https://www.fullcirclelabs.bio (our website) is provided by Full Circle Labs Limited (‘we’, ‘our’ or ‘us’). We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals in the European Economic Area (EEA).Given the nature of our website, we do not expect to collect the personal data of anyone under 13 years old. If you are aware that any personal data of anyone under 13 years old has been shared with our website please let us know so that we can delete that data. This privacy policy is divided into the following sections:
This privacy policy relates to your use of our websiteonly. Throughout our website we may link to other websites owned and operated by certain trusted third parties to make additional products and services available to you. Those third-party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third-party websites, please consult their privacy policies as appropriate.
The personal data we collect about you depends on the particular activities carried out through our website. We will collect and use the following personal data about you:
You must provide this personal data to use our website and the services on it unless we tell you that you have a choice. We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
We collect personal data from you:
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The table below explains what we use your personal data for and why.
What we use your personal data for
Our reasons
Creating and managing your account with us
To perform our contract with you or to take steps at your request before entering into a contract
Providing services to you
To perform our contract with you or to take steps at your request before entering into a contract
Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us
For our legitimate interests, i.e. to minimise fraud that could be damaging for you and/or us
Enforcing legal rights or defend or undertake legal proceedings
Depending on the circumstances:
Customising our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website
Depending on the circumstances:
If you have provided such a consent you may withdraw it at any time by letting us know (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn)
Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended
Depending on the circumstances:
If you have provided such a consent you may withdraw it at any time by letting us know (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn)
Payment Processing
We use ‘Cookies’ to process payments. You cannot opt out of using ‘Cookies’ from our payment processor (‘Stripe’).
Communications with you not related to marketing, including about changes to our terms or policies or changes to the services or other important notices
Depending on the circumstances:
Protecting the security of systems and data used to provide the services
To comply with our legal and regulatory obligationsWe may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
Statistical analysis to help us understand our customer base
For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price
Updating and enhancing customer records
Depending on the circumstances:
Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, eg to record and demonstrate evidence of your consents where relevant.
To comply with our legal and regulatory obligations
Marketing our services to existing and former customers
For our legitimate interests, ie to promote our business to existing and former customers. See ‘Marketing’ below for further information
To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency
In such cases information will be anonymised where possible and only shared where necessary
Depending on the circumstances:
More details about how we use your personal data and whyare set out in the table below:
We do not collect special category personal data.
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
We will use your personal data to send you updates (byemail, text message, telephone or post) about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business. We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
We routinely share personal data with:
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on Field Foundry Ltd to ensure they can only use your personal data to provide services to us and to you. We or the third parties mentioned above occasionally also share personal data with:
More details about who we share your personal data withand why are set out in the table below:
Recipient
Processing operation (use) by recipient
Relevant categories of personal data transferred to recipient
Field Foundry Ltd — a company incorporated in England with registered number 16292596, whose registered office is at Qmb Innovation Centre Suite 7, Lab 2 - First Floor, 42 New Road, London, England, E1 2AX
Uses data to provide services to Full Circle Labs customers (only with customer permission)
Name, email address
Simpler Postage Ltd — a company incorporated in England with registered number 11514195, whose registered office is at First Floor, Templeback, 10 Temple Back, Bristol, United Kingdom, BS1 6FL
Generate shipping labels
Name, shipping address, phone number
Stripe Payments UK Ltd — a company incorporated in England with registered number 08480771, whose registered office is at 9th Floor, 107 Cheapside, London, EC2V 6DN
Process card payments, detect and prevent fraud
NA
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
We will not keep your personal data for longer than we need it for the purpose for which it is used. For example, If you stop using your account we will delete or anonymise your account data after 7 years.
The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy. It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK andEEA laws designed to ensure the privacy of your personal data. We will transfer your personal data to:
As we are based in the UK we will also transfer your personal data from the EEA to the UK.
Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:
Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.
Where we transfer your personal data outside the EEA we do so on the basis of an adequacy decision. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law and reflected in an update to this policy.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.
More details about the countries outside the UK to which your personal data is transferred are set out in the table below:
Recipient country
Recipient
Processing operation (use)by recipient
Lawful safeguard
USA
Stripe Payments
Process card payments, detect and prevent fraud
Adequacy regulation further to paragraph 5(1)(a) of Part 3 of Schedule 21 to the Data Protection Act 2018
USA
Simpler Postage
Generate shipping labels
Adequacy regulation further to paragraph5(1)(a) of Part 3 of Schedule 21 to the Data Protection Act 2018
More details about the countries outsidethe EEA to which your personal data is transferred are set out in the table below
Recipient country
Recipient
Processing operation (use) by recipient
Lawful safeguard
United Kingdom
Field Foundry Ltd — a company incorporated in England with registered number 16292596, whose registered office is at Qmb Innovation Centre Suite 7, Lab 2 - First Floor, 42 New Road, London, England, E1 2AX
Provide services to Full Circle Labs customers
Adequacy decision: Commission Implementing Regulation (EU) 2021/1772 of 28 June 2021 pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council on the adequate protection of personal data by the United Kingdom
United Kingdom
Full Circle Labs Ltd — a company incorporated in England with registered number 13948086, whose registered office is at Venture X White City, 1 Ariel Way, London, England, W12 7SL
Provide services to Full Circle Labs customers
Adequacy decision: Commission Implementing Regulation (EU) 2021/1772 of 28 June2021 pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council on the adequate protection of personal data by the United Kingdom
If you would like further information about data transferred outside the UK/EEA, please contact us (see ‘How to contact us’ below)
A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our website. We use cookies on our website. These help us to provide payment services using Stripe. The cookies that we needed are essential to provide our card payment services and cannot be opted out of.
You generally have the following rights, which you can usually exercise free of charge:
Access to a copy of your personal data
The right to be provided with a copy of your personal data.
Correction (also known as rectification)
The right to require us to correct any mistakes in your personal data.
Erasure (also known as the right to be forgotten)
The right to require us to delete your personal data—in certain situations.
Restriction of use
The right to require us to restrict use of your personal data in certain circumstances.
Data portability
The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.
To object to use
The right to object at any time to your personal data being used for direct marketing (including profiling); and in certain other situations to our continued use of your personal data (eg where we use your personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims.)
Not to be subject to decisions without human involvement
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. We do not make any such decisions based on data collected by our website.
The right to withdraw consents
If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any timeYou may withdraw consents by contacting us (see ‘How to contact us’ below). Withdrawing consent won’t affect prior lawful use.
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.
If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Please contact us if you have any queries or concernsabout our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with:
the Information Commissioner in the UK — Make a complaint to the ICOor by telephone: 0303 123 1113
We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you, for example via including a prominent link to a description of those changes on our website for a reasonable period or by other means, such as email.
Individuals in the UK
You can contact us by email if you have any questions about this privacy policy or the information we hold about you, to exercise aright under data protection law or to make a complaint. Our contact details are shown below:
Venture X White City, 1 Ariel Way, London, W12 7SL
Individuals in the EEA
Individuals within the EEA can contact us directly (see above).
