Privacy Policy

Last updated - March 2026. - At Breakroom, we are committed to keeping your personal data safe and secure and handling it in accordance with our legal obligations.

1. INTRODUCTION

This Privacy Notice provides details of how we collect and process your personal data through the use of our website and platform, as well as how we process your personal data if you become a client or supplier.

By providing us with your data, you warrant to us that you are over 18 years of age.

Sine Wave Entertainment Limited is the data controller, and we are responsible for your personal data (referred to as “we”, “us” or “our” in this Privacy Notice).

We have appointed a Data Privacy Manager who is responsible for overseeing privacy and data protection matters within our organisation on a voluntary basis. We have assessed our processing activities and determined that we are not required to appoint a formal Data Protection Officer (DPO) under UK GDPR. If you have any questions about this Privacy Notice, please contact the Data Privacy Manager using the details below:

Full name of legal entity: Sine Wave Entertainment Limited
Company Number: 05894627
ICO Registration Number: ZB119685
Registered Address: Landmark, 2 Portman Street, London W1H 6DU
Email: gdpr@sinewavecompany.com

It is very important that the information we hold about you is accurate and up-to-date. Please let us know if your personal information changes at any time by emailing us at: gdpr@sinewavecompany.com

Where we process the personal data of individuals located in the European Economic Area (EEA) in connection with our services, we also comply with the EU General Data Protection Regulation (EU GDPR). In accordance with Article 27 of the EU GDPR, we have appointed an EU representative. If you are located in the EEA and wish to exercise your rights or raise a concern under EU GDPR, you may contact our EU representative using the details below:

Representative: Rickert Rechtsanwaltsgesellschaft mbH
Registered Address:
Colmantstraße 15, 53115 Bonn, Germany
Email:
art-27-rep-sinewave@rickert.law

2. WHAT DATA WE COLLECT ABOUT YOU, FOR WHAT PURPOSE, AND ON WHAT GROUNDS WE PROCESS IT

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process the following categories of personal data about you:

  • Communication Data that includes any communications you send to us—whether that be through the contact form on our website, through email, text, social media messaging, social media posting, becoming a client or supplier, or any other form of communication you send to us. We process this data for the purposes of communicating with you, for record keeping, and for the establishment, pursuance, or defence of legal claims. Our lawful ground for this processing is our legitimate interests, which in this case are to reply to communications sent to us, to keep records, and to establish, pursue, or defend legal claims.

  • Customer and Supplier Data that includes data relating to any purchases of goods and/or services—such as your name, title, billing address, delivery address, email address, phone number, contact details, purchase details, bank details, and bank or credit card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contractWe will direct any questions or rights requests you may send us as required under our customer agreements.

  • User Data that includes data about how you use our website and any online services, together with any data that you post for publication on our website or through our online services. We process this data to operate our website, ensure relevant content is provided to you, maintain the security of our website, keep backups of our website and/or databases, and to enable publication and administration of our website, online services, and business. Our lawful ground for this processing is our legitimate interests, which in this case are to enable us to properly administer our website and operate our business.

  • Technical Data that includes data about your use of our website and online services—such as your IP address, login data, browser details, page visit length, page views and navigation paths, details about the frequency of your visits, time zone settings, and other technology on the devices you use to access our website. The source of this data is our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you, and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests, which in this case are to enable us to properly administer our website and our business, grow our business, and determine our marketing strategy.

  • Marketing Data that includes data about your preferences in receiving marketing from us and our third parties, and your communication preferences. We process this data to enable you to partake in our promotions, deliver relevant website content and advertisements to you, and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests, which in this case are to study how customers use our products/services, develop those products and services, grow our business, and determine our marketing strategy.

  • We may use Customer Data, User Data, Technical Data, and Marketing Data to deliver relevant website content and advertisements to you, and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is our legitimate interests, which are to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely, to grow our business).

Sensitive Data
We do not collect any sensitive data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information, and genetic and biometric data. We do not collect any information about criminal convictions and offences.

When we are required to collect personal data by law, or under the terms of the contract between us, and you do not provide that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you do not provide the requested data, we may have to cancel a product or service you have ordered. If we do, we will notify you at the time.

We will only use your personal data for the purpose for which it was collected, or for a reasonably compatible purpose if necessary. For more information, please email us at gdpr@sinewavecompany.com. In cases where we need to use your personal data for an unrelated purpose, we will notify you and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

We do not carry out automated decision-making or any type of automated profiling.

3. HOW WE COLLECT YOUR PERSONAL DATA

We may collect personal data when you provide it directly to us (for example, by filling in forms on our website or by sending us emails). We may automatically collect certain data as you use our website through the use of cookies and similar technologies. Please see our Cookie Policy for more details.

We may receive data from third parties based outside the UK, including providers of technical, payment, and delivery services. For example, this may include analytics and search information providers such as Google and advertising networks such as Facebook.

4. MARKETING COMMUNICATIONS

Our lawful ground for processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely, to grow our business).

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications if (i) you made a purchase or asked for information about our goods or services, or (ii) you agreed to receive marketing communications and, in each case, you have not since opted out of receiving such communications. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.

Before we share your personal data with any third party for their own marketing purposes, we will obtain your express consent.

You can ask us or third parties to stop sending marketing communications at any time by either (a) logging on to the website or platform and checking or unchecking the relevant boxes to adjust your marketing preferences, or (b) following the opt-out links on any marketing message sent to you. You can also email us at: gdpr@sinewavecompany.com

If you opt out of receiving marketing communications, this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations, etc.

5. DISCLOSURES OF YOUR PERSONAL DATA

In the course of doing business, we may have to share your personal data with the parties set out below:

  • Other companies (including within our group) that provide services to us.

  • Service providers that offer IT and system administration services.

  • Professional advisers, including lawyers, bankers, auditors, and insurers.

  • Government bodies that require us to report processing activities.

  • Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and treat it in accordance with the law. We only allow these third parties to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We share your personal data within our group of companies, which may involve transferring your data outside the UK. Some of our third-party suppliers may also transfer or store information outside the UK to fulfill our contractual obligations and provide services on our behalf.

We are subject to the provisions of the UK General Data Protection Regulation (UK GDPR), which protects your personal data. Where we transfer your data to third parties outside the UK, we will ensure that certain safeguards are in place to provide a similar degree of security for your personal data. As such:

  • We may transfer your personal data to countries that United Kingdom regulatory authorities have approved as providing an adequate level of protection for personal data; or

  • If we use US-based providers that are part of the UK regulator-approved privacy framework, we may transfer data to them, as they have equivalent safeguards in place; or

  • Where we use certain service providers who are established outside the UK, we may use specific contracts or codes of conduct or certification mechanisms approved by the ICO which give personal data the same protection it has in the UK.

If none of the above safeguards are available, we may request your explicit consent for the specific transfer. You will have the right to withdraw this consent at any time.

Where we process the personal data of individuals located outside the UK and EEA, we aim to comply with any applicable local data protection requirements in those jurisdictions.

7. DATA SECURITY

We have security measures in place to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know. They will only process your personal data on our instructions and are required to keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulators of a breach if we are legally required to do so.

8. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including satisfying any legal, accounting, or reporting requirements.

When establishing data retention timelines, we consider the amount, nature, and sensitivity of the data; the potential risk of harm from unauthorised use or disclosure; the processing purposes and whether these can be achieved by other means; and applicable legal requirements.

For tax purposes, we are legally required to keep basic information about our clients and suppliers (including contact, identity, financial, and transaction data) for six years after they stop being clients or suppliers.

In some circumstances, we may anonymise your personal data for research or statistical purposes. In these cases, we may use this information indefinitely without further notice to you.

Full details of our retention periods are set out in our Data Retention Policy, which is available on request by emailing us at: gdpr@sinewavecompany.com.

11. COOKIES

You can set your browser to refuse all or some cookies, or to alert you when websites set or access them. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or fail to function properly. For more information about the cookies we use, please see our Cookie Policy.

Last updated March 2026.