Privacy Policy

Last updated: 12/08/2025

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:

What this policy applies to

This privacy policy relates to your use of our website only.

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.

Personal data we collect about you

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:

  • your name, address and contact information, including email address and telephone number and company details
  • any shipping addresses specified for your order
  • your billing information, transaction and payment card or other payment method information
  • details of any information, feedback or other matters you give to us by phone, email, post or via social media
  • your account details, such as username and login details
  • your activities on, and use of, our website
  • information about the services we provide to you
  • your contact history, purchase history and saved items
  • information about how you use our website and technology systems
  • your responses to surveys, competitions and promotions

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.

How your personal data is collected

We collect personal data from you:

  • directly, when you enter or send us information, such as when you register with us, contact us (including via email), send us feedback, purchase products or services via our website, post material to our website and complete customer surveys or participate in competitions via our website; and
  • indirectly, such as your browsing activity while on our website; we will usually collect information indirectly using the technologies explained in the section on ‘Cookies and other tracking technologies’ below.

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

  • where you have given consent
  • to comply with our legal and regulatory obligations
  • for the performance of a contract with you or to take steps at your request before entering into a contract, or
  • for our legitimate interests or those of a third party

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 list below explains what we use your personal data for and why.

  • Creating and managing your account with us

    • Reason: to perform our contract with you or to take steps at your request before entering into a contract.

  • Providing services to you
    — Reason: to perform our contract with you or to take steps at your request before entering into a contract.

  • Identity checks and fraud prevention
    — Reason: our legitimate interests (to minimise fraud that could be damaging for you and/or us).

  • Enforcing legal rights / handling legal proceedings
    — Reason: either to comply with legal and regulatory obligations, or (in other cases) our legitimate interests (to protect our business, interests and rights).

  • Customising our website and its content to your preferences
    — Reason: either your consent (see Cookies and other tracking technologies); or our legitimate interests (to deliver the best service efficiently). You may withdraw consent at any time.

  • Analytics on how you use our website
    — Reason: either your consent (see Cookies and other tracking technologies); or our legitimate interests (to improve our service efficiently). You may withdraw consent at any time.

  • Payment processing
    — Reason: cookies are required for our payment processor (Stripe — link: Stripe). These cannot be opted out of for payments.

  • Service communications (non‑marketing)
    — Reason: to comply with legal and regulatory obligations or, in other cases, our legitimate interests (to deliver the best service efficiently).

  • Security of systems and data
    — Reason: to comply with legal and regulatory obligations and, beyond those obligations, our legitimate interests (to ensure security).

  • Statistical analysis
    — Reason: our legitimate interests (to deliver the best service efficiently).

  • Updating and enhancing customer records
    — Reason: to perform our contract with you or take steps at your request; to comply with legal and regulatory obligations; or our legitimate interests (e.g. keeping in touch about existing orders and new products).

  • Compliance disclosures and record‑keeping (e.g., evidence of consents)
    — Reason: to comply with legal and regulatory obligations.

  • Marketing to existing and former customers
    — Reason: our legitimate interests (to promote our business to existing and former customers). See Marketing.

  • Sharing data in connection with significant corporate transactions or restructuring
    — Reason: either to comply with legal and regulatory obligations or our legitimate interests (to protect, realise or grow business value).

How and why we use your personal data — more detail

More details about how we use your personal data and why are set out below:

  • Purpose: Communications with you not related to marketing (e.g., changes to terms/policies or to products/important notices).

    • Processing operation: Addressing and sending communications as required by data protection laws (UK GDPR/Data Protection Act 2018; EU GDPR).
    • Lawful basis (UK/EU GDPR): Compliance with a legal obligation (Article 6(1)(b)).
    • Data involved: Name, address and contact information (including email, phone) and company details; account details (username).

  • Purpose: Communications about changes to terms/policies or products/important notices (where not covered above).

    • Processing operation: Addressing and sending communications.
    • Lawful basis (UK/EU GDPR): Our legitimate interests (Article 6(1)(f): to be as efficient as possible in delivering service).
    • Data involved: Name, address and contact information (including email, phone) and company details; account details (username).

Special category personal data

We do not collect special category personal data.

Sharing

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.

Marketing

We will use your personal data to send you updates (by email, 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.

Who we share your personal data with

We routinely share personal data with:

  • third parties we use to help deliver our services to you, e.g. payment service providers, warehouses and delivery companies
  • other third parties we use to help us run our business, e.g. website hosts and website analytics providers
  • Field Foundry Ltd (when you have given us permission to do so) — link to company site: Field Foundry Ltd

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:

  • our and their external auditors (bound by confidentiality obligations)
  • our and their professional advisors (such as lawyers and other advisors) (bound by confidentiality obligations)
  • law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
  • other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring—usually, information will be anonymised but this may not always be possible. The recipient will be bound by confidentiality obligations.

Who we share your personal data with — in more detail

  • Recipient: Field Foundry Ltd — a company incorporated in England (number 16292596), registered office: Qmb Innovation Centre Suite 7, Lab 2 - First Floor, 42 New Road, London, England, E1 2AX — link: https://fieldfoundry.com/

    • Use of data: Provide services to Full Circle Labs customers (only with customer permission).
    • Personal data shared: Name, email address.

  • Recipient: Simpler Postage Ltd — a company incorporated in England (number 11514195), registered office: First Floor, Templeback, 10 Temple Back, Bristol, United Kingdom, BS1 6FL — link: https://www.easypost.com/

    • Use of data: Generate shipping labels.
    • Personal data shared: Name, shipping address, phone number.

  • Recipient: Stripe Payments UK Ltd — a company incorporated in England (number 08480771), registered office: 9th Floor, 107 Cheapside, London, EC2V 6DN — link: https://stripe.com/

    • Use of data: Process card payments; detect and prevent fraud.
    • Personal data shared: N/A.

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

How long your personal data will be kept

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.

Transferring your personal data out of the UK and EEA

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 and EEA laws designed to ensure the privacy of your personal data.

We will transfer your personal data to:

  • our service providers located outside the UK in the USA

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:

  • UK: the UK government has decided the particular country ensures an adequate level of protection of personal data (an adequacy regulation) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here. We rely on adequacy regulations for transfers to the following countries: United States.
  • EEA: the European Commission has decided that the particular country ensures an adequate level of protection of personal data (an adequacy decision) further to Article 45 of the EU GDPR. A list of countries is available here. We rely on adequacy decisions for transfers to the following countries: United Kingdom, United States.
  • there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
  • a specific exception applies under relevant data protection law.

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.

Transferring your personal data out of the UK — in more detail

  • Recipient country: USA

    • Recipient: Stripe Payments — Stripe
    • Use: Process card payments; detect and prevent fraud.
    • Lawful safeguard: Adequacy regulation (paragraph 5(1)(a) of Part 3 of Schedule 21 to the Data Protection Act 2018).

  • Recipient country: USA

    • Recipient: Simpler Postage — Simpler Postage
    • Use: Generate shipping labels.
    • Lawful safeguard: Adequacy regulation (paragraph 5(1)(a) of Part 3 of Schedule 21 to the Data Protection Act 2018).

Transferring your personal data out of the EEA — in more detail

  • Recipient country: USA

    • Recipient: Stripe Payments — Stripe
    • Use: Process card payments; detect and prevent fraud.
    • Lawful safeguard: Adequacy regulation (paragraph 5(1)(a) of Part 3 of Schedule 21 to the Data Protection Act 2018).

  • Recipient country: USA

    • Recipient: Simpler Postage — Simpler Postage
    • Use: Generate shipping labels.
    • Lawful safeguard: Adequacy regulation (paragraph 5(1)(a) of Part 3 of Schedule 21 to the Data Protection Act 2018).

If you would like further information about data transferred outside the UK/EEA, please contact us (see ‘How to contact us’ below).

Cookies and other tracking technologies

A cookie is a small text file which is placed onto your device (e.g. 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 — link to provider: Stripe.

The cookies that we need are essential to provide our card payment services and cannot be opted out of.

Your rights

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 (rectification) — The right to require us to correct any mistakes in your personal data.
  • Erasure (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 (e.g. where we use it for our legitimate interests unless there are compelling legitimate grounds or it’s required for 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.
  • Right to withdraw consents — If you have provided us with consent to use your personal data, you can withdraw that consent at any time by contacting us (see ‘How to contact us’). 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:

  • provide enough information to identify yourself (e.g. your full name, address and customer or matter reference number) and any additional identity information we may reasonably request from you; and
  • let us know which right(s) you want to exercise and the information to which your request relates.

Keeping your personal data secure

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.

How to complain

Please contact us if you have any queries or concerns about 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:

Changes to this privacy policy

We may change this privacy policy from time to time — when we make significant changes we will take steps to inform you, for example by including a prominent link to a description of those changes on our website for a reasonable period or by other means, such as email.

How to contact us

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 a right under data protection law or to make a complaint.

Our contact details
Venture X White City, 1 Ariel Way, London, W12 7SL
Email: contact@fullcirclelabs.bio

Individuals in the EEA

Individuals within the EEA can contact us directly (see above).