Version: 2026.06.02

IMAGE CAPTURE AND USE POLICY

1. Purpose

This Image Capture and Use Policy governs the collection, use, processing, and disclosure of images and sounds captured during the Rock in Rio Lisboa event or any initiatives or activities associated with Rock in Rio Lisboa (hereinafter, the “Event”), organized by ROCK WORLD LISBOA, S.A., taxpayer identification number (NIPC) 506 652 041, with registered office at Edifício Lacs, Cais da Rocha Conde D’Óbidos, 1350-352 Lisbon, acting as the data controller for the personal data processing operations determined by it.

This Policy applies to the capture and use of images, photographs, videos, and sound recordings carried out in the context of the organization, production, communication, promotion, and archiving of the Event, without prejudice to specific policies that may apply to other processing operations, namely video surveillance for security purposes, where applicable.

By participating in the Event, participants acknowledge that images, photographs, videos, and sound recordings may be captured for the purposes described in this Policy. This information does not, in itself, constitute a general and unlimited authorization for individualized uses of participants’ images, which shall be assessed in accordance with applicable legislation and, where necessary, shall depend on specific consent or authorization.

The processing of personal data carried out under this Policy complies with Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR), Portuguese Law No. 58/2019 of 8 August, and all other applicable legal provisions concerning personality rights and image rights.

2. Purposes of Image Capture

Images and recordings may be used for the following purposes:

• Journalistic and informational coverage of the Event;

• Promotion, publicity, and institutional communication of the Event and its future editions;

• Publication on the Event’s websites, social media channels, digital platforms, and mobile applications;

• Production of audiovisual content, documentaries, reports, and promotional materials;

• Historical and documentary archiving of activities carried out within the scope of the Event;

• Communication with sponsors, partners, and media organizations, insofar as necessary and appropriate for the production, promotion, and institutional communication of the Event.

The use of images in which participants appear individually, prominently, or as the central element of communication, particularly for specific promotional campaigns, brand activations, testimonials, interviews, or standalone commercial content, shall be subject to a separate assessment and, where legally required, shall depend on specific consent or authorization.

3. Legal Basis

The processing of images and sounds is based on the following legal grounds:

a) Legitimate Interest

The capture of images in the context of a large-scale public event, namely crowd scenes, general atmosphere, performances, and activities, is based on ROCK WORLD LISBOA’s legitimate interest in documenting, promoting, and publicizing the Event.

This legitimate interest shall be exercised in a proportionate and contextualized manner, seeking to avoid excessive, decontextualized, or unjustifiably intrusive uses that may adversely affect participants’ rights, freedoms, and safeguards.

b) Specific Consent or Authorization

Whenever the use of a participant’s image requires, under applicable law, a lawful basis based on consent, such consent shall be requested beforehand in a freely given, specific, informed, and unambiguous manner.

In particular, consent or specific authorization may be requested for the capture and/or use of individualized or highlighted images, interviews, testimonials, personalized promotional content, sponsor or partner activations, as well as the prominent use of minors’ images.

c) Freedom of Expression and Information

The capture and dissemination of images for journalistic, informational, or media coverage purposes may also be carried out under the right to freedom of expression and information, in accordance with applicable law.

Media organizations, photographers, journalists, audiovisual producers, or any other entities capturing and using images for their own purposes may act as independent data controllers and shall be responsible for complying with the legal obligations applicable to them.

4. Scope of Image Capture

During the Event, duly identified photography, video, and audiovisual production teams may be present.

Capturing activities may occur in all public areas, common spaces, stages, activities, and other areas associated with the Event, focusing primarily on environmental and general contextual images of the Event.

The following may be collected:

• Photographs;

• Videos;

• Live-streamed images;

• Sound recordings;

• Testimonials and interviews voluntarily provided by participants.

Whenever possible and appropriate, the organization shall prioritize capturing environmental scenes, crowds, stages, and general Event contexts, avoiding the individualized and prominent use of participants’ images without an appropriate legal basis.

The provision of testimonials or interviews by participants shall be voluntary and may be subject to the collection of specific consent or authorization, depending on the intended purpose and method of use.

5. Use and Disclosure of Images

The organization shall seek to ensure that the use of images is appropriate, proportionate, and consistent with the public nature of the Event.

Images shall be used within the scope of the legitimate promotion of the Event and the organization’s activities and may be shared with partners, sponsors, media partners, and suppliers involved in the production and promotion of the Event, always within the context of its institutional and promotional communication.

The sharing of images with partners, sponsors, media partners, and suppliers shall be limited to what is necessary, appropriate, and proportionate to the purposes described in this Policy. Any independent use of images by sponsors or partners for their own campaigns, separate from the Event’s institutional communication, shall require its own legal basis and, where applicable, specific consent or authorization from the data subjects.

Images may be disclosed through the following channels:

• Official Event website;

• Official social media channels;

• Digital platforms;

• Advertising and promotional materials;

• Press releases;

• Television, radio, print media, and digital media related to the Event;

• Institutional reports and corporate presentations;

• Historical and promotional archives of the Event.

Disclosure may occur in Portugal or in other countries where content is accessible through the Internet.

The use of certain digital platforms and social networks may involve international transfers of personal data, which shall be carried out in accordance with the legally established mechanisms applicable thereto.

6. Retention of Images

The collected images may be retained for the period necessary to achieve the purposes described above, including historical, documentary, and promotional purposes related to the Event and its future editions.

Images included in the Event’s historical or documentary archives may be retained for longer periods whenever necessary for archiving purposes, institutional memory, or historical documentation of the organization’s activities.

Whenever possible and appropriate, data minimization and proportionate retention measures shall be applied.

When determining retention periods, the organization shall consider, among other factors, the nature of the images, the purpose of their use, the context in which they were captured, the existence of published content or materials integrated into institutional, promotional, or historical records, as well as the need to preserve evidence or defend legal rights.

Raw footage or images not selected for use may be deleted or have access restricted when they are no longer necessary for the purposes that justified their collection.

7. Data Subjects’ Rights

Under applicable data protection legislation, data subjects may exercise the following rights:

• Right of access;

• Right to rectification;

• Right to erasure, where applicable;

• Right to restriction of processing;

• Right to object;

• Right to withdraw consent, where processing is based on consent;

• Right to lodge a complaint with the competent supervisory authority.

These rights may be exercised by contacting: privacidade.pt@rockinrio.com.

The exercise of rights may be subject to legal limitations, particularly where processing is necessary for freedom of expression and information, archiving in the public interest, historical or documentary archiving, or the establishment, exercise, or defense of legal claims.

Whenever possible, requests should contain sufficient information to identify the image or content concerned, namely the date, location, context of capture, platform where the image was published, and any other element facilitating its identification.

8. Complaints

Without prejudice to any other administrative or judicial remedy, data subjects have the right to lodge a complaint with the Portuguese Data Protection Authority (Comissão Nacional de Proteção de Dados – CNPD).

9. Minors

Parents, guardians, or legal representatives of minors participating in the Event are responsible for ensuring that they are legally entitled to authorize the participation of such minors in activities where individualized image capture may occur.

The organization shall seek to avoid the individualized and prominent use of minors’ images for promotional purposes without obtaining the legally required authorizations.

Whenever necessary and legally required, specific consent shall be requested for the use of minors’ images.

The presence of minors in general crowd, environmental, stage, or Event-context images may occur incidentally and contextually, without prejudice to the adoption of special care whenever the minor’s image is individualized, highlighted, or used as a central communication element.

10. Objection to the Use of Images

Participants may exercise their right to object to the use of their image in accordance with applicable legislation.

Participants who, for legitimate reasons, wish to object to the use of their image in individualized promotional materials should contact the organization through the available channels, namely via the email address indicated in this Policy.

The organization shall assess each request according to the specific circumstances, the fundamental rights involved, and the applicable legal obligations.

Where the request concerns content that has already been published, the organization shall evaluate the technical and legal feasibility of removing, limiting, or replacing the content, without prejudice to situations where maintaining the image may be justified by freedom of expression and information, archiving purposes, public interest, the defense of rights, or any other applicable legal basis.

11. Amendments to the Policy

This Policy may be updated at any time to reflect legal, regulatory, or operational changes. The most recent version shall always be available on the Event’s official website.

Whenever changes are materially relevant, the organization shall seek to ensure that participants are informed through appropriate means.

12. Contact

For any questions regarding this Policy or the processing of personal data, participants may contact the organization via email at: privacidade.pt@rockinrio.com.

Alternative Dispute Resolution

1.

Users, in their capacity as consumers, may submit complaints through customer support by sending a communication to infolisboa@rockinrio.pt.

2.

Without prejudice to the right to resort to legally available alternative dispute resolution mechanisms, the parties shall, whenever possible, seek to reach an amicable, fair, and appropriate solution to the dispute within a maximum period of 30 (thirty) days from receipt of the relevant complaint.

3.

Under Portuguese Law No. 144/2015 of 8 September, in the event of a consumer dispute, consumers may refer the matter to the following alternative consumer dispute resolution entity:

Lisbon Consumer Conflict Arbitration Centre
Address: Rua dos Douradores, No. 112 – 2nd Floor, 1100-207 Lisbon, Portugal
Telephone: (+351) 218 807 030
Email: juridico@centroarbitragemlisboa.pt or director@centroarbitragemlisboa.pt
Website: www.centroarbitragemlisboa.pt

For further information, please consult the Portuguese Consumer Portal at: www.consumidor.pt.