Privacy Policy

1. What does this Privacy Policy refer to?

This privacy policy (hereinafter referred to as the Privacy Policy) defines the basic terms and conditions of personal data processing, which must be observed by all users of the (hereinafter referred to as the Website), recipients of the services of Avia Solutions Group Arena, JSC (hereinafter referred to as the Arena), persons who have made active actions on Twinsbet Arena’s social media accounts, persons who have consented to receive Twinsbet Arena’s promotional materials, applicants participating in Twinsbet Arena’s recruitment procedures, persons entering the premises of the building managed by Twinsbet Arena – Twinsbet Arena (hereinafter referred to as the Arena) according to the lists (hereinafter referred to as the Customers).

The Customer is deemed to have read and consented to the Privacy Policy when he/she visits the Website, purchases a service, visits Twinsbet Arena’s social media accounts, agrees to receive Twinsbet Arena’s direct marketing communications, applies for a job at Twinsbet Arena, attends the Arena’s events or off-site activities, according to pre-determined lists (e.g., employees of companies providing catering services). A Customer who disagrees with any provision of the Privacy Policy loses the right to visit the Website, use any of the services provided by Twinsbet Arena, apply for a job at Twinsbet Arena, be active on Twinsbet Arena’s social networking accounts, or access Twinsbet Arena by list.

2. About Twinsbet Arena

Avia Solutions Group Arena, JSC, entity code 126078441, registered office at Ozo g. 14, Vilnius, data about the company are collected and stored in the Vilnius Branch of the Register of Legal Entities of the Republic of Lithuania. Contacts for personal data issues: e-mail: [email protected]; telephone +370 6721 5621.

3. What is Personal Data?

Personal Data is any information collected by Twinsbet Arena 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 Twinsbet Arena collects about Customers for the purposes set out in this Privacy Policy or the Customer’s separate consent or agreement with Twinsbet Arena.

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

4. How Twinsbet Arena collects and uses Customer Personal Data

Twinsbet Arena 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 Twinsbet Arena collects personal data about:

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

Organising 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.


Direct marketing


3 years from receipt of consent


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

The basis for processing the data of customers attending events is consent

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

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.

6. Direct Marketing

For persons who have provided their contact details and expressed their wish to receive information about the goods and/or services offered by Twinsbet Arena, we will send offers regarding the provision of services or sale of goods by Twinsbet Arena, newsletters and other promotional materials, ask for their opinion on the services provided, and inform them about Twinsbet Arena’s news and the procedure for providing the services by electronic means of communication (email or SMS).

For the purpose of direct marketing, Twinsbet Arena will process the following personal data about you: email.

Your data will be used for the purpose of direct marketing for 3 years after consent has been obtained and then deleted.

Unless you are our Customer and have objected to receiving direct marketing communications from Twinsbet Arena, we will send you communications about goods or services that are similar to the services or goods you are purchasing. We will give you the opportunity to opt-out of receiving such communications.

You have the right to opt-out of receiving direct marketing communications at any time by contacting us at [email protected].
If you are 16 years of age, you can give your own consent to receive direct marketing communications.
Your email is provided to the social media network Facebook for the purpose of displaying advertisements from Twinsbet Arena.

7. Contact Us

The website provides a number of ways in which you can contact the Twinsbet Arena. 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 in order 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 Twinsbet Arena services on the Website if you are 16 years old. Any information you provide to Twinsbet Arena 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.

8.1. 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 Twinsbet Arena’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 Twinsbet Arena to recognise and count visitors to the website, as well as track how visitors move around the Website as they use it. This helps Twinsbet Arena 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 Twinsbet Arena 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 title

Purpose of processing

Moment of creation

Period of validity

Nature of the cookie (essential, analytical, functional)

Data used

Additional information cookie / laravel_session

User session ID

Entering a page

2 hours


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) cookie / remember_82e5d2c56



A cookie created by the website system that identifies the session of the active user

By visiting the website

5 years


Randomly generated number cookie / XSRF-TOKEN

Improving the browsing experience and being used to protect your website from malicious bots

By visiting the website

2 hours


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. 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


{0.1} 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




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.


Description of the cookie

More information

Tawk. This is a cookie used for real-time chat functionality.

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.

Instagram cookies are used to implement the functionality of displaying information with certain activity-related keywords.

YouTube cookies are used to implement the functionality of displaying information with certain keywords related to the activity.

8.2. Third Party Services

(a) Each time a Customer visits the Website, Twinsbet Arena 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 Twinsbet Arena could improve it. Twinsbet Arena 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

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;

(b) on Instagram, whose privacy notice is available at

(c) YouTube, whose privacy notice is available at;

(d) LinkedIn, whose privacy notice is available at

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 Twinsbet Arena’s social media accounts and websites with your consent. We undertake not to violate your honour and dignity by using such photographs.

Media representatives may only publish your photographs in accordance with their own legal requirements, but Twinsbet Arena 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 Twinsbet Arena, 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. Twinsbet Arena may take photographs and videos during mass events and/or at events organised by Twinsbet Arena, and these activities may result in your image being captured in photographs and/or videos, which may be used by Twinsbet Arena solely for the purposes of publicity to inform the public about the event and/or events that have been held.

11. Video Surveillance

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

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 on the basis of 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.

12. 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 Twinsbet Arena 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 Twinsbet Arena’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 organisation.
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’.

13. 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.

14. Security of your Personal Data

Your personal data will be processed in accordance with the General Data Protection Regulation, the Law on Legal Protection of Personal Data of the Republic of Lithuania and other legal requirements. When processing your personal data, we implement organisational and technical measures to ensure the protection of personal data against accidental or unlawful destruction, alteration, disclosure, as well as against any other unlawful processing.

15. Your Rights

This section provides information about the rights you have in relation to our processing of your personal data and when you can exercise these rights. If you would like more information about your rights or to exercise them, please contact us at the following email address: [email protected].

15.1 Right to Withdraw Consent

If you have given us your explicit consent to the processing of your data, you can withdraw it at any time.

15.2 Right of Access to your Personal Data

We want you to fully understand how we use your personal data so that you do not experience any inconvenience. You can contact us at any time to enquire whether we are processing any of your personal data. If we store or use your personal data in any way, you have the right to access it. To do so, please submit a written request to us at the following email address: [email protected], confirming your identity; please observe the principles of fairness and reasonableness when making such a request. We will respond within 1 month of receiving your request.

15.3. Right to Request Further Information

We hope that you will understand that discussing all possible ways of collecting and using personal data is very complex. We endeavour to provide as clear and comprehensive information as possible and we undertake to update this Privacy Policy as and when the use of personal data changes. However, if you have any questions about our use of your personal data, we will be happy to answer them or provide you with any additional information we may disclose. If you have any specific questions or do not understand the information provided, please contact us.

15.4 Additional Rights

Below you will find information about additional rights that you may have, which you can exercise by following the procedures described below.

(a) You have the right to ask us to correct any inaccuracies in the data we hold. In this case, we may ask you to confirm the corrected information.

(b) You have the right to ask us to erase your personal data. Please note that we will only be able to comply with such a request if:

  • Your personal data is no longer necessary for the purposes for which it was collected (e. g. we need your personal data in order to respond to your emails).
  • We are prohibited by law from collecting, storing or using personal data.
  • Your personal data is not necessary for the establishment, exercise or defence of a legal claim, e. g. in legal proceedings.

(c) You have the right to ask us to restrict or not process your personal data:

  • The period of time necessary to verify the accuracy of your personal data when you make a complaint about the accuracy of the data.
  • Where our collection, storage or use of your personal data is unlawful, but you choose not to request erasure.
  • Where we no longer need your personal data, but you need it to establish, exercise or defend a legal claim.
  • The period necessary to determine whether we have an overriding legal basis to continue processing your personal data if you have exercised your right to object to the processing of personal data.

(d) You have the right to the transfer of the data we have received from you with your consent or for the purposes of concluding an agreement. If you exercise this right, we will transfer a copy of the data you have provided to upon your request.

(e) You have the right to object to our use of your personal data in the following cases:

  • Where we use such data to further our legitimate interests, but we have no overriding legal basis for continuing to use your personal data; or
  • At any time when we use your personal data to send newsletters or for direct marketing purposes. In this case, the data will no longer be used for these purposes but may be used for other legitimate purposes.

16. Complaints

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]).

17. 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.

18. 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.