Privacy Policy - Prize Promotion - Galapagos

1.    Who is the data controller?
NGC Europe Limited, with registered office at 10 Hammersmith Grove, London W6 7AP (hereinafter the "Controller"), is the data controller of your personal data. The Controller can be contacted at the following e-mail address  

2.    Which personal data are processed?
The Controller process the personal data provided by you (hereinafter, the "Data") and collected during your participation to the Galapagos prize promotion (hereinafter the "Promotion"). The Data includes your name and email address.

3.    For what purposes the Data are processed?
The Data will be processed by the Controller for the following purposes:
a)    To perform the contract to which you are party in order to participate to the Promotion, including management and administration of the Promotion;
b)    To comply with legal obligations or with orders of the competent authorities (the purposes under point a) and b) are jointly defined as the “Contractual Purposes”);
c)    To complete a corporate transaction, such as a proposed or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Controller business, assets or stock, including any bankruptcy or similar proceedings (hereinafter defined as the “Legitimate Interest Purposes").
d)    Upon your prior consent, (i) for the promotion of product and services of the Controller or third parties operating in the following sectors television and magazine, by offers, promotions and other marketing communications via traditional mail, e-mail, SMS, telephone, chat and social media (ii) for profiling, in order to customize the above marketing activities to the interests and needs of the clients  (hereinafter defined as the "Marketing Purposes") .

4.    On what legal basis do we process your Data?
The processing of your Data is mandatory for the Contractual Purposes, since it necessary for your participation to the Promotion in the case of let. a) Section 3 above, and to comply with legal obligations in the case of let. b) Section 3 above.
The processing for Legitimate Interested Purposes is necessary to fulfil the legitimate interest of the Controller and of its counterparties to perform the economic activities under let. c) Section 3, according to par. 3 Article 6 of the General European Union Regulation on the protection of personal data no. 679/2016 (hereinafter the “Privacy Regulation”), which is adequately balanced with your interest since the data processing is performed within the limits strictly necessary to perform such economic activities. The processing activity for Legitimate Interest Purposes is not mandatory and you can object at any time through the modalities as per Section 8 of this Privacy Policy, however in such case the Data may not be further used for the Legitimate Interest Purposes.  
The processing for Marketing Purposes is discretionary. Without your consent, you cannot receive our generic marketing communications or communications based on your interests and needs. You can revoke your consent, according to the instruction set out in Section 8 of this Privacy Policy.

5.    How do we process your Data?
The Data is processed through both electronic and manual means and is protected through adequate security measures that guarantee security, confidentiality and the avoidance of unauthorized access.

6.    Who has access to the Data?
The Data will be processed by the Controller for all the purposes described above.
For the Contractual Purposes the Data may also be communicated to the following categories of third parties, which perform activities instrumental and connected to the performance of the Promotion within the European Union and, within the limits referred to in Section 7 below, outside the European Union, such as: (i) assistance service providers for the performance of the Promotion, including prize-winning organization agencies, tax and legal advisory offices, (ii) IT or archiving service providers, (iii) group companies. The Data may be disclosed for the Legitimate Interest Purposes to (i) tax and legal advice consultants, (ii) assignee companies or divested business branch, potential buyers of the Controller and companies resulting from possible mergers, demergers or other corporate transactions relating to the Controller, also in the context of the activities functional to such transactions and (iii) competent authorities. The Data may finally be disclosed for the Marketing Purposes to group companies and service providers.
The parties indicated above may act, as appropriate, as data processors or independent data controllers. The updated list of external data processors is available at the Controller's registered office and may be requested by contacting the Controller at the following e-mail address

7.    Is your Data transferred abroad?
Your Data may be transferred to countries within and outside the European Economic Area, in particular to the Unites States of America. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place appropriate and suitable safeguards designed to protect your Data and the transfer it in compliance with  applicable data protection laws, such as standard contractual clauses adopted by the European Commission as per Articles 45 and 46 of the Privacy Regulation.
You have the right to request a copy of the above measure or further information on the transfer of your Data by contacting the Controller at the address indicated in Section 8 of this Privacy Policy.

8.    What are your rights with regard to your Data?
You have the right, at any given time, to: (i) obtain confirmation as to whether or not your Data exist; (ii) be informed of its content and source, verify its accuracy or request rectification, update or amendments; (ii) request the deletion, conversion to an anonymous form or restriction of any Data processed in breach of applicable law, as well as to oppose its processing, in all cases, for legitimate reasons.
In this regard you may send your request at the following e-mail address
It is understood that you will have the right to lodge a complaint with the supervisory authority where the applicable conditions are met.

9.    What is going to happen on May 25, 2018 with the effectiveness of the Privacy Regulation?
On 25 May 2018, the Privacy Regulation becomes effective and the following provisions will apply, which shall be deemed as not applicable before that date:

A.    Retention period applying to your Data
The Data collected (i) for Contractual Purposes and Legitimate Interest Purposes are retained for a period equal to the duration of the Promotion, plus a period required to process your data, save for additional retention period needed for defense purposes or as required by competent authorities or applicable law; (ii) for Marketing Purposes under Section 3 letter c) point (i) of this Privacy Policy are retained for the duration of the Promotion plus 24 months, whilst for the Marketing Purposes under Section 3 letter c) point (ii) of this Privacy Policy the Data are retained for a period of 12 months after its collection.
At the end of the retention period your Data will be either cancelled, anonymized or aggregated.

B.        Additional rights
In addition to the rights as indicated in Section 8 of this Privacy Policy and further to the application of the Privacy Regulation, you will also have the right, in any given moment, to:

a)    Request to Controller to limit the processing of the Data where:
•    You contest the accuracy of the Data until we have taken sufficient steps to correct or verify its accuracy;
•    The processing is unlawful but you do not want us to erase the Data;
•    We no longer need the Data for the purposes of the processing, but you require the Data  for the establishment, exercise or defense of legal claims; or
•    Where you have objected to processing for the Legitimate Interest Purposes pending verification as to whether the Controller has compelling legitimate grounds to continue processing.
b)        Object to the processing of your Data;
c)        Request the erasure of your Data without undue delay;
d)        Receive an electronic copy of your Data, that you have provided to us, if you  would like to port your Data to yourself or a different provider (“data portability”), when the Data is processed by automatic means and the processing is either (i) based upon your consent or (ii) the fact that the processing is necessary for performance of contract related to the Promotion; and
e)    Lodge a complaint with the relevant supervisory authority.

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