Data protection

Name and address of the data protection officer

The data protection officer for this website is

newclicks UG (haftungsbeschränkt) & Co. KG

Richard Zelzer

Außenwall 6

47495 Rheinberg

Phone: 02843 1761000

info@newclicks.de

The controller within the meaning of the General Data Protection Regulation and other national data protection laws of the member states as well as other data protection regulations is

newclicks UG (haftungsbeschränkt) & Co. KG

Außenwall 6

47495 Rheinberg

Telephone: 02843 1761000

info@newclicks.de

General information on data processing

Scope of the processing of personal data

We collect and use our users' personal data only to the extent necessary to provide a functional website and our content and services. The collection and use of our users' personal data only takes place regularly with the user's consent. An exception applies in cases where prior consent cannot be obtained for factual reasons and the processing of the data is permitted by law.

Legal basis for the processing of personal data

Insofar as we obtain the consent of the data subject for the processing of personal data, Art. 6 para. 1 lit. a EU General Data Protection Regulation (GDPR) serves as the legal basis.

When processing personal data that is necessary for the fulfilment of a contract to which the data subject is a party, Art. 6 para. 1 lit. b GDPR serves as the legal basis. This also applies to processing operations that are necessary for the performance of pre-contractual measures.

Insofar as the processing of personal data is necessary to fulfil a legal obligation to which our company is subject, Art. 6 para. 1 lit. c GDPR serves as the legal basis.

In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.

If the processing is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6 para. 1 lit. f GDPR serves as the legal basis for the processing.

Provision of the website and creation of log files

Description and scope of data processing

Each time our website is accessed, our system automatically collects data and information from the computer system of the accessing computer. The following data is collected:

Information about the browser type and version used
The user's operating system
The user's internet service provider
The IP address of the user
Date and time of access
Websites from which the user's system accesses our website
Websites that are accessed by the user's system via our website
Name and URL of the retrieved file

The data is also stored in the log files of our system. This data is not stored together with other personal data of the user.

Legal basis for data processing

The legal basis for the temporary storage of data and log files is Art. 6 para. 1 lit. f GDPR.

Purpose of the data processing

The temporary storage of the IP address by the system is necessary to enable the website to be delivered to the user's computer. For this purpose, the user's IP address must remain stored for the duration of the session.

The data is stored in log files to ensure the functionality of the website. We also use the data to optimise the website and to ensure the security of our information technology systems. The data is not analysed for marketing purposes in this context.

These purposes also constitute our legitimate interest in data processing in accordance with Art. 6 para. 1 lit. f GDPR.

Duration of storage

The data will be deleted as soon as it is no longer required to fulfil the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended.

If the data is stored in log files, this is the case after 7 days at the latest. Storage beyond this period is possible. In this case, the IP addresses of the users are deleted or anonymised so that it is no longer possible to identify the accessing client.

Objection and removal options

The collection of data for the provision of the website and the storage of data in log files is absolutely necessary for the operation of the website. Consequently, there is no possibility for the user to object.

Integration of services via third-party providers

Google Analytics

Our website uses Google Analytics, a web analysis service provided by Google Inc. Google Analytics uses so-called "cookies", text files that are stored on your computer and enable your use of the website to be analysed. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. On our website, we use the code extension "anonymizeIp", which serves to activate IP anonymisation on this website. However, by using this extension, your IP address will be shortened beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area.

Google will use this information exclusively on our behalf to analyse your use of the website, to compile reports on website activity and to provide other services related to website activity and internet usage to the website operator. The abbreviated IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website.

You can also prevent Google Analytics from collecting data by clicking on the following link https://tools.google.com/dlpage/gaoptout?hl=de. An opt-out cookie will be set to prevent the future collection of your data when you visit this website.

Further information can be found in Google's privacy policy https://www.google.com/intl/de/policies/privacy/. Google has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

Google Remarketing

We use Google Adwords to draw attention to our attractive offers with the help of advertising material (so-called Google Adwords) on external websites. We can determine how successful the individual advertising measures are in relation to the advertising campaign data. We are interested in showing you adverts that are of interest to you, making our website more interesting for you and achieving a fair calculation of advertising costs.

These adverts are delivered by Google via so-called 'ad servers'. For this purpose, we use ad server cookies, through which certain parameters for measuring success, such as the display of adverts or clicks by users, can be measured. If you access our website via a Google advert, Google Adwords will store a cookie on your PC. These cookies generally lose their validity after 30 days and are not intended to identify you personally. The unique cookie ID, number of ad impressions, per placement (frequency), last impression (relevant for post-view conversions) and opt-out information (marking that the user no longer wishes to be contacted) are usually stored as analysis values for this cookie.

These cookies enable Google to recognise your internet browser. If a user visits certain pages of an Adwords customer's website and the cookie stored on their computer has not yet expired, Google and the customer can recognise that the user clicked on the ad and was redirected to this page. A different cookie is assigned to each Adwords customer. Cookies can therefore not be tracked via the websites of Adword customers. We ourselves do not collect and process any personal data in the aforementioned advertising measures. We only receive statistical analyses from Google. This analysis enables us to recognise which of the advertising measures used are particularly effective. We do not receive any further data from the use of the advertising material; in particular, we cannot identify users on the basis of this information.

Due to the marketing tools used, your browser automatically establishes a direct connection with the Google server. We have no influence on the scope and further use of the data collected by Google through the use of this tool and therefore inform you according to our level of knowledge: Through the integration of AdWords Conversion, Google receives the information that you have called up the corresponding part of our website or clicked on an advert from us. If you are registered with a Google service, Google can assign the visit to your account. Even if you are not registered with Google, Google can assign the visit to your account. Even if you are not registered with Google or have not logged in, there is a possibility that the provider will find out your IP address and store it.

You can prevent participation in this tracking process in various ways:

by setting your browser software accordingly; in particular, suppressing third-party cookies means that you will not receive any adverts from third-party providers;
by deactivating cookies for conversion tracking by setting your browser to block cookies from the domain www.googleadservices.com, https://www.google.de/settings/ads, whereby these settings are deleted when you delete your cookies.
by deactivating the interest-based ads of the providers that are part of the self-regulation campaign 'About Ads' via the link http://www.aboutads.info/choices, whereby this setting is deleted when you delete your cookies
by permanently deactivating them in your Firefox, Internet Explorer, Microsoft Edge or Google Chrome browsers via the link https://support.google.com/ads/answer/7395996. We would like to point out that in this case you may not be able to use all functions of this offer to their full extent

The legal basis for the processing of your data is Art. 6 para. 1 sentence 1 lit. f GDPR. Further information on data protection at Google can be found here: https://policies.google.com/privacy?hl=de and https://services.google.com/sitestats/de.html. Alternatively, you can visit the website of the Network Advertising Initiative (NAI) at https://www.networkadvertising.org/ Google has submitted to the EU-US Privacy Shied, https://www.privacyshield.gov/EU-US-Framework.

Google Adwords conversion tracking

We use the Google Adwords service to record important events and actions (so-called conversions) that are carried out on our website. We collect this data for the purpose of better displaying advertisements with Google Adwords to precisely those users who exhibit specific user behaviour.

Such actions can be, for example, filling out a contact form, scrolling to the bottom of a page, using a page for more than 1 minute, clicking on a specific link, etc.

Furthermore, conversions can also have a monetary value, making it easier for us to compare the relationship between the money spent on advertising and the return in potential sales.

You can prevent participation in this tracking process in various ways:

by setting your browser software accordingly; in particular, suppressing third-party cookies means that you will not receive any adverts from third-party providers;
by deactivating cookies for conversion tracking by setting your browser to block cookies from the domain www.googleadservices.com, https://www.google.de/settings/ads, whereby these settings are deleted when you delete your cookies.
by deactivating the interest-based ads of the providers that are part of the self-regulation campaign 'About Ads' via the link http://www.aboutads.info/choices, whereby this setting is deleted when you delete your cookies
by permanently deactivating them in your Firefox, Internet Explorer, Microsoft Edge or Google Chrome browsers via the link https://support.google.com/ads/answer/7395996. We would like to point out that in this case you may not be able to use all functions of this offer to their full extent

Google Fonts

In accordance with data protection regulations, we do not integrate web fonts from Google servers in the USA, but load them locally. The web font files were downloaded from the Internet for this purpose and then manually integrated into the system.

Google Maps

We use a plugin of the internet service Google Maps on our website. The operator is Google Inc. based in the USA, CA 94043, 1600 Amphitheatre Parkway, Mountain View. By using Google Maps on our website, usage information about this website and your IP address are sent to a Google server in the USA. This data is also stored there. We do not know the exact content of this data and have no knowledge of its use by Google. However, the company distances itself from linking the data with information from other Google services and the collection of personal data. Google may, however, transmit this information to third parties. By deactivating Javascript in your browser, you prevent Google Maps from being executed. However, this also means that you will no longer be able to use map services. By using our website, you consent to the described collection and processing of information by Google Inc. Further information on the data protection provisions and terms of use for Google Maps can be found here: https://www.google.com/intl/de_de/help/terms_maps.html.

Integration of YouTube videos

We have integrated YouTube videos into our online offering, which are stored on http://www.YouTube.com and can be played directly from our website. These are all integrated in "extended data protection mode", i.e. no data about you as a user is transferred to YouTube if you do not play the videos. Only when you play the videos will the data mentioned in paragraph 2 be transmitted. We have no influence on this data transfer.

When you visit the website, YouTube receives the information that you have accessed the corresponding subpage of our website. In addition, the data mentioned above in this declaration is transmitted. This occurs regardless of whether YouTube provides a user account through which you are logged in or whether no user account exists. If you are logged in to Google, your data will be assigned directly to your account. If you do not wish your data to be associated with your YouTube profile, you must log out before activating the button. YouTube stores your data as usage profiles and uses them for the purposes of advertising, market research and/or customising its website. Such an evaluation is carried out in particular (even for users who are not logged in) to provide customised advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, whereby you must contact YouTube to exercise this right.

Further information on the purpose and scope of data collection and its processing by YouTube can be found in the privacy policy. There you will also find further information on your rights and setting options to protect your privacy: https://www.google.de/intl/de/policies/privacy. Google also processes your personal data in the USA and has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

Integration of Vimeo videos

Plugins from the Vimeo video portal of Vimeo, LLC, 555 West 18th Street, New York, New York 10011, USA are integrated on our website. Each time you access a page that offers one or more Vimeo video clips, a direct connection is established between your browser and a Vimeo server in the USA. Information about your visit and your IP address is stored there. By interacting with the Vimeo plugins (e.g. clicking the start button), this information is also transmitted to Vimeo and stored there. If you have a Vimeo user account and do not want Vimeo to collect data about you via this website and link it to your membership data stored with Vimeo, you must log out of Vimeo before visiting this website.

The privacy policy for Vimeo with more detailed information on the collection and use of your data by Vimeo can be found at http://vimeo.com/privacy. Vimeo also calls up the Google Analytics tracker via an iFrame in which the video is called up. This is Vimeo's own tracking, to which we have no access. You can prevent tracking by Google Analytics by using the deactivation tools that Google offers for some Internet browsers. Users can also prevent Google from collecting the data generated by Google Analytics and relating to their use of the website (including your IP address) and from processing this data by Google by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de

Use of cookies

Description and scope of data processing

Our website uses cookies. Cookies are text files that are stored in the Internet browser or by the Internet browser on the user's computer system. When a user accesses a website, a cookie may be stored on the user's operating system. This cookie contains a characteristic string of characters that enables the browser to be uniquely identified when the website is called up again.

We use cookies to make our website more user-friendly. Some elements of our website require that the accessing browser can be identified even after a page change.

The following data is stored and transmitted in these so-called technically necessary cookies:

- cookie_hinweis

Information about the cookie selection made (integer)

- lang

Language selection of the user so that the correct language is displayed (integer)

- PHPSESSID

PHP session ID so that data (e.g. shop) can be transferred from one page to another (26 characters, is automatically deleted or reassigned after a session)

We also use so-called technically unnecessary cookies on our website, which enable an analysis of the user's surfing behaviour or improve the display of advertising on the Internet. The following data can be transmitted in this way

- Google Analytics and Tag Manager

The user data collected in this way is pseudonymised by technical precautions. It is therefore no longer possible to assign the data to the accessing user. The data is not stored together with other personal user data.

When accessing our website, users are informed about the use of cookies for analysis purposes by an information banner and referred to this privacy policy. In this context, there is also a reference to how the storage of cookies can be prevented in the browser settings.

When accessing our website, users are informed about the use of cookies for analytical purposes and their consent to the processing of the personal data used in this context is obtained. In this context, reference is also made to this privacy policy.

There are some cookies that are displayed when you visit our website, so-called third-party cookies, which originate from other websites and we therefore have no way of blocking them or prohibiting communication with your sources. Depending on whether and which portals you use on the Internet, it is possible that these cookies may or may not be stored on your computer. Nevertheless, we would like to inform you about these cookies.

With your consent, we also integrate cookies from third-party providers. In this case, the corresponding data packets from third parties are stored in your browser or transmitted to them. As a rule, you can also prevent the use of third-party cookies by adjusting your browser settings accordingly. The legal basis for the processing of your personal data using third-party cookies is Art. 6 para. 1 lit. a) GDPR. In this case, you can also withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Legal basis for data processing

The legal basis for the processing of personal data using cookies is Art. 6 para. 1 lit. f GDPR.

Purpose of the data processing

The purpose of using technically necessary cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that the browser is recognised even after a page change

The purposes of the individual technically necessary cookies that may appear on our website can be found in the tables above.

The user data collected by technically necessary cookies is not used to create user profiles.

These purposes also constitute our legitimate interest in the processing of personal data in accordance with Art. 6 para. 1 lit. f GDPR.

Duration of storage, objection and removal options

Cookies are stored on the user's computer and transmitted by it to our website. As a user, you therefore have full control over the use of cookies. You can deactivate or restrict the transmission of cookies by changing the settings in your Internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all functions of the website to their full extent.

Contact forms and email contact

Description and scope of data processing

There are contact forms on our website that can be used to contact us electronically. If a user makes use of this option, the data entered in the input mask is transmitted to us and stored. The type and content of the data transmitted to us can be found in the names and any descriptions in or on the input fields of the respective form. Please pay particular attention to mandatory fields.

When the message is sent, the following data, which is not necessarily visible in the form, is also stored:

The IP address of the user
Date and time of sending
Consent to the privacy policy

Your consent to the processing of the data is obtained during the sending process and reference is made to this privacy policy.

Alternatively, you can contact us via the e-mail address provided. In this case, the user's personal data transmitted with the e-mail will be stored.

The data will not be passed on to third parties in this context. The data is used exclusively for processing the conversation.

Legal basis for data processing

The legal basis for the processing of the data is Art. 6 para. 1 lit. a GDPR if the user has given consent.

The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 para. 1 lit. f GDPR. If the e-mail contact is aimed at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b GDPR.

Purpose of the data processing

The processing of the personal data from the input mask serves us solely to process the contact. If you contact us by email, this also constitutes the necessary legitimate interest in processing the data.

The other personal data processed during the sending process is used to prevent misuse of the contact form and to ensure the security of our information technology systems.

Duration of storage

The data is deleted as soon as it is no longer required to fulfil the purpose for which it was collected. For the personal data from the input screen of the contact form and those sent by email, this is the case when the respective conversation with the user has ended. The conversation is ended when it can be inferred from the circumstances that the matter in question has been conclusively clarified.

The additional personal data collected during the sending process will be deleted after a period of 7 days at the latest.

Right of objection and cancellation

The user has the option to revoke their consent to the processing of personal data at any time. If the user contacts us by e-mail, they can object to the storage of their personal data at any time. In such a case, the conversation cannot be continued.

To revoke your consent or object to the storage of your data, simply give us a call or send us an e-mail.

Telephone: 0 28 43 1 76 10 00
eMail: info@newclicks.de

All personal data stored in the course of making contact will be deleted in this case.

Rights of the data subject

The following list includes all rights of data subjects under the GDPR. Rights that are not relevant to your own website do not need to be mentioned. In this respect, the list can be shortened. If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights vis-à-vis the controller

Right to information

You can request confirmation from the controller as to whether personal data concerning you is being processed by us.

If such processing is taking place, you can request the following information from the controller

The purposes for which the personal data is processed;
the categories of personal data being processed
the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed
the envisaged period for which the personal data concerning you will be stored, or, if specific information on this is not possible, the criteria used to determine that period
the existence of a right to rectification or erasure of personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing
the existence of a right to lodge a complaint with a supervisory authority
all available information about the origin of the data if the personal data is not collected from the data subject
the existence of automated decision-making, including profiling, referred to in Art. 22 (1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

You have the right to request information as to whether the personal data concerning you is transferred to a third country or to an international organisation. In this context, you may request to be informed of the appropriate safeguards pursuant to Art. 46 GDPR in connection with the transfer.

Right to rectification

You have a right to rectification and/or completion vis-à-vis the controller if the processed personal data concerning you is incorrect or incomplete. The controller must make the rectification without undue delay.

Right to restriction of processing

You may request the restriction of the processing of personal data concerning you under the following conditions

if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
the controller no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims, or if you have objected to processing pursuant to Art. 21 (1) GDPR pending the verification whether the legitimate grounds of the controller override your grounds.
the controller no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims, or if you have objected to processing pursuant to Art. 21 (1) GDPR pending the verification whether the legitimate grounds of the controller override your grounds.

If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.

Right to cancellation

Obligation to erase

You have the right to obtain from the controller the erasure of personal data concerning you without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

The personal data concerning you are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
You revoke your consent on which the processing was based pursuant to Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a GDPR and there is no other legal basis for the processing.
You object to the processing pursuant to Art. 21 para. 1 GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 para. 2 GDPR.
The personal data concerning you has been processed unlawfully.
The deletion of personal data concerning you is necessary to fulfil a legal obligation under Union law or the law of the Member States to which the controller is subject.
The personal data concerning you have been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.

Information to third parties

If the controller has made the personal data concerning you public and is obliged to erase it pursuant to Article 17(1) GDPR, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you as the data subject have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

Exceptions

The right to erasure does not apply if the processing is necessary

to exercise the right to freedom of expression and information
for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
for reasons of public interest in the area of public health in accordance with Art. 9 para. 2 lit. h and i and Art. 9 para. 3 GDPR
for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Art. 89 para. 1 GDPR, insofar as the right referred to in section a) is likely to render impossible or seriously impair the achievement of the objectives of that processing, or
for the establishment, exercise or defence of legal claims.

Right to information

If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to notify all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort.

You have the right vis-à-vis the controller to be informed about these recipients.

Right to data portability

You have the right to receive the personal data concerning you, which you have provided to the controller, in a structured, commonly used and machine-readable format. You also have the right to transmit this data to another controller without hindrance from the controller to which the personal data has been provided, where

the processing is based on consent pursuant to Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR or on a contract pursuant to Art. 6 para. 1 lit. b GDPR and
the processing is carried out by automated means.

In exercising this right, you also have the right to obtain that the personal data concerning you be transferred directly from one controller to another controller, insofar as this is technically feasible. The freedoms and rights of other persons must not be affected by this.

The right to data portability does not apply to the processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Right to object

You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions.

The controller will no longer process the personal data concerning you unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.

If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.

In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you have the possibility of exercising your right to object by automated means using technical specifications.

Right to revoke the declaration of consent under data protection law

You have the right to withdraw your declaration of consent under data protection law at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Automated decision-making in individual cases, including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision

is necessary for the conclusion or fulfilment of a contract between you and the controller
is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or
with your express consent.

However, these decisions may not be based on special categories of personal data pursuant to Art. 9 para. 1 GDPR, unless Art. 9 para. 2 lit. a or g GDPR applies and appropriate measures have been taken to protect the rights and freedoms as well as your legitimate interests.

With regard to the cases referred to in (bullet point 1) and (bullet point 3), the data controller shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express your point of view and to contest the decision.

Right to lodge a complaint with a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.

The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy pursuant to Art. 78 GDPR.