Privacy Policy

1. Who is this Privacy Policy for?

This Privacy Policy applies to all individuals who use the services of “Twinsbet” arenos and/or “Skonio dvelksmas” and/or “back stage EVENT STRATEGY,” are our business partners or seek to become them, visit our website or premises, submit inquiries to us, or otherwise interact with us (e.g., through social media), or apply for job vacancies. If you are an existing business partner, more detailed information on how we process your personal data may be provided in your contract with us. In certain cases, this Privacy Policy provides information about which of your personal data is processed, for what purpose, on what legal basis, and how long it is stored, as well as information on your rights as a data subject and other legally required information. This information is important, so we hope you read it carefully. By visiting our website and/or using the information and/or services provided there, you confirm that you have read and understood this Privacy Policy.

2. Data Controller. About the Company, “Company,” “Skonio dvelksmas,” and “back stage EVENT STRATEGY”

The Data Controller is Star Dome, UAB, legal entity code 126078441, registered office at Ozo g. 14, Vilnius, with company data collected and stored in the Vilnius branch of the Register of Legal Entities of the Republic of Lithuania (“Company” or “we”). Contact details for personal data matters: email [email protected]; phone +370 6721 5621.

 

“Company” is a trademark owned by the Company and refers to the operation and administration of the Arena located at Ozo g. 14, Vilnius (the “Arena”), including rental of Arena premises and organization of events held in the Arena.

 

“Skonio dvelksmas” is a trademark owned by the Company and refers to catering service activities.

 

“back stage EVENT STRATEGY” is a trademark owned by the Company, representing event strategy agency services.

 

3. What is Personal Data?

Personal Data is any information collected by the Company about the Customer which can be used to identify the Customer and is stored electronically or otherwise.

Personal data includes any information, including the Customer’s name, surname, address, IP address, email, telephone, and date of birth, which the Company collects about Customers for the purposes set out in this Privacy Policy or the Customer’s separate consent or agreement with the Company.

This data also includes personal information of Customers in the public domain, which the Company becomes aware of through the Customer’s contact with the Company via social media or through active actions on the Company’s social media accounts.

4. How the Company collects and uses Customer Personal Data

Company requires personal data of Customers which may be collected in the following ways. In this Privacy Policy, we set out what you can expect when Company collects personal data about:

• Persons who use Company’s services or purchase goods distributed by Company.
• Persons who agree to receive Company marketing material.
• Persons who participate in Company lotteries, games, and promotions.
• Persons who contact Company.
• Website visitors.
• Social media users who contact the Company via Twinsbet in any way.
• Social media accounts or active participation therein.
• Persons attending events at Company or accessing the Arena premises on the basis of lists.
• Applicants for the job.

5. Personal Data processed while providing Services

Purpose of processing	Personal data processed	Time limit for data processing	Basis for processing
Contracting, providing and selling services to customers and partners	The signatory’s position, name, surname, signature, email, and telephone, if the signatory is a natural person, in addition to his/her place of residence/address, date of birth, bank account details.	10 years after the conclusion of the contract, evidence of the fact of the conclusion of the contract and the information and accounting documents related to the conclusion of the contract, 5 years for another information	Fulfilment of the agreement (GDPR Art. 6(1)(b))
Organizing competitions, lotteries and games	Name, surname, date of birth, place of residence/address, telephone, and email.	3 months after all persons who have participated in the competitions, games or lotteries have collected their prizes.	Consent (GDPR Art. 6(1)(a))
Direct marketing	Email.	3 years from receipt of consent	Consent (GDPR Art. 6(1)(a))
Access to the Arena by visitor list	Name and surname.	1 week after the event	The basis for processing the data of catering and other service providers is the legitimate interest in the performance of the contract with the entity providing the services in the Arena (GDPR Art. 6(1)(f))
Protection of property and persons	Video recordings, date and time of recording, and location (Arena)	Video recordings shall be retained for 14 days, except in the cases referred to in the Policy where video recordings shall be retained for longer periods of time	Legitimate interest in protecting property and persons (GDPR Art. 6(1)(f))
Informing the public	Image as seen in a photograph, image and/or audio in a video, event, and date of event	3 years from the date of publication	Legitimate interest in capturing and using for representational purposes images of events taking place in the Arena (GDPR Art. 6(1)(f)).

6. Direct Marketing

For individuals who have provided their contact details and expressed a wish to receive information about the Company’s offered goods and/or services, we will send offers regarding the provision of the Company’s services or the sale of goods, as well as newsletters, via electronic communication channels (email).

The personal data processed for the purpose of sending newsletters (direct marketing), the legal basis for such processing, and the data retention period are specified in Section 5 of the Privacy Policy, “What personal data do we process and why?”. Your data will be used for direct marketing purposes for 3 years after your last login (active action) and will then be deleted.

You have the right to unsubscribe from direct marketing messages at any time by clicking “Unsubscribe” in the newsletter or by contacting us at [email protected].

If you are at least 16 years old, you may provide consent to receive direct marketing messages independently.

 

7. Contact Us

The website provides a number of ways in which you can contact the Company. We accept, review and respond to all messages ourselves. If you contact us by email, we will process the following data: your name and surname, email and the text of the correspondence.

Such data will be processed to prepare the performance of the agreement or to answer your questions. If you do not provide your contact details, it will not be possible to contact you.

Please note that the Website may also use email monitoring or blocking software and it is your responsibility to ensure that the emails you send do not contain illegal content.

Correspondence will be stored for 1 year from the date of receipt of the message, except for information for which other time limits are specified in the Privacy Policy or in legal acts.

Any personal data you provide when you interact with us is only used for the purposes set out above and view messages, as well as administer and manage communication flows. We undertake not to use your personal data in any publications in a way that could identify you without your explicit consent.

Please note that we may need to contact you by post, email or telephone. Please inform us immediately if your personal data changes.

8. Visitors to Websites

You can order the Company services on the Website if you are 16 years old. Any information you provide to Company when you become a registered Customer will be stored and protected with the Customer’s consent in accordance with the terms and conditions of the Privacy Policy.

If, in our reasonable opinion, you have breached any provision of our Privacy Policy, we have the right to refuse providing services.

• Cookies

A cookie is a small file made up of letters and numbers that we store on your browser or on your computer’s hard drive with your consent. We use different cookies for different purposes. Cookies also help us to distinguish you from other users of the Website, thus providing a more pleasant experience and allowing us to improve the Website.

Most browsers allow you to reject all cookies, while some browsers only allow you to reject third-party cookies. You can therefore take advantage of these options. However, please note that blocking all cookies will have a negative impact on the use of the Website and without cookies you will not be able to use all the services provided on the Website.

We use the following cookies, a detailed list of which can be found below.

(a) Strictly Necessary Cookies

These cookies are necessary for the Website to function. The data processed by these cookies is based on the proper performance of the agreement during the Customer’s visit to the Website and on Company’s ability to ensure the quality and security of the visit. These may include cookies that, for example, allow the Customer to log in and access secured areas of the Website, use the shopping cart function or other services.

(b) Analytical and/or Performance Cookies

These cookies allow Company to recognise and count visitors to the website, as well as track how visitors move around the Website as they use it. This helps Company to improve the performance of the website, for example, to ensure that users can easily find what they are searching for. The processing of the data collected by these cookies is based on the consent of Customers.

(c) Functional Cookies

These cookies are used to identify Customers when they return to the Website. This allows Company to provide content tailored to the needs of Customers and to remember information relevant to Customers. The processing of the data collected by these cookies is based on the consent of Customers.

Cookie/ Cookie title	Purpose of processing	Moment of creation	Period of validity	Nature of the cookie (essential, analytical, functional)	Data used	Additional information
twinsbetarena.lt cookie / laravel_session	User session ID	Entering a page	2 hours	essential	Randomly generated number	A cookie used to ensure the functionality of the page and maintain the user’s browsing session (e. g. to go back to the last place on the list)
twinsbetarena.lt cookie / remember_82e5d2c56 bdd0811 318f0cf078b78bfc	A cookie created by the website system that identifies the session of the active user	By visiting the website	5 years	functional	Randomly generated number
twinsbetarena.lt cookie / XSRF-TOKEN	Improving the browsing experience and being used to protect your website from malicious bots	By visiting the website	2 hours	essential	Randomly generated number	The cookie is regenerated for each request. This cookie is used for security purposes when the user makes a request to the server. The cookie helps the server to determine whether the user has sent the request from the website or from an external script.
twinsbetarena.lt cookie / landing_shown	Allows us to identify whether a user has seen the initial advertising window on a website so that it is not shown again.	After visiting the website, displaying the Landing promo page and closing it after by the visitor	24 hours	functional	{0.1}
twinsbetarena.lt cookie / Avia Solutions Group-cookies	Allows us to identify whether the user accepts the privacy policy and the cookies collected.	By clicking I agree to the privacy policy	365 days	essential	accepted

 

The second type of cookie is used to collect information to calculate attendance (collect statistical information), to provide content that is relevant to visitors’ interests, and to keep a record of their visit history. The Company does not use this type of cookies but it draws visitors’ attention to the fact that some of the Company’s partners may use this type of cookies, so if a visitor suspects that this type of cookie is being used without his/her consent, he/she should contact the specific partner of the Company.

Tool	Description of the cookie	More information
va.tawk.to	Tawk. This is a cookie used for real-time chat functionality.	https://www.tawk.to/privacy-policy/
Google Analytics	The information used includes information about visitor behaviour on the website, the effectiveness of marketing campaigns and technical device data of visitors. The result is statistical and does not identify personal details of visitors.	https://policies.google.com/technologies/cookies
Instagram	Instagram.com cookies are used to implement the functionality of displaying information with certain activity-related keywords.	http://instagram.com/legal/privacy/
YouTube	Youtube.com cookies are used to implement the functionality of displaying information with certain keywords related to the activity.	https://www.youtube.com/static?template=privacy_guidelines

• Third Party Services

(a) Each time a Customer visits the Website, Company collects information about the Customer’s use of the Website using Google Analytics, a third party software. For example, the Customer’s actions on the Website are recorded and patterns of behaviour are identified. This service is used to determine how many people visit the Website and different parts of the Website. The information collected helps us to find out how the Website is performing and how Company could improve it. Company does not identify Customers and does not allow Google Analytics to do so.

(b) The Website contains YouTube videos. The service provider YouTube controls all information collected when individuals view its content. YouTube’s privacy policy is available at https://www.google.co.uk/intl/en-GB/policies/privacy/.

9. Social Media

Any information you provide to us via social media (including messages, the use of the “Like” and “Follow” boxes, and other communications) is under the control of the social network manager.

The website contains links to our social media accounts. We currently have the following accounts:

(a) Facebook, whose privacy notice is available at https://www.facebook.com/privacy/explanation;

(b) on Instagram, whose privacy notice is available at http://instagram.com/legal/privacy/

(c) YouTube, whose privacy notice is available at https://www.youtube.com/static?template=privacy_guidelines;

(d) LinkedIn, whose privacy notice is available at https://www.linkedin.com/legal/privacy-policy.

We recommend that you read the privacy notices of third parties and contact these providers directly if you have any questions about how they use your personal data.

10. Participation in Arena Events

Your attendance and photo may be used to inform the public about Arena events. Photographs taken of you at Arena events may be published on Company’s social media accounts and websites with your consent. We undertake not to violate your honor and dignity by using such photographs.

Media representatives may only publish your photographs in accordance with their own legal requirements, but Company is not responsible for the actions of media representatives.

Photos will be published and kept for 3 years after the event, except for exceptions allowed by law.
It is important to note that although the event takes place at the Arena, in most cases the event is not organised by Company, but rather by event organisers, private companies and/or individuals. In this case, we always recommend that you check who the event organiser is and refer to their privacy policy, which should include information about your possible photography, filming and use of such material. Company may take photographs and videos during mass events and/or at events organised by Company, and these activities may result in your image being captured in photographs and/or videos, which may be used by Company solely for the purposes of publicity to inform the public about the event and/or events that have been held.

11. Video Surveillance

To protect the safety of you, other visitors and employees, as well as to protect the security of Company’s property and record and preserve evidence of incidents, i. e. damage to property, theft, unauthorized acts, injuries to employees, accidents, etc., we maintain a permanent video surveillance system in the Arena and its territories. During video surveillance, we collect, process and keep your personal data as set out in the table in Clause 5 of this Policy.

12. Participation in the Recruitment Process

We collect and process your CV and/or cover letter and/or any other information you provide for the purpose of participating in the recruitment process for the purpose of conducting the job selection based on your consent which you express to us or to the recruitment service provider by sending your CV.

If you do not provide us with your CV and/or cover letter, we will not be able to assess your suitability for the position.
In the event that you do not express your individual consent to the processing of your personal data after the end of the recruitment process, we undertake to delete and/or destroy your personal data within 5 working days after the successful applicant has signed the employment contract.

13. Disclosure of Data

We may disclose information about you to our employees, managers, agents, service providers or subcontractors as reasonably necessary for those purposes as set out in this Privacy Policy.

In addition, we may disclose information about you in the following cases:

• If we have to do it by law.
• To assert our rights or interests (including the provision of your personal data to third parties for the purpose of collecting debts owed to us).
• In connection with the intended sale of the Company business or part of its assets by disclosing your personal data to a potential buyer of the business or part of the business.
• The sale of Company’s operations or a substantial part of its assets to third parties.

Your personal data will not be transferred to a third country and/or an international organization. We do not provide your personal data to any third parties except as provided in this Privacy Policy.

The list of recipients or categories of recipients specified in the Privacy Policy is/are subject to change. Thus, if you wish to be informed about changes in the recipients of your personal data, please notify us by email to [email protected], indicating ‘I wish to be informed about changes in the recipients of my personal data, name, and surname’.

14. Third-Party Material and Third-Party Websites

Our Website may contain advertising from third parties. Such third parties are solely responsible for the content of such advertising and must ensure that it complies with all applicable laws and regulations.

You visit third-party websites at your own risk. We do not accept any direct or indirect responsibility for the content, accuracy of the information, opinions or quality of the goods and services offered by the third party.

Our information material may contain information that originates from third-party websites. Material taken from a third-party website will be acknowledged accordingly and may include a link to the original website. We neither accept any responsibility for any material published on a third-party website to which the Customer is directed for further information, nor for the use of personal data by such third party.

15. Security of your Personal Data

When processing personal data, we strictly comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (the “GDPR”), the Law on the Legal Protection of Personal Data of the Republic of Lithuania, the Law on Electronic Communications of the Republic of Lithuania, and other directly applicable legal acts governing personal data protection, as well as the instructions of competent authorities. When processing your personal data, we implement organizational and technical measures that ensure the protection of personal data against accidental or unlawful destruction, alteration, disclosure, and any other unlawful processing.

16. Your Rights

This section provides information about the rights you have in relation to our processing of your personal data and the circumstances in which you may exercise these rights.
You are guaranteed the following rights:

• the right to be informed about the processing of your personal data;
• the right of access to the personal data we process about you;
• the right to request rectification of the personal data we process;
• the right, in certain cases, to request the erasure (“right to be forgotten”) of your personal data;
• the right, in certain cases, to request restriction of the processing of your personal data;
• the right to object to the processing of your personal data where the processing is based on our legitimate interests. You have the right to object to such processing; however, if we have compelling legitimate grounds for the processing, we may continue processing your personal data without your consent. To exercise this right, please contact us at [email protected];
• the right to withdraw your consent at any time, where processing is based on consent;
• the right, in certain cases, to receive or transfer your personal data to another data controller (the right to data portability).

17. Where to submit a complaint?

If you believe that your rights as a personal data subject have been and/or may be violated, please contact us immediately with a complaint at email [email protected]. Once we have received your complaint, we undertake to contact you within the shortest possible period of time (not exceeding 30 days) to inform you of the progress of the investigation of the complaint and subsequently of the outcome.
If you are not satisfied with the results of the investigation, you can lodge a complaint with the supervisory authority, the State Data Protection Inspectorate (email: [email protected]).

18. Responsibility

You are responsible for ensuring that the data you provide to us is accurate, correct and complete. If there are any changes to the data you have provided, you must notify us immediately by email to [email protected]. In no event shall we be liable for any damage caused to you as a result of you providing incorrect or incomplete personal data or failing to inform us of any changes to such data.

19. Amendments to the Privacy Policy

We may update or change this Privacy Policy at any time. Such updated or amended Privacy Policy will be effective upon posting on our Website. You should check it from time to time to make sure that you are satisfied with the current version of this Privacy Policy.

Last updated on 1 October 2025.