1. Purpose

This Privacy Notice explains how DifferentGuys Studio ("we", "us", "our") processes personal data in connection with our website, communications, and the services we provide ("Services"). We are committed to processing personal data responsibly and in accordance with applicable data protection legislation, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Turkish Law on the Protection of Personal Data No. 6698 (KVKK).

2. Scope

This Notice applies to personal data processed by us in our capacity as a data controller. It does not extend to third-party websites or services which you may access via links from our Site; such third parties operate under their own privacy policies.

3. Changes to This Notice

We may update this Privacy Notice from time to time. Any amendments shall be reflected by an updated "Last Updated" date. We encourage you to review this Notice periodically.

4. About Us

DifferentGuys Studio is a creative technology studio registered in the United Kingdom and Türkiye. The Site is hosted by Squarespace, Inc. Depending on the nature of your engagement with us, DifferentGuys Studio may act as a data controller (where we determine the purposes and means of processing) or as a data processor (where we process personal data on behalf of our clients in accordance with their instructions).

5. How to Contact Us

All enquiries relating to data protection should be directed to: hello@differentguys.studio

6. Personal Data We Collect

Depending on the nature of your interaction with us, we may process the following categories of personal data:

•       Identity and Contact Data: name, email address, company name, job title (where you provide this via email correspondence)

•       Correspondence Data: emails and messages you send to us, meeting notes, preferences you share

•       Technical Data: IP address, device and browser information, approximate location (e.g., country/city), server logs — collected automatically by our hosting provider (Squarespace)

•       Usage Data: pages viewed, session duration, referring website — collected via Squarespace Analytics

•       Business/Transaction Data: invoices, billing details, payment status (where applicable in the context of our Services)

We do not intentionally collect special category data (sensitive personal data) unless it is necessary for a specific engagement and appropriate lawful safeguards are in place.

7. How We Collect Personal Data

We collect personal data through the following means:

•       directly from you (via email correspondence or during meetings);

•       automatically via cookies and analytics tools provided by Squarespace;

•       from publicly available sources where relevant for legitimate business purposes.

8. Individuals Whose Data We Process

We may process personal data relating to: visitors to our Site; individuals who submit enquiries; clients, partners, and suppliers; and participants at events.

9. Purposes and Legal Bases for Processing

We process personal data for the following purposes, relying on the legal bases indicated:

•       to operate, secure, and improve our Site (legitimate interests);

•       to respond to enquiries and communicate with you (legitimate interests / steps prior to entering into a contract);

•       to provide and manage our Services (performance of a contract / legitimate interests);

•       to manage supplier relationships and fulfil administrative, accounting, and compliance obligations (performance of a contract / legal obligation); and

•       to send marketing communications where permitted (consent where required; otherwise legitimate interests with opt-out).

Where we deploy non-essential cookies, we shall rely on your consent as the lawful basis for processing.

10. Consequences of Not Providing Data

Where you decline to provide certain information, we may be unable to respond to your enquiry, provide our Services, or process an application.

11. Disclosure of Personal Data

We may disclose personal data to the following categories of recipients, subject to appropriate contractual protections:

•       our hosting provider, Squarespace, Inc. (which processes Technical and Usage Data on our behalf);

•       our clients (where necessary to deliver Services);

•       professional advisers (including lawyers and accountants) under obligations of confidentiality; and

•       regulatory authorities or law enforcement agencies where required by law.

12. International Data Transfers

Your personal data may be processed in countries outside your region of residence. In particular, our Site is hosted by Squarespace, Inc., which operates servers in the United States. Data may also be transferred between the United Kingdom and Türkiye in connection with our business operations.

Where such transfers occur, we shall ensure that appropriate safeguards are in place to protect your personal data:

•       For transfers from the UK: We rely on Standard Contractual Clauses (SCCs), UK International Data Transfer Agreements, or other lawful transfer mechanisms approved under UK GDPR.

•       For transfers from Türkiye: We rely on your explicit consent or ensure that the recipient country provides adequate protection or that appropriate contractual safeguards are in place, in accordance with KVKK requirements.

For more information on how Squarespace handles data transfers, please refer to Squarespace's Privacy Policy at www.squarespace.com/privacy.

13. Data Security

We implement appropriate administrative, technical, and organisational measures designed to protect personal data against unauthorised access, loss, destruction, or alteration.

14. Data Retention

We shall retain personal data only for so long as is necessary to fulfil the purposes for which it was collected, after which it shall be securely deleted or anonymised, unless a longer retention period is required by law or necessary for the establishment, exercise, or defence of legal claims.

15. Your Rights

Subject to applicable law, you may have certain rights in relation to your personal data. Under UK GDPR, these include the right to: access your personal data; request rectification of inaccurate data; request erasure; restrict processing; object to processing; and request data portability.

Under Turkish law (KVKK Article 11), you have the right to: learn whether your personal data is being processed; request information about processing; learn the purpose of processing and whether data is used accordingly; know the third parties to whom data is transferred; request rectification of incomplete or inaccurate data; request erasure or destruction; request notification of rectification or erasure to third parties; object to adverse results arising from automated analysis; and seek compensation for damages arising from unlawful processing.

To exercise any of these rights, please direct your request to: hello@differentguys.studio .We may require verification of your identity before processing such requests.

16. Marketing Communications

You may opt out of receiving marketing communications at any time by contacting us at: hello@differentguys.studio.

17. Children's Privacy

Our Site is not directed at individuals under the age of eighteen (18), and we do not knowingly collect personal data from minors.