Privatuma Politika

SIA “LIEPAJA MUSIC” PRIVACY POLICY

Effective from: 28 September 2026

SIA “Liepaja Music” (hereinafter – the Controller) is committed to protecting your personal data and privacy. The purpose of thisPrivacy Policy is to provide information on how personal data may be processed when visiting the Pegaza Pagalms website www.pegazapagalms.lv and using Pegaza Pagalms services, the purposes for which such data are processed, the legal basis for the processing, how long the data are retained, and your rights as adata subject.

When processing personal data, the Controller complies with the laws and regulations in force in the Republic of Latvia, Regulu (ES) 2016/679 (2016. gada 27. aprīlis) on the protection of natural persons with regard to the processing of personal data, and other applicable legislation in the field of personal data protection.

All terms used in this Privacy Policy shall have the meaning assigned to them under the General Data Protection Regulation.

1. CONTROLLER

The controller of personal data is:

SIA “Liepaja Music”
Registration No.: 52103085891
Registered address: O. Kalpaka iela 92-1, Liepāja, LV-3405, Latvia
Website: www.pegazapagalms.lv
E-mail: info@liepajamusic.lv
Telephone: +371 26 470 868
‍
Actual place of operation of the SIA “Liepaja Music” structural unit “Pegaza Pagalms”:
Kuršu iela 20, Liepāja, LV-3401, Latvia‍

2. COLLECTION AND PROCESSING OF PERSONAL DATA

The Controller may obtain personal data:

directly from the data subject, for example, when receiving an e-mail, telephone call or submission via the website contact form;
when making a reservation for an event, venue rental or other services;
when entering into and performing a contract;
when receiving information from cooperation partners, where there is a legal basis for doing so;
when visiting Pegaza Pagalms and its premises, where video surveillance is carried out;
during events organised by Pegaza Pagalms, when photographs or video recordings aretaken;
when using the website and related technologies, including cookies, where such technologies are used.

Personal data are processed only by authorised personsand by personal data processors engaged by the Controller where this is necessary for the Controller’s operations and the provision of services.

3. PURPOSES AND LEGAL BASIS FOR PERSONAL DATA PROCESSING

3.1. Communication

If you contact Pegaza Pagalms by e-mail, telephone or via the website contact form, we may process the name, e-mail address, telephone number and other information provided in your message in order to communicate effectively with you, answer questions, handle requests and provide information about Pegaza Pagalms services, events or venue rental.

3.2. Event and venuereservations

Pegaza Pagalms piedāvā telpu nomu korporatīviem, privātiem, izglītojošiem un kultūras pasākumiem, kā arī pasākumu organizēšanu Pegaza Pagalma teritorijā.

Lai organizētu telpu nomu un veiktu rezervāciju, sazinātos ar klientu, noslēgtu līgumu, kā arī nodrošinātu ar pakalpojumu saistīto administratīvo jautājumu risināšanu, saskaņā ar datu regulas 6. panta 1. punkta b) apakšpunktu, var tikt apstrādāts:

name and surname;
telephone number;
e-mail address;
information about the event or reservation;
information concerning representation of a legal entity, where applicable;
other information necessary for the provision of the service.

3.3. Payments andaccounting documents

Pursuant to Article 6(1)(c) of the GDPR, in order toprocess payments and fulfil accounting and tax obligations laid down by law, the Controller may process client and transaction information necessary forpreparing and retaining invoices, receipts, contracts and other accounting documents.

3.4. Information andmarketing communications

Pursuant to Article 6(1)(a) of the GDPR, if you have consented to receive Pegaza Pagalms news, information about events, special offers or other marketing information, your e-mail address may be used to send such communications.

The purpose of the processing is to provide information about events at Pegaza Pagalms, news, updates and offers.

‍Consent may be withdrawn at any time by using the unsubscribe option in the e-mail received or by contacting the Controller at info@liepajamusic.lv.

3.5. Photography andfilming during events

Pursuant to Article 6(1)(f) of the GDPR, photography and/or filming may take place during events organised at Pegaza Pagalms inorder to document the activities and events of the cultural venue and to create communication and marketing materials for Pegaza Pagalms.

Photographs and video materials may be published:

on the Pegaza Pagalms website;
on Pegaza Pagalms social media accounts;
through other communication channels of the Controller;
in information and publicity materials.

3.6. Video surveillance

Video surveillance may be carried out on the Pegaza Pagalms premises in order to protect persons and property, prevent or detect unlawful activities, and safeguard the legitimate interests of the Controller and third parties.

Pursuant to Article 6(1)(f) of the GDPR, a person’simage may be processed as a result of video surveillance.

Video surveillance recordings are retained for up to 7 days, except where a specific recording is required for the investigation of an incident, the protection oflegal rights or the resolution of a legal dispute.

4. RECIPIENTS OF PERSONAL DATA

Personal data may be disclosed to:

authorised employees of the Controller;
personal data processors engaged by the Controller;
IT, website maintenance and technical service providers;
accounting and legal service providers, where necessary;
service providers involved in organising events, to the extent necessary for the provision of the relevant service;
stateor municipal authorities, law enforcement authorities or other institutions where required or requested by applicable law.

The Controller does not disclose personal data tothird parties unless such disclosure is necessary for the provision of aservice, compliance with a legal obligation or the pursuit of the Controller’s legitimate interests.

5. TRANSFER OF PERSONAL DATA OUTSIDETHE EUROPEAN UNION AND THE EUROPEAN ECONOMIC AREA

Where the Controller uses service providers whose infrastructure or processing activities may be located outside the European Union or the European Economic Area (EU/EEA), the Controller ensures that personal data are transferred in accordance with Regulation (EU) 2016/679 (GDPR) and only where an appropriate legal basis and the necessary data protection safeguards are in place.

For its operations, Pegaza Pagalms uses digital services provided by third parties, including Zoho Mail, Google, Meta Platforms, Inc. and Canva. Depending on the service used and its functionality, personal data may be processed or stored outside the EU/EEA, including in the United States.

Where personal data are transferred to the United States, the Controller, insofar as applicable to the relevant service providerand processing activity, relies on the European Commission adequacy decision concerning the EU-U.S. Data Privacy Framework or other transfer mechanisms andappropriate safeguards provided for under the GDPR.

‍Google LLC is certified under the EU-U.S. Data Privacy Framework with regard to transfers of personal data from the European Economic Area to the United States. Meta Platforms, Inc. is certified under the EU-U.S. Data Privacy Framework with regard to the categories of personal data coveredby its certification.

Canva US Inc. has declared its adherence to the principles of the EU-U.S. Data Privacy Framework. Canva states that personal data may be processed in various countries, including the United States, andthat, where necessary, European Commission-approved Standard Contractual Clauses are also used for transfers of European users’ data.

6. RETENTION OF PERSONAL DATA

The Controller retains personal data only for as longas necessary for the relevant purpose of personal data processing or for as long as retention is required by applicable law.

Personal data processed on the basis of the data subject’s consent are retained until consent is withdrawn, unless another legal basis exists for continued processing.

Where personal data are necessary to protect the Controller’s rights or interests, they may be retained until the matter concerned has been finally resolved or the applicable limitation period has expired.

Type of personal data processing

Personal data processed

Purpose

Legal basis for personal data processing

Potential recipients of personal data

Data retention period

Communication with website visitors

E-mail address and other information provided by the person during communication

To answer questions, handle requests and communicate regarding Pegaza Pagalms activities, events and services

The Controller’s legitimate interest in ensuring effective communication with clients and interested persons (Article 6(1)(f) GDPR)

Authorised employees of SIA “Liepaja Music”; processors engaged by the Controller that provide e-mail, website and IT services

For as long as necessary to handle the relevant request and provide a response, but no longer than necessary to achieve the purpose of the processing

Processing of event and venue reservations

Name, surname, e-mail address, telephone number, information about the event or reservation and other data necessary for the provision of the service

To process event and venue reservations, communicate with the client, enter into a contract and provide the service

Entering into and performance of a contract (Article 6(1)(b) GDPR)

Authorised employees of SIA “Liepaja Music”; service providers involved in organising events; processors engaged by the Controller

Until the reservation/service has been completed and thereafter for as long as necessary to comply with legal requirements or protect the Controller’s legitimate interests

Processing of payments and accounting documents

Name, surname, legal entity details, payment information and other data required in accounting documents

Preparation and accounting of invoices, payments and other accounting documents

Compliance with a legal obligation (Article 6(1)(c) GDPR)

Accounting staff of SIA “Liepaja Music”; outsourced accountant; competent state authorities where required by law

In accordance with the retention periods for accounting and tax documents prescribed by law

Sending information and marketing communications

E-mail address, name (if provided) and information concerning consent to receive communications

To provide information about Pegaza Pagalms events, news, offers and updates

Consent of the data subject (Article 6(1)(a) GDPR)

Authorised employees of SIA “Liepaja Music”; e-mail/marketing service providers engaged by the Controller

Until consent is withdrawn. Consent may be withdrawn at any time by sending a withdrawal request from the registered e-mail address to info@liepajamusic.lv; this does not affect the lawfulness of processing carried out while the consent was valid.

Photography and filming during events

A person’s image, voice or other data captured in the material where the person is identifiable

Documentation of events, presentation of Pegaza Pagalms activities, publicity and marketing

The Controller’s legitimate interest in presenting and promoting Pegaza Pagalms activities (Article 6(1)(f) GDPR), where consent is not required in the particular circumstances

Authorised employees of SIA “Liepaja Music”; photographers and video operators; social media and website administrators; other processors engaged by the Controller

Published photo/video materials – for as long as they are required for Pegaza Pagalms communication, publicity or archival purposes. The need for continued retention is reviewed periodically; where the relevant purpose no longer exists, the materials are deleted unless another legal basis for retention applies. Unpublished materials – in accordance with the specific documentation purpose.

Video surveillance

A person’s image

To ensure the safety of persons and property and to prevent or detect unlawful activities

Legitimate interests of the Controller and third parties (Article 6(1)(f) GDPR)

Authorised employees of SIA “Liepaja Music”; video surveillance system maintenance provider; law enforcement authorities in cases provided for by law

Up to 7 days, except where a recording is required for the investigation of a specific incident or the protection of legal rights

Processing of submissions, proposals and complaints

Name, surname, e-mail address, telephone number, information included in the submission and other personal data voluntarily provided by the person

To review and assess a submission, proposal or complaint and provide a response

Compliance with a legal obligation (Article 6(1)(c) GDPR) or the Controller’s legitimate interests where no legal obligation applies in the particular case

Authorised employees of SIA “Liepaja Music”; processors engaged by the Controller; competent state or municipal authorities, where necessary

2 years after the submission has been reviewed and the information has been provided.

Questionnaires and registration for participation in an event

Name, surname, e-mail address, telephone number and other information necessary to arrange the reservation or participation in the relevant event

To arrange registration and reservations for participation in an event, maintain participant records and provide communications related to the event

Article 6(1)(b) GDPR – processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Authorised employees of SIA “Liepaja Music”; processors engaged by the Controller; competent state or municipal authorities, where necessary

Personal data are retained for up to 1 month after the event, unless applicable law or the specific relationship with the data subject requires a longer retention period

7. RIGHTS OF THE DATA SUBJECT

Under the GDPR, you have the right to:

receive information about the processing of your personal data;
request access to your personal data;
request rectification of inaccurate personal data;
request erasure of personal data in cases provided for by law;
request restriction of the processing of personal data in cases provided for by law;
object to the processing of personal data where the processing is based on the Controller’s legitimate interests;
where processing is based on consent, withdraw your consent at any time;
receive your personal data in a portable format in cases provided for by law;
not be subject to automated decision-making, including profiling, where Article 22 of the GDPR applies to the relevant processing.

To exercise your rights, you may submit a request tothe Controller by writing to info@liepajamusic.lv.

The Controller will assess the request and respond within the time limit prescribed by law.

8. LODGING A COMPLAINT

If you believe that the Controller processes your personal data in breach of applicable legal requirements, you have the right to contact the Controller first.

You also have the right to lodge a complaint with the supervisory authority:

‍Data State Inspectorate
Blaumaņa iela 11/13, Riga, LV-1011
Website: www.dvi.gov.lv

9. PERSONAL DATA SECURITY

The Controller implements appropriate technical and organisational measures to protect personal data against unauthorised or unlawful processing, accidental loss, destruction, damage or unauthorised access.

Access to personal data is granted only to persons who require such access in order to perform their employment or service-related duties.

10. AUTOMATED DECISION-MAKING ANDPROFILING

The Controller does not carry out automated decision-making, including profiling, which produces legal effects concerningthe data subject or similarly significantly affects the data subject.

If such processing is introduced in the future, the Controller will provide theinformation required under the GDPR.

11. CHANGES TO THE PRIVACY POLICY

The Controller has the right to amend this Privacy Policy in order to keep it up to date with changes in legislation, the Controller’s activities or the technologies used.

The current version of the Privacy Policy is publishedon the Pegaza Pagalms website www.pegazapagalms.lv.

‍In the event of material changes, the Controller will, where necessary, ensure that data subjects are appropriately informed.

12. CONTACT INFORMATION

If you have any questions regarding the processing ofpersonal data or the exercise of your rights as a data subject, please contact:

‍SIA “Liepaja Music”
E-mail: info@liepajamusic.lv
Telephone: +371 26 470 868
Address: O. Kalpaka iela 92-1, Liepāja, LV-3405

Structural unit “Pegaza Pagalms”
Kuršu iela 20, Liepāja, LV-3401

RENTAL