Website, you have the possibility of entering personal information of third parties. If you provide personal information of third parties on this Website, you confirm that you have obtained the necessary consent or another lawful basis for processing their data in accordance with GDPR. You acknowledge that you are solely responsible for the accuracy and lawfulness of such information.
4.3 To the extent permitted by law, you agree to indemnify and hold harmless the Data Controller from any claims, liabilities, damages, or costs arising from your provision of third-party personal data.
4.4 The Data Controller remains fully accountable under GDPR for all personal data processed and reserves the right to remove or block any third-party data that appears to have been provided unlawfully.
5. Third-Party Links and Services
5.1 This Privacy Policy has no effect on, and does not govern, any other third-party platform, retailer, service, or external website (collectively, "Third-Party Services") that may be accessed via links provided on this Website.
5.2 This Privacy Policy does not apply to information collection by any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website, which is not owned or operated by us.
5.3 Other websites or properties of Ryan Winegan, including some that are linked to/from the Website, may have different privacy policies; and some of the subpages of this Website may have additional privacy notices to cover activity not covered by this Privacy Policy: therefore, please review the privacy policy or privacy notices on those websites or properties if you visit or use them.
6. Scope / Applicability
6.1 General Scope
This Privacy Policy applies to all users of our Website and services. Our legal obligations under the General Data Protection Regulation (GDPR), the Italian Data Protection Code (Codice in materia di protezione dei dati personali, Legislative Decree no. 196/2003, as amended), and related EU and Italian data protection laws apply specifically to individuals located within the European Economic Area (EEA).
6.2 User Categories
(a) Users in the EEA: Your personal data is processed in accordance with EU and Italian data protection laws, including GDPR and the Italian Data Protection Code. You have rights under these laws, such as access, rectification, erasure, restriction of processing, data portability, and the right to lodge a complaint with the relevant supervisory authority (e.g., the Italian Garante per la Protezione dei Dati Personali);
(b) Users outside the EEA: We apply this Privacy Policy as a best practice; however, certain GDPR- and Italian law-specific rights (such as the right to lodge a complaint with an EU or Italian supervisory authority) may not be available. While local laws in your jurisdiction may provide additional rights, any processing of your personal data by us is conducted in accordance with EU and Italian data protection laws. By using the Website outside the EEA, you agree that Ryan Winegan shall not be held liable for any personal data-related claims or liabilities resulting from your use of the Website if you are located outside the EEA.
(c) Limitation of Liability for Non-EEA Users: By using this Website outside the EEA, you acknowledge that specific rights under EU and Italian lay may not fully apply and that any claims under these laws may be limited by the applicable laws of your jurisdiction.
agree that Ryan Winegan shall not be held liabile for any personal data-related claims or liabilities resulting from your use of the Website if you are located outside the EEA.
6.3 Acknowledgement of Processing
By using our Website, you acknowledge that your personal data may be processed in accordance with this Privacy Policy. EEA users (including those in Italy) may exercise their rights under EU and Italian data protection law.
6.4 As our place of establishment is in the Italian Republic (hereinafter, "Italy"), the processing of personal data is carried out in accordance with:
(a) EU data protection laws, including the GDPR; and
(b) the Italian Data Protection Code (Legislative Decree no. 196/2003), as amended by Italian Legislative Decree no. 101/2018.
7. Data Collection
7.1 We may collect the following categories of personal data, including:
(a) Identity Data: Name, surname, or any other identity data;
(b) Contact Data: Email address, phone number, postal address, or other contact details;
(c) Technical Data: May include IP address, device information, browser type, operating system, or other technical identifiers if such data is collected in the future;
(d) Usage Data: May include information about how you use our website, products, or services, if such data is collected in the future; or
(e) Marketing Data: May include preferences regarding promotional communications, interests, or other marketing-related information.
7.2 We may ask you to provide personal data, such as your name, email address, phone number, or other personal data, that can be used to contact or identify you. The personal data will be processed based on the applicable legal basis under GDPR for each specific purpose, which will be clearly communicated to you at the time of collection.
7.3 The personal data we collect when you provide it directly to us may include the following types of information:
(a) Communications: When you communicate with us, for example via email, contact forms, or other means of communication, we collect your name, contact information, and the content of any communications, messages, or information you provide to us;
(b) Other voluntarily provided information: We may collect any other personal data that you voluntarily provide to us, such as details submitted through forms, messages, or other interactions; or
(c) Personal data of third parties: If you provide personal information of third parties, you confirm that you have obtained the necessary consent or another lawful basis for processing. Such data are processed on the legal basis of consent, legitimate interest, or other lawful basis, as communicated at the time of collection.
7.4 We collect certain personal data you provide to us through:
(a) your access or use of the Website, any of the Services, or any of the Materials;
(b) your electronic communications with us, such as when you inquire about Ryan Winegan, any of the Services, and information related to any other matter you make an inquiry to us about;
(c) any contact you make to us by submitting a (contact) form on the Website, and we may collect additional information from you via calls, chat, text or other means;
(d) any contact you make with us by reaching out to us by means of any of the Services, in affiliation with us, when applicable, and we may collect additional information from you via calls, chat, text or other means;
(e) any comment or post you make and communicate with us on any social media channel and digital platform;
(f) your access to public or private membership groups, including those hosted via a third-party platform, such as, Facebook and others;
(g) your interactions with our social media channels, and, in the future, through subscriptions to updates, newsletters, or other promotional materials. Where such communications are for marketing purposes, we will rely on your consent. Where communications are related to our services or your account, we may rely on our legitimate interests in providing and improving our services; or
(h) your offline communications with us, such as in-person communications.
7.5 We may collect personal data when it is provided to us by the third-party services we use in connection with promoting Ryan Winegan, promoting and selling the work Ryan Winegan, or carrying out other related purposes (for example, external fulfillment providers such as AliveShoes or other fulfillment providers, or other external third-party websites). Where required, such processing will be based on your consent, our legitimate interests, or another lawful basis under the GDPR.
7.6 Information we may collect from other resources include information that is publicly available, such as information from social media or similar platforms, search engines, public directories, published materials, open databases, open-source intelligence (OSINT), and other public data sources.
7.7 This Website does not process "special data." Particular data (i.e., special data) are those that can reveal racial and ethnic origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, associations or organizations of a religious, philosophical, political or trade union, health and sex life.
7.8 No judicial data is processed through this Website.
7.9 Our website may contain links to external websites and platforms, such as social media platforms we use, online non-profit organization websites, third-party online stores where Ryan Winegan products are sold, or other websites and platforms. These external websites may collect and process your personal data according to their own privacy policies. We encourage you to review the privacy policies of these third-party websites before providing any personal information.
7.10 You are not required to provide any information to us. However, failure to provide the personal data requested may result in our inability to fulfill certain requests, such as providing services or responding to inquiries. We will only request the personal data necessary to perform the services or functions you have requested. If you choose not to provide the required personal data, we may not be able to provide the requested services, respond to inquiries, or fulfill your requests.
8. Purposes and Legal Bases of Data Collection
8.1 We use personal data for the following purposes:
(a) to communicate with you, provide you with updates and other information related to us, provide information that you request, respond to your comments and questions, provide support, and deliver communications or fulfill other relevant activities, based on the legal basis of our legitimate interests. You have the right to object at any time to the processing of your personal data based on legitimate interests;
(b) to provide, maintain, improve, and enhance the service we offer, based on the legal basis of our legitimate interests in operating, maintaining, improving, and enhancing our services;
(c) to conduct analysis and develop insights that enable us to operate, protect, make informed decisions, and report on our business or other normal operations, based on the legal basis of our legitimate interests;
(d) for compliance purposes, including enforcing our legal rights or as required by applicable laws, regulations, judicial processes, or governmental requests, based on the legal basis of our legal obligations; and
(e) for any other purpose for which we provide notice at the time of collection. Where required, such processing will be based on your consent, our legitimate interests, or another lawful basis under the GDPR.
8.2 As a general rule, we do not disclose or share your personal data without your consent. However, we may disclose personal data in the following circumstances:
(a) Safety and Protection: We may disclose personal data to appropriate third parties if we believe in good faith that it is necessary to protect or defend the rights, safety, or property of us or others, including to enforce thing to enforce this Privacy Policy or any contractual agreement with you;
(b) Business Transfers: We may disclose personal data to counterparties or their service providers in connection with a strategic transaction, reorganization, bankruptcy, receivership, or transfer of services, provided the recipient is required to protect the personal data; or
(c) Consent/At Your Direction: We may disclose personal data to third parties if you give us your consent or otherwise direct us to do so;
(d) Legal and Regulatory Requirements: We may disclose personal data to government authorities, law enforcement, or other parties where required by law, regulation, judicial process, or to establish, exercise, or defend legal rights;
(e) Future Vendors and Service Providers: In the future, we may share personal data with vendors, contractors, or other service providers who perform services on our behalf or on third-party platforms, such as data storage, analytics, payment processing, marketing, security, fraud prevention, legal services, or other operational services. Any such vendors or contractors would be required to protect personal data and may only process it for the purposes of providing these services; or
(f) Aggregated or Anonymized Data: We may aggregate or anonymize personal data so that it can no longer reasonably be used to identify you. We may use such aggregated or anonymized information for purposes such as improving and adding features to the Website and our Services, conducting research, promoting the work and activities of Ryan Winegan, and other similar purposes. We may also share aggregated or anonymized information on our social media plaforms, other online platforms, or in our communications, and with third parties that provide fulfillment services for us or other services on our behalf. In the future, we may also share such information with advertisers, promotional partners, sponsors, event promoters, or other partners who support our work. Aggregated or anonymized information will be maintained in non-identifiable form, and we will not attempt to re-identify it, unless required by law.
8.3 We do not offer the possibility of registering to this Website. Therefore, we do not process your personal data for this purpose.
8.4 It is not possible to make purchases on this Website. Therefore, your personal data will not be processed for this purpose.
8.5 We may collect information from publicly available resources, such as information from social media or similar platforms, search engines, public directories, published materials, open databases, open-source intelligence (OSINT), and other public data sources, and for the the following purposes:
(a) to carry out research and development activities to improve and evolve our services, and as such our offerings and functionality may evolve over time, based on the legal basis of our legitimate interests. You have the right to object to such processing at any time; and
(b) to respond to a user’s contact or support interactions with us, based on the legal basis of our legitimate interests. You have the right to object to such processing at any time.
9. Information From Minors
9.1 We do not knowingly collect or use personal data from minors. Because personal data will not be specifically identified as being from minors, users of this website should be aware that personal data submitted by minors may be treated in the same manner as information given by an adult.
9.2 If we learn that we have collected or received personal data from a minor without verification of parental or guardian consent, Ryan Winegan will delete that information. If you believe we might have any information from or about a minor, please promptly inform Ryan Winegan.
9.3 Please view our [Terms and Conditions] for details about age limitations of users of this Website.
10. Cookies and Tracking Technologies
10.1 For information about our use of cookies and similar technologies, please see our [Cookie Policy].
11. Analytics (Fathom + Badge)
11.1 This website uses Fathom Analytics, a privacy-focused website analytics service by Conva Ventures Inc., to analyze and improve the use of our Website. The legal basis for processing is our legitimate interest in understanding how our website is used.
11.2 Fathom Analytics does not use cookies and does not store any personal data about you as a visitor. In order to provide us with aggregate statistics, Fathom processes the following minimal technical information:
(a) IP address (anonymized immediately and not stored in identifiable form);
(b) brower type and version (User-Agent string);
(c) operating system and device information; and
(d) the pages accessed, referring URL, and time of access.
11.3 This information is processed in aggregate only and does not allow us to identify individual visitors. Fathom does not create user profiles, does not combine data across websites, and does not share or sell visitor data to third parties.
11.4 A small "Privacy-Friendly Analytics" badge may appear on the Website (bottom corner) to inform users that analytics are anonymous and cookie-free.
11.5 For more information about Fathom Analytics and their approach to data protection, please visit: https://usefathom.com/compliance.
12. Data Retention
12.1 Personal data collected in the context of processing activities that are not subject to specific statutory retention obligations will be retained only for as long as necessary to achieve the purposes for which the data was collected, and for a maximum of 12 months after the relevant actvity has been completed, unless a longer retention period is required to comply with legal obligations or to establish, exercise, or defend legal claims.
12.2 Personal data obtained from publicaly available sources may be retained for as long as it remains relevant to the purposes for which it was collected, and will be periodically reviewed to ensure that retention is appropriate. Such data is not subject to the 12-month retention limited described above.
13. Your Data Protection Rights
13.1 Under both EU and Italian data protection laws, you have the following rights:
(a) Right of Access: You have the right to obtain confirmation as to whether or not your personal data is being processed, and, if so, access to the data and related information;
(b) Right to Rectification: You may request the the correction of inaccurate or incomplete personal data;
(c) Right to Erasure ("Right to be Forgotten"): You can request the deletion of your personal data in certain cases, such as when the data is no longer necessary or has been unlawfully processed;
(d) Right to Restriction of Processing: You may request the limitation of processing where you contest the accuracy of your data, object to its processing, or when processing is unlawful and you oppose deletion;
(e) Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible;
(f) Right to Object: You can object, at any time, to the processing of your personal data when it is based on legitimate interests or for direct marketing purposes;
(g) Right to Withdraw Consent: Where processing is based on your consent, you can withdraw that consent at any time without affecting the lawfulness of processing based on consent before its withdrawal; and
(h) Right to Lodge a Complaint: You have the right to lodge a compliant with a supervisory authority (e.g. the Garante per la Protezione dei Dati Personali, translated as the Italian Data Protection Authority in English).
13.2 Please note that the rights listed in section 10.1 is merely provided for your convenience, but we do not warrant the accuracy or exhaustiveness of the summary nor should you rely on it as an accurate or exhaustive list of your rights.
14. Correcting Your Information
14.1 You may contact us if you believe a correction is needed related to personal information that you have provided to us. Once we receive and confirm your verifiable request, we will take those actions we deem necessary. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
15. Security of Data
15.1 The processing of your personal data will be mainly carried out with the help of electronic or automated means, according to the methods and with the tools suitable to ensure their security and confidentiality in compliance with the GDPR and Italian law. These measures are enacted to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.
15.2 While we are committed to maintaining the security of your personal data, please note that no method of transmission over the internet or method of electronic storage is completely secure, and therefore we cannot guarantee absolute protection against unauthorized access.
16. Opting Out of Communications
16.1 If you have received communications from us that you did not authorize or no longer wish to receive, please contact us immediately. Upon receiving your request, we will promptly discontinue such communications and ensure that your personal data is no longer used for this purpose. You have the right to object at any time, free of charge, to how we use your personal data for future communications, in accordance with the GDPR and Italian law.
17. International Transfers
17.1 We may transfer personal data between the European Union (EU), the United States (US), and other countries as necessary for providing our services. These transfers are carried out in compliance with applicable data protection laws, and we use Standard Contractual Clauses (SCCs), approved by the European Commission, to ensure that personal data is adequately protected in line with the GDPR.
17.2 While we take appropriate safeguards, including the use of SCCs and other measures, to protect your personal data, please be aware that no data transmission or storage system can be guaranteed to be 100% secure. Therefore, despite our efforts to protect your personal data, we cannot guarantee its absolute security during transfer, storage, or processing, whether within or outside the EU, US, or any other jurisdiction.
17.3 By submitting your personal data to us, you:
(a) acknowledge and accept that there are inherent risks associated with international data transfers, including the possibility of unauthorized access or loss of data during such transfers;
(b) consent to the transfer of your personal data across borders, including from the EU to the US and vice versa, and any other jurisdictions where the data may be processed, even if those jurisdictions may not offer the same level of protection as required under the GDPR; and
(c) agree that, to the fullest extent permitted by applicable law, we will not be held liable for any loss, damage, or unauthorized access to your personal data during the transfer, storage, or processing, including data transfers outside the EU and the US. This clause does not limit our legal obligations under GDPR.
17.4 We are committed to implementing reasonable technical and organizational measures to protect your personal data and comply with applicable data protection laws. If you have any concerns regarding the security of your personal data or the international data transfer process, you can contact us at privacy@ryanwinegan.com for further details or clarification.
18. Amendments to this Privacy Policy
18.1 We may update this Privacy Policy from time to time. If changes involve new data processing that require consent, we will notify you and obtain your consent in accordance with EU and Italian law.
18.2 As disclosed in our Terms and Conditions, significant changes to this Privacy Policy will be reflected by updating the "Effective Date" at the top of this page and, where required by law, we will notify you via email or a prominent notice on our Website.
18.3 We encourage you to review this page periodically to stay informed about how we process your personal data.
19. How to Contact Us
19.1 If you have any questions or wish to exercise your rights, please contact the Data Controller at privacy@ryanwinegan.com.
19.2 You may also lodge a complaint with your local Data Protection Authority, for example:
(a) Italy: The Italian Data Protection Authority (Garante per la protezione dei dati personali)
English Website link: [https://www.garanteprivacy.it/web/garante-privacy-en/home_en]
Italian Website link: [https://www.garanteprivacy.it/]
Privacy Policy
Effective Date: September 5, 2025
Last Updated: September 24, 2025