I. Notice concerning the party responsible for this website / Controller

The party responsible for processing data for the purposes of Regulation (EU) 2016/679 (General Data Protection Regulation; in the following: GDPR)  as well as all other national data protection acts and regulations is:

Global Junior Golf e.V., Hauptstraße 42, 68259 Mannheim, Germany
Phone: +49 621 / 79 80 482
Fax: +49 621 / 79 80 135
E-Mail: service@globaljuniorgolf.com
Website: www.globaljuniorgolf.com

II. Overview of data protection

1. Processing of personal data

The following gives a simple overview of what happens to your personal data when you visit our website. Personal data means any information relating to an identified or identifiable natural person.

We process personal data of our users basically only to ensure the proper functioning of our website and with their consent. Exceptions are possible in case a prior consent is impossible for practical reasons and the processing is permitted by law.

How do we collect your data?

Some data are collected when you provide them to us. This can, for example, be data you enter on a contact form.

Other data are collected automatically by our IT systems when you visit the website. These data are primarily technical data such as the browser and operating system you are using or when you access the page.
2. Legal basis for the processing of personal data

In cases in which you have given consent to the processing of your personal data for one or more specific purposes, the processing of such data is lawful according to article 6 No. 1 a) GDPR.

The processing of personal data which are necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract is lawful according to Article 6 No. 1 b) GDPR.

The processing of personal data which is necessary for compliance with a legal obligation to which we are subject is lawful according to Article 6 No. 1 c) GDPR.

In case the processing of personal data should be necessary in order to protect the vital interests of you or another natural person, the legal basis is Article 6 No. 1 d) GDPR.

In case the processing of personal data is necessary for the purposes of the legitimate interests pursued by us or by a third party and such interests are not overridden by the interests or fundamental rights and freedoms of you and require protection of personal data, the legal basis is Article 6 No. 1 f) GDPR.

3. Storage period and erasure of personal data

Your personal data will be erased in case their storage is no longer necessary for the purposes for which they are processed. They may be stored for longer periods in so far as this is obligatory according to EU or national law.

III. Data collection on our website and logfiles

Some data are collected automatically by our IT systems when you visit our website. These are: information on your browser including the used version, your operating system, your internet service provider, IP address, date and time of access, websites from which your local system was able to access our website and websites accessed from your system via our website.

These data are kept in the logfiles of our system. They are not kept together with any other of your personal data. Legal basis for the temporary storage of these data and logfiles is Article 6 No. 1 f) GDPR. The temporary storage of your IP address by our IT system is necessary to ensure a proper access to our website. For this purpose your IP address must be stored as long as you visit our website. The storage of data in logfiles is further necessary to ensure the proper functioning of our website. These data are necessary to optimize our website and to ensure the safety of our IT systems. An evaluation of your data for marketing purposes is excluded.

Your data are erased as soon as they are not necessary any more to attain the objective pursuit. In case of the capture of data for providing access to our website they are erased as soon as the session is terminated. In case of data storage in logfiles they are deleted after seven days at the latest. A storage after this period is possible. Your IP address will be deleted or modified in order to make a correlation to you impossible.

The collection of your data is necessary for providing access to our website; the data storage in logfiles is also necessary to ensure the proper functioning of our website. It follows that there is no right to object against the data collection and storage.

IV. Cookies

Our website uses cookies. Cookies are small text files that are stored on your computer and saved by your browser. We use cookies to make our website more user-friendly, efficient and secure.

Most of the cookies used by us are automatically deleted when you close your browser. Some elements of our website require the identification of your browser also after moving to another page. Other cookies may therefore be stored in your operating system. They make it possible to recognize your browser when you next visit the site.

We do not use any personal data collected by the use of cookies for generating user profiles.

Legal basis for the use of cookies is Art. 6 No. 1 f) GDPR.

Cookies are stored on your computer and transmitted to our website. You can configure your browser to inform you about the use of cookies so that you can decide on a case-by-case basis whether to accept or reject a cookie. Alternatively your browser can be configured to automatically accept cookies under certain conditions or to always reject them, or to automatically delete cookies when closing your browser. Disabling cookies may limit the functionality of our website.

V. Newsletter

You can subscribe to our free newsletter on our website. This requires that you provide us with the following data: name, e-mail address.

Additionally, the following data are collected: IP address, date and time of access.

We will process these data only with your prior consent according to Article 6 No. 1 a) GDPR. In case you are below the age of 16 years, consent will be required by the holder of parental responsibility over you. We only use these data to send our e-mails / newsletters to you and do not pass any data on to third parties. We collect your personal data exclusively for the purpose of sending the newsletter and preventing a misuse of our service as well as of your e-mail address.

The legal basis is your consent according to Article 6 No. 1 a) GDPR. In case you are below the age of 16 years, the processing of your data is lawful only if and to the extent that consent is given by the holder of parental responsibility over you, Art. 8 No. 1 GDPR.

Your data are erased as soon as they are not necessary any more for the purpose of sending you the newsletter. Your e-mail address is stored as long as your subscription is active.

You may cancel your subscription to the newsletter / mailing by means of the link found at the bottom of the newsletter at any time. You can also unsubscribe from the newsletter directly on our website or by sending us an e-mail to service@globaljuniorgolf.com.

VI. Registration

You have the possibility to set up an account and sign up for a tournament on our website. For this purpose, you have to fill in personal data in our registration form which are then transmitted to us and stored. In particular, you have to fill in the following data:

Gender, last name, first name, address, telephone number, fax number, mobile number, e-mail address, e-mail address parent / guardian, day and place of birth, country of birth, nationality, hobbies, home club, HCP, shirt size, largest success/top finishes, academic information/school information, When started playing golf, graduation year, Facebook/profile-URL, coaches access (YES/NO).

The data are stored in an external database hosted by Netcomposer Medien GmbH, Am Bach 10, 68789 St. Leon-Rot. They are transmitted to the server of Netcomposer Medien GmbH exclusively for their correct administration and storage as well as the proper functioning of our website. A transfer of data to third parties by Netcomposer Medien GmbH is excluded. Legal basis for the transmission of the data to the external database is Art. 6 Abs. 1 b) GDPR.

At the time of registration, also the following data are automatically collected: IP address, date and time of access.

Within the process of setting up an account, we will also require your consent to receive e-mails from us periodically (=mass mails) with an overview of upcoming tournaments, essential tournament info or important updates during a tournament such as starting times, delay due to weather, updated hotel info and etc.

In the course of registration, we will require your consent to the processing of these data. In case you are below the age of 18 years, consent will be required by the holder of parental responsibility over you.

Legal basis for the processing of these data is your consent according to Article 6 No. 1 a) GDPR. In case you are below the age of 18 years, the processing of your data is lawful only if and to the extent that consent is given by the holder of parental responsibility over you, Art. 8 No. 1 GDPR.

Your registration is necessary in order to provide you with our services as a member of the Global Junior Golf e.V. as well as all services in connection with the golf tournaments offered by us.

Some of your personal data concerning the participation in a tournament are transmitted to global rankings, namely, WAGR, provided by R&A Championships Ltd., Beach House, Golf Place, St Andrews, Fife KY16 9JA, United Kingdom (www.wagr.com), Junior Golf Scoreboard, c/o New Business Associates, Inc., 4510 Cox Road, Suite 303, Glen Allen, VA 23060, USA (www.juniorgolfscoreboard.com) and European Golf Rankings, Intelligent Solutions for Golf, Spitzwegstr., 68789 St. Leon-Rot, Germany (www.europeangolfrankings.com).These are:

WAGR: name of tournament, first name, last name, result list, age, gender, country
Junior Golf Scoreboard: first name, last name, hometown, country, age group, graduation year, result list
European Golf Rankings: gender; last name, first name, day of birth, home golf club, nation HCP, result list

The transmission of your data to the global rankings is necessary to ensure the correct evaluation of the tournament and your HCP. Legal basis for the transmission is Article 6 No. 1 b) GDPR.

We do not have any influence on the handling and storage of your personal data by the global rankings. You will find more information on how they handle your data directly their Privacy Policy on their websites: https://www.wagr.com/en/Footer-Pages/Privacy-policy.aspx; https://www.juniorgolfscoreboard.com/privacypolicy.asp; https://www.europeangolfrankings.com/seite/privacy.

When you register for a tournament in Germany arranged and performed by us, we will transmit some of your personal data to the local golf club hosting the tournament. These data are: first name, last name, HCP, home golf club, nation.

The club will enter these data into the national web of your home country in order to provide access to them for your home club, to ensure the correct evaluation of your HCP and to enable the creation of your score card. This has the advantage that you do not have to transmit your results to your home club by yourself.

When your membership expires after the end of the calendar year your membership becomes inactive, if you don´t renew your membership for the consecutive calendar year. Your personal data will be stored for 3 consecutive years, if you will not renew you account. Once a player reached the age of 22 or has not renewed his membership in the 3 consecutives year, his data will be automatically deleted. In case you fill in the registration form without finishing the registration by interrupting or failing to complete the payment process, your personal data will nevertheless be transmitted to us and stored for a period of 7 days. If the payment of your membership fee is not made within this period, your personal data will be erased.

Your data are erased as soon as they are not necessary any more for the purpose of their collection. In particular, they are erased as soon as you cancel the membership in the Global Junior Golf e.V.

You have the possibility to cancel your registration at any time as well as to amend the personal data collected by us. You can cancel your membership in the Global Junior Golf e.V. as well as your account by sending us an e-mail to service@globaljuniorgolf.com. You can amend your personal data by logging into your account. You may revoke your consent to receiving our mass mails by sending us an e-mail to service@globaljuniorgolf.com.

Whenever you participate in a tournament, the complete result list will be transmitted to the global rankings. It follows that there is no right to object against the transmission of the data to them.

 

VII. Contact form and e-mail contact

You may contact us by using our electronic contact form on our website. In this case, we collect the following data from you: name, e-mail address, IP address, subject of contact & telephone number. In the course of sending us the form, we will require your consent to the processing of these data. In case you are below the age of 16  years, consent will be required by the holder of parental responsibility over you.

At the time of sending the contact form to us, the following data are automatically collected: IP address, date and time of access.

Alternatively, you can contact us via our e-mail address on our website. In this case, the personal data transmitted by you in your e-mail are stored.

We do not pass any of your personal data on to third parties in this context. Your data are exclusively processed for the purpose of communicating with you.

Legal basis is your consent according to Article 6 No. 1 a) GDPR. In case you are below the age of 16 years, the processing of your data is lawful only if and to the extent that consent is given by the holder of parental responsibility over you, Art. 8 No. 1 GDPR. Legal basis for the processing of data which are transmitted by you by an e-mail is Article 6 No. 1 f) GDPR.

The processing of your personal data is exclusively necessary for the purposes of communication with you. Your data will be deleted as soon as the communication with you is terminated.

You have the right to object to your consent to the processing of your data at any time by sending us an e-mail to service@globaljuniorgolf.com. In this case, all personal data stored in the process of the communication will be erased. The communication cannot be continued in this case.

VIII. MailChimp (Newsletter tracking)

This website uses the services of MailChimp to send newsletters. This service is provided by Rocket Science Group LLC., 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA.

MailChimp is a service which organizes and analyzes the distribution of newsletters. All data provided by you to subscribe to our newsletter (see under V.), in particular your e-mail address, will be stored on MailChimp servers in the U.S. MailChimp is certified under the EU-US Privacy Shield. This is an agreement between the EU and the U.S. to insure compliance with European privacy standards in the United States.

We use MailChimp to analyze our newsletter campaigns. When you open an e-mail sent by MailChimp, a file included in the e-mail (so-called web beacon) connects to MailChimp´s servers in the United States. This allows us to determine if a newsletter message has been opened and which links you click on. Additionally, technical information is collected, namely, time of retrieval, IP address, browser type and operating system.

The data processing is based on Article 6 No.1 f) GDPR. The data collected from you are used exclusively to analyze our newsletter campaigns, in particular for the statistical analysis of our campaigns. The results of such analyses can be used to better tailor future newsletters to our interests.

The collected data will be stored as long as you have subscribed for our newsletter. They will immediately be deleted from our servers and those of MailChimp when you cancel your subscription. Data we have stored for other purposes, in particular registration, remain unaffected.

You may withdraw your consent to the use of your data by MailChimp at any time by unsubscribing to the newsletter. For unsubscribing to the newsletter, we provide a link in every newsletter we send. You can also unsubscribe from the newsletter directly on our website or by sending us an e-mail to service@globaljuniorgolf.com.

IX. Transmission of data to our business partners / licensees / tournament hosts, when registering for a tournament hosted by third party

In order to perform and organize the Golf Tournaments initiated and promoted by us, we corporate with partners in many countries worldwide.  When you register for a certain tournament of the Global Junior Golf Tour or 21 Golf League, the personal data stored in your account will be forwarded to our business partner in this country.

These data are:
gender, last name, first name, address, telephone number, fax number, mobil number, e-mail address, e-mail address parent / guardian, day and place of birth, country of birth, nationality, hobbies, home club, HCP, shirt size, largest success/top finishes, academic information/school information, When started playing golf, graduation year, facebook/profile-URL, coaches access (YES/NO).

You will be informed in the course of the registration procedure to which of our partners (name and contact info) your personal data will be transferred.

Legal basis for the transmission of these data to our partners is Article 6 No. 1 b) GDPR. The transmission of your data to our partner in the country in which you register for a tournament is necessary in order to provide you with all services as a participant of the tournament and to ensure the best performance of the tournament as well as accommodation and catering services.

Our partners are contractually bound to keep all of your personal data strictly confidential. As soon as you register for a tournament performed and organized by one of our partners, you will enter into a contract directly with our partner. From this stage on, we do not have any influence on the handling and storage of your personal data by our partner. You will find more information on how the specific partner handles your data directly from him. You must contact the partner directly or inquire on his website if available to further review his privacy policy.

In case you do not agree with the transmission of all or some of your personal data to our business partners, you will not be able to participate in the specific tournament. If you wish to register for a tournament, it follows that there is no right to object against the transmission of the data.

X. PayPal

Our website accepts payments via PayPal. The provider of these services is PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg.

If you select payment of your membership fee via PayPal, the following data provided by you will be supplied to PayPal: e-mail address. Additionally, technical information collected by us is also transmitted to PayPal, namely, IP address, date and time of access.

Legal basis for the transmission of your data to PayPal is Article 6 Abs. 1 b) GDPR. Your data are transmitted to PayPal exclusively for purposes of executing the payment of your membership fees.

Your payment data are not stored by us. We do not have any influence on the handling and storage of your personal data by PayPal. Please find further information in the Privacy Policy of PayPal under https://www.paypal.com/de/webapps/mpp/ua/privacy-full?locale.x=de_DE.

As long as we have not yet transmitted your personal data to PayPal, you may object to the transmission at any time by not completing the payment process with PayPal. In this case, a payment of your membership fee via PayPal will not be possible. In this case, all personal data filled in by you so far, will be transmitted to us and stored for a period of 7 days. If the payment of your membership fee is not made within this period, your personal data will be erased.

XI. Facebook

Our website includes a link to Facebook. The social network Facebook is provided by Facebook Inc., 1 Hacker Way, Menlo Park, California 94025, USA.  As soon as you click on the Facebook link on our website, a direct connection between your browser and the Facebook server is established. This enables Facebook to receive information that you have visited our site from your IP address. The following data are transmitted automatically to Facebook: Facebook name, Facebook profile picture, Facebook cover picture, e-mail address provided to Facebook, Facebook ID, Facebook friends, Facebook likes, birthday, gender, country, language.

If you click on the Facebook link while you are logged on to Facebook, Facebook can allocate the visit of our website to your Facebook account.

Legal basis for the processing of your data is Art. 6 No. 1 a) GDPR. We have no influence on the handling and storage of your data by Facebook. Please obtain more information from the Privacy Policy of Facebook: https://de-de-facebook.com/policy.php. If you do not want Facebook to allocate the visit of our website with your Facebook account, please log out from your Facebook account.

XII. Youtube

Our website includes links to the video portal Youtube, which is operated by Youtube LLC, 901 Jerry Avenue, St. Bruno, CA 94066, USA.

As soon as you click on the Youtube link on our website, a direct connection between your browser and the Youtube server is established. This enables Youtube to receive information that you have visited our site from your IP address. The following data are transmitted automatically to them: IP address, date and time of access.

If you click on the Youtube link while you are logged on to your Youtube account, Youtube can allocate the visit of our website to your account.

YouTube is used to help make our website appealing. This constitutes a justified interest pursuant to Art. 6 (1) (f) GDPR.

We have no influence on the handling and storage of your data by Youtube. Please obtain more information from its Privacy Policy https://policies.google.com/privacy?hl=de&gl=de.

If you do not want Youtube to allocate the visit of our website with your account, please log out from your Youtube account. If you’re logged in to your YouTube account, YouTube allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your YouTube account.


XIII. Vimeo

Our website includes links to the video portal Vimeo, which is operated by Vimeo Inc., 555 West 18 Street, New York, New York 10011, USA.

As soon as you click on the Vimeo link on our website, a direct connection between your browser and the Vimeo server is established. This enables Vimeo to receive information that you have visited our site from your IP address. The following data are transmitted automatically to them: IP address, date and time of access.

If you click on the Vimeo link while you are logged on to your Vimeo account, Vimeo can allocate the visit of our website to your account.

Vimeo is used to help make our website appealing. This constitutes a justified interest pursuant to Art. 6 (1) (f) GDPR.

We have no influence on the handling and storage of your data by Vimeo. Please obtain more information from its Privacy Policy on https://vimeo.com/privacy.

If you do not want Vimeo to allocate the visit of our website with your account, please log out from your Vimeo account.

If you’re logged in to your Vimeo account, Vimeo allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your Vimeo account.


XIV. Google Maps

Our website uses the Google Maps Map services via an API. It is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

To use Google Maps, its is necessary to save your IP address. This information is generally transmitted to a Google server in the U.S. and stored there. The provider of our website has no influence on this data transfer.

The use of Google Maps is in the interest of making our website appealing and to facilitate the location of places specified by us on our website. This constitutes a justified interest pursuant to Article 6 No. 1 f) GDPR.

We have no influence on the handling and storage of your IP address by Google. More information can be found in the Privacy Policy of Google at httsp://www.google.de/intl/de/policies/privacy/.

In order to use Google Maps via our website, the transmission of your IP Address  to Google is necessary. It follows that there is no right to object against the collection and storage of your IP address in this case. You can avoid the transmission and storage of your IP address by Google if you decide not to use the Google Maps Map service via our website.

 

XV. Google Web Fonts

For uniform representation of fonts, this page uses web fonts provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. When you open a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly.

For this purpose your browser has to establish a direct connection to Google servers. Google thus becomes aware that our web page was accessed via your IP address. To use Google Fonts, it is necessary to save your IP address. This information is generally transmitted to a Google server in the U.S. and stored there. The provider of our website has no influence on this data transfer.

The use of Google Web fonts isdone in the interest of a uniform and attractive presentation of our website. This constitutes a justifiedinterest pursuant to Art. 6 (1) (f) DSGVO.If your browser does not support web fonts, a standard font is used by your computer.

You may object to the processing and storage of your personal data directly towards Google.  Further information about handling user data, can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy at https://www.google.com/policies/privacy/.

 

XVI. Rights of the data subject

 

1. Right of access

You have the right to obtain from the responsible party / controller confirmation as to whether or not personal data concerning you are being processed by us. Where is the case, you have the right to access to the personal data and following information:

The purposes of the processing; the categories of personal data concerned; the recipients or categories of recipient to whom the personal data have been or will be disclosed; where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; the existence of the right to request from us rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing; the right to lodge a complaint with a supervisory or authority.

You further have the right to be informed whether your personal data are transferred to a third country or to an international organization as well as of the appropriate safeguards pursuant to Article 46 GDPR relating to the transfer.

2.  Right to rectification

You have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

3. Right to restriction of processing

You have the right to obtain from the controller restriction of processing in the following cases:

– the accuracy of the personal data is contested by you for a period enabling the controller to verify the accuracy of your 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 your personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims

– you have objected to processing pursuant to Article 21 No 1 GDPR pending the verification whether the legitimate grounds of the controller override those of you.

Where processing has been restricted according to one of these grounds, such personal data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a member state.

You will be informed by the controller before the restriction of processing is lifted.

4. Right to erasure

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

– the personal data are no longer necessary in relation to the purpose for which they were collected or otherwise processed

– you withdraw consent on which the processing is based according to Article 6 No. 1 a) GDPR, and where there is no other legal ground for the processing

– you object to the processing pursuant to Article 21 No. 1 and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21 No. 2 GDPR.

– your personal data have been unlawfully processed

– your personal data have to be erased for compliance with a legal obligation in the European Union or member state law to which the controller is subject

– your personal data have been collected in relation to the offer of information society services referred to in Article 8 No. 1.

The right to erasure shall not apply to the extent that processing is necessary:

– for exercising the right of freedom of expression and information

– for compliance with a legal obligation with 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 No. 2 h) and i) as well as Art. 9 No. 3 GDPR

– for the establishment, exercise or defence of legal claims.

5. Right to information

The controller shall communicate any rectification or erasure of your personal data or restriction of processing carried out in accordance with Article 16, Article 17 No. 1 and Article 18 to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The controller shall inform you about those recipients if you request it.

6. Right to data portability

You have the right to receive your personal data which you have provided to the controller in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from us, where:

– the processing is based on your consent pursuant to Article 6 No. 1 a) or on a contract pursuant to Article 6 No. 1 b); and

– the processing is carried out by automated means.

In these cases, you have the right to have your personal data transmitted directly from one controller to another, were technically feasible.

The exercise of these rights is without prejudice to Article 17. These rights shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. These rights shall not adversely affect the rights and freedoms of others.

7. Right to object

You have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on Article 6 No. 1 e) or f), including profiling based on those provisions. We will no longer process the personal data in this case unless we demonstrate compelling legitimate grounds for the processing with override your interest, rights and freedoms or for the establishment, exercise or defence of legal claims.

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

Where you objected to processing for direct marketing purposes, your personal data shall no longer be processed for such purposes.


8. Right to revoke your consent

You have the right to revoke your declaration of consent under data protection law at any time. This will not affect the legality of the processing of your data until the time of revocation.

9. Right to file complains with regulatory authorities

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 your personal data 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 Article 78 GDPR.