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Privacy policy

This is the privacy policy for the use of this portal and all subdomains belonging to these domains. The user agrees to the data protection provisions set out here.

All formulations mentioned in the following that refer specifically to one gender are to be understood as expressly applying to all genders.

The processing of personal data within the framework of the use of the aforementioned websites, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the EU Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to the City of Jena, in particular the Thuringian Data Protection Act.

By means of this data protection declaration, the public is informed about the type, scope and purpose of the personal data collected, used and processed by the City of Jena when using the above-mentioned websites. Furthermore, data subjects are informed of their rights by means of this data protection declaration.

The personal data is stored on specially protected servers in Germany. Access to this data is only possible for a few specially authorised persons who are involved in the technical, commercial or editorial maintenance of the servers. The data is conscientiously protected against loss, destruction, falsification, manipulation and unauthorized access or unauthorized disclosure.

Definitions

This data protection declaration is based on the terms used by the European Directive and Ordinance Maker when adopting the DSGVO. This data protection declaration is intended to be easy to read and understand.

To ensure this, the terms used are explained in advance. The following terms, among others, are used in this data protection declaration:

Personal data means any information relating to an identified or identifiable natural person (hereinafter "data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Data subject means any identified or identifiable natural person whose personal data are processed by the controller.

Processing is any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organisation, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Restriction of processing is the marking of stored personal data with the aim of limiting their future processing.

Profiling is any form of automated processing of personal data which consists in using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or change of location.

Pseudonymisation is the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures which ensure that the personal data are not attributed to an identified or identifiable natural person.

The controller or person responsible for processing is the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its designation may be provided for under Union or Member State law.

Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

A recipient is a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not a third party. However, public authorities that may receive personal data in the context of a specific investigation task under Union or Member State law shall not be considered as recipients.

Third party means any natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons who, under the direct authority of the controller or the processor, are authorised to process the personal data.

Consent shall mean any freely given specific and informed indication of the wishes of the data subject, in the form of a declaration or other unambiguous affirmative act, by which the data subject signifies his agreement to the processing of personal data relating to him.

Name and address of the controller and the data protection officers

The data controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is:

Contact person: Annette Schwarze-Engel
Central Coordination Office for Citizen Participation

Am Anger 26
07743 Jena

Tel. 03641 49-5134
fax 03641 49-5005
buergerbeteiligung@jena.de

Data protection officer of the data controller:
Melanie Pesch
At the Anger 15
07743 Jena or P.O. Box 10 03 38, 07703 Jena

Tel. 03641 49-2113
Fax 03641 49-2114
datenschutz@jena.de

Collection of general data and information

The website of the City of Jena collects a series of general data and information each time a data subject or automated system calls up the website. This general data and information is stored in the log files of the server. The following data can be collected

  1. browser types and versions used,
  2. the operating system used by the accessing system,
  3. the website from which an accessing system arrives at the municipal website (so-called referrer),
  4. the sub-websites which are accessed via an accessing system on the municipal website,
  5. the date and time of an access to the website,
  6. an Internet protocol address (IP address),
  7. the Internet service provider of the accessing system and
  8. other similar data and information that serve to avert danger in the event of attacks on the municipal information technology systems.

When using these general data and information, the City of Jena does not draw any conclusions about the data subject. The data stored in the log files are not stored together with other personal data of the user.
The legal basis for the temporary storage of the data and the log files is Art. 6 para. 1 lit. f DSGVO.
This information is required in order to

  1. to deliver the contents of the municipal website correctly,
  2. to optimise the contents of the municipal website as well as the advertising for the same,
  3. to ensure the long-term functionality of the municipal information technology systems and the technology of the website, as well as
  4. to provide law enforcement authorities with the information necessary for prosecution in the event of a cyber-attack.

Therefore, the City of Jena analyzes anonymously collected data and information on one hand for statistical purposes, and on the other hand for the purpose of increasing data protection and data security within the City of Jena, in order to ensure an optimal level of protection for personal data processed by the City of Jena. An analysis of the data for marketing purposes does not take place in this context.

The data is deleted as soon as it is no longer required to achieve 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. Storage beyond this is possible. In this case, the IP addresses of the users are deleted or alienated, so that an assignment of the calling client is no longer possible.

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

Cookies

The Internet pages of the City of Jena use cookies. Cookies are text files that are stored on a computer system via an Internet browser.
Numerous Internet pages and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a string of characters by which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored.

This enables the visited Internet pages and servers to distinguish the individual browser of the person concerned from other Internet browsers that contain other cookies. A specific internet browser can be recognised and identified via the unique cookie ID.
Through the use of cookies, the City of Jena can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on the website can be optimized for the user. For example, the user of an Internet site that uses cookies does not have to re-enter his or her access data each time he or she visits the Internet site, because this is done by the Internet site and the cookie stored on the user's computer system.

The data subject can prevent the setting of cookies by the municipal website at any time by means of an appropriate setting of the Internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time using an Internet browser or other software programs. This is possible in all common Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of the website may be fully usable.

The legal basis for the processing of personal data using cookies is Art. 6 (1) lit. f DSGVO.

Submitting a suggestion

Suggestions can be submitted on this website. In doing so, the following data will be requested and stored:

  • Name*
  • e-mail address*
  • title*
  • Short description*

Fields marked with * are mandatory. The name, title and short description of the proposal will be published. The e-mail address provided will only be used for queries or to confirm whether the proposal is valid or not. The personal data entered by the data subject are collected and stored exclusively for internal use by the data controller and for its own purposes.

The data provided as part of a suggestion will be stored by us permanently until the user objects.

The legal basis for the processing of personal data when submitting a proposal is Art. 6 (1) lit. b DSGVO.

Registration on the website

The data subject has the possibility to register on the website of the controller by providing personal data. Which personal data are transmitted to the controller in the process results from the respective input mask used for the registration.

The personal data entered by the data subject are collected and stored exclusively for internal use by the controller and for its own purposes. The controller may arrange for the data to be transferred to one or more processors, for example a parcel service provider, who will also use the personal data exclusively for an internal use attributable to the controller.

By registering on the website of the controller, the IP address assigned by the internet service provider (ISP) of the data subject, the date as well as the time of registration are furthermore stored. The storage of this data takes place against the background that only in this way can the misuse of the services offered be prevented and, if necessary, this data enables criminal offences committed to be clarified. In principle, this data is not passed on to third parties unless there is a legal obligation to pass it on or the passing on serves the purpose of criminal prosecution.

The registration of the data subject by providing personal data is used by the controller to offer the data subject content or services which, by their nature, can only be offered to registered users. Registered persons are free to modify the personal data provided during registration at any time or to have them completely deleted from the data of the controller.

The controller shall provide any data subject at any time, upon request, with information on what personal data is stored about the data subject. Furthermore, the controller shall correct or delete personal data at the request or indication of the data subject, provided that this does not conflict with any statutory retention obligations. The entire staff of the controller shall be available to the data subject as contact persons in this context.

Registering to vote

On this website, proposals can be voted on during a certain period of time. Registration is required for voting. The following data will be requested and stored:

  • First name
  • Last name
  • Date of birth
  • Address (street, city, postal code)
  • E-mail address

To participate in the voting, the e-mail address must first be confirmed. Subsequently, the data will be checked against the population register. This is necessary because only citizens of Jena who are at least 16 years old can vote. After successful verification, voting can take place. The voting is anonymous, no reference can be made between the votes and the person. The personal data will be stored so that no multiple votes of the same person are possible.

The personal data will be deleted after the end of the voting.

The legal basis for the processing of personal data when submitting a proposal is Art. 6 para. 1 lit. b DSGVO.

Contact possibility via the website

Based on statutory provisions, the website of the City of Jena contains information that enables a quick electronic contact and direct communication, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or by using a contact form, the personal data transmitted by the data subject will be stored automatically.

Such personal data transmitted on a voluntary basis by a data subject to the controller will be stored for the purposes of processing or contacting the data subject. This personal data will not be disclosed to third parties.

Routine erasure and blocking of personal data

The controller shall process and store personal data of the data subject only for the period of time necessary to achieve the purpose of the storage or where provided for by the European Directive and Regulation or other legislator in laws or regulations to which the controller is subject.

If the storage purpose ceases to apply or if a storage period prescribed by the European Directive and Regulation Maker or another competent legislator expires, the personal data will be routinely blocked or deleted in accordance with the statutory provisions.

Rights of the data subject

Every data subject has the right, granted by the European Directive and the Regulation, to obtain confirmation from the controller as to whether personal data concerning him or her are being processed. If a data subject wishes to exercise this right, he or she may, at any time, contact the City of Jena.

Any person concerned by the processing of personal data has the right, granted by the European Directive and Regulation, to obtain at any time from the controller, free of charge, information about the personal data concerning him or her that have been stored and a copy of that information. In addition, the European Directive and Regulation legislator has granted the data subject access to the following information:

  • The purposes of the processing,
  • the categories of personal data processed,
  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular in the case of recipients in third countries or international organisations,
  • if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration,
  • the existence of a right to obtain the rectification or erasure of personal data concerning him or her or to obtain the restriction of processing by the controller or a right to object to such processing,
  • the existence of a right of appeal to a supervisory authority,
  • if the personal data are not collected from the data subject: Any available information about the origin of the data,
  • The existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in these cases, meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.

Furthermore, the data subject shall have the right to obtain information as to whether personal data have been transferred to a third country or to an international organisation. If this is the case, the data subject shall also have the right to obtain information on the appropriate safeguards in relation to the transfer.

If a data subject wishes to exercise this right of access, he or she may contact the City of Jena at any time.

Any person concerned by the processing of personal data has the right, granted by the European Directive and Regulation, to obtain the rectification without delay of inaccurate personal data concerning him or her. Furthermore, the data subject has the right to request the completion of incomplete personal data, including by means of a supplementary declaration, taking into account the purposes of the processing.

If a data subject wishes to exercise this right, he or she may, at any time, contact the City of Jena.

Any person concerned by the processing of personal data has the right, granted by the European Directive and the Regulation, to obtain from the controller the erasure without delay of personal data concerning him or her, where one of the following reasons applies and to the extent that processing is no longer necessary:

  • The personal data were collected or otherwise processed for such purposes for which they are no longer necessary.
  • The data subject withdraws his or her consent on which the processing was based pursuant to Article 6(1)(a) DSGVO or Article 9(2)(a) DSGVO and there is no other legal basis for the processing.
  • The data subject objects to the processing pursuant to Article 21(1) DSGVO and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) DSGVO.
  • The personal data have been processed unlawfully.
  • The erasure of the personal data is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
  • The personal data has been collected in relation to information society services offered pursuant to Article 8(1) DSGVO.

If one of the aforementioned reasons applies, and a data subject wishes to arrange for the erasure of personal data stored by the City of Jena, he or she may, at any time, contact the City.

If the personal data have been made public by the City of Jena and the City as a data controller is obliged to erase the personal data pursuant to Article 17(1) of the Data Protection Regulation, the City shall implement reasonable measures, including technical measures, taking into account the available technology and the cost of implementation, in order to inform other data controllers which process the published personal data, that the data subject has requested from those other data controllers the erasure of all links to the personal data or copies or replications of the personal data, unless the processing is necessary. In individual cases, the necessary steps will be taken.

Any person concerned by the processing of personal data has the right, granted by the European Directive and Regulation, to obtain from the controller the restriction of processing where one of the following conditions is met:

  • The accuracy of the personal data is contested by the data subject for a period enabling the controller to verify the accuracy of the personal data.
  • The processing is unlawful, the data subject objects to the erasure of the personal data and requests instead the restriction of the use of the personal data.
  • The controller no longer needs the personal data for the purposes of the processing, but the data subject needs it to assert, exercise or defend legal claims.
  • The data subject has objected to the processing pursuant to Article 21(1) of the GDPR and it is not yet clear whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of personal data stored by the City of Jena, he or she may, at any time, contact the City. The restriction of the processing will be arranged.

Any person concerned by the processing of personal data has the right, granted by the European Directive and Regulation, to receive the personal data concerning him or her, which have been provided by the data subject to a controller, in a structured, commonly used and machine-readable format.

He or she also has the right to transmit such data to another controller without hindrance from the controller to whom the personal data have been provided, provided that the processing is based on consent pursuant to Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR or on a contract pursuant to Article 6(1)(b) of the GDPR and the processing is carried out by automated means, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, when exercising the right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to obtain that the personal data be transferred directly from one controller to another controller where technically feasible and provided that this does not adversely affect the rights and freedoms of other individuals.

The right to data portability does not apply to 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.

In order to assert the right to data portability, the data subject may at any time contact the City of Jena.

Any person affected by the processing of personal data has the right granted by the European Directive and Regulation to object at any time, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her which is carried out on the basis of Article 6(1)(e) or (f) DSGVO. This also applies to profiling based on these provisions.

The Stadt Jena shall no longer process the personal data in the event of the objection, unless it can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the assertion, exercise or defence of legal claims.

If the City of Jena processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data processed for such marketing. This also applies to the profiling, insofar as it is related to such direct marketing. If the data subject objects to the City of Jena to the processing for direct marketing purposes, the City of Jena will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her carried out by the City of Jena for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the Data Protection Regulation (DSGVO), unless such processing is necessary for the performance of a task carried out in the public interest.

In order to exercise the right to object, the data subject may directly contact the City of Jena. The data subject is also free to exercise his or her right to object by means of automated procedures using technical specifications in the context of the use of information society services, notwithstanding Directive 2002/58/EC.

Any data subject concerned by the processing of personal data shall have the right, granted by the European Directive and the Regulation, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her, unless the decision is necessary for the conclusion or performance of a contract between the data subject and the controller, or

  1. is not necessary for the conclusion or performance of a contract between the data subject and the controller, or
  2. is permitted by Union or Member State law to which the controller is subject, and that law contains suitable measures to safeguard the rights and freedoms and legitimate interests of the data subject; or
  3. is carried out with the express consent of the data subject.

If the decision

  1. is necessary for entering into, or the performance of, a contract between the data subject and the data controller, or
  2. If the decision is made with the explicit consent of the data subject, the City of Jena shall implement suitable measures to safeguard the rights and freedoms as well as the legitimate interests of the data subject, which include at least the right to obtain the intervention of a data subject on the part of the responsible person, to express his or her point of view and to contest the decision.

If the data subject wishes to exercise the rights concerning automated decisions, he or she may, at any time, contact the City of Jena.

Any person affected by the processing of personal data has the right granted by the European Directive and Regulation to withdraw consent to the processing of personal data at any time. The withdrawal of consent shall not affect the lawfulness of the processing carried out on the basis of the consent until the withdrawal. If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact the City of Jena.

Privacy policy on the use and application of Matomo

The controller has integrated the Matomo component on this website. Matomo is an open source software tool for web analysis. Web analysis is the collection, collation and evaluation of data about the behaviour of visitors to websites. Among other things, a web analysis tool collects data about the website from which a data subject has accessed a website (so-called referrer), which sub-pages of the website have been accessed or how often and for how long a sub-page has been viewed. A web analysis is mainly used for the optimisation of a website and for the cost-benefit analysis of internet advertising.

The software is operated on the server of the controller, the data protection sensitive log files are stored exclusively on this server.
The purpose of the Matomo component is to analyse the flow of visitors to this website. The controller uses the data and information obtained, among other things, to evaluate the use of this website in order to compile online reports showing the activities on the municipal websites.

This helps to continuously improve the website and its user-friendliness. These purposes also constitute the legitimate interest in the processing of the data in accordance with Art. 6 Para. 1 lit. f DSGVO. By anonymising the IP address, the interest of users in the protection of their personal data is sufficiently taken into account.

Matomo sets a cookie on the information technology system of the data subject. What cookies are has already been explained above. By setting the cookie, the city of Jena is enabled to analyse the use of the city's website. Each time one of the individual pages of this website is called up, the Internet browser on the information technology system of the data subject is automatically caused by the Matomo component to transmit data to our server for the purpose of online analysis. As part of this technical procedure, we obtain knowledge of personal data, such as the IP address of the data subject, which serves us, among other things, to trace the origin of visitors and clicks.

By means of the cookie, personal information, such as the time of access, the place from which access originated and the frequency of visits to our website are stored. Each time you visit our website, this personal data, including the IP address of the Internet connection used by the person concerned, is transmitted to our server. This personal data is stored by us. This personal data will not be passed on to third parties.

The software is set in such a way that the IP addresses are not stored in full, but 2 bytes of the IP address are masked (e.g.: 192.168.xxx.xxx). In this way, an assignment of the shortened IP address to the calling computer is no longer possible.
The data subject can prevent the setting of cookies by the municipal website, as already described above, at any time by means of an appropriate setting of the Internet browser used and thus permanently object to the setting of cookies. Such a setting of the Internet browser used would also prevent Matomo from setting a cookie on the information technology system of the data subject. In addition, a cookie already set by Matomo can be deleted at any time via an internet browser or other software programs.

Furthermore, the data subject has the possibility to object to the collection of data generated by Matomo and related to a use of this website and to prevent such a collection. For this purpose, the data subject must set an opt-out cookie. If the information technology system of the data subject is deleted, formatted or reinstalled at a later point in time, the data subject must set an opt-out cookie again.

However, with the setting of the opt-out cookie, there is the possibility that the Internet pages of the controller are no longer fully usable for the data subject.

Further information and the applicable data protection provisions of Matomo can be found here.

Disable web analytics

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Legal basis of the processing

Insofar as consent of the data subject is obtained for processing operations of personal data, Art. 6 (1) lit. a EU General Data Protection Regulation (DSGVO) serves as the legal basis.

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

Insofar as processing of personal data is necessary for compliance with a legal obligation to which the City of Jena is subject, Art. 6 (1) c DSGVO serves as the legal basis.
In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 (1) (d) DSGVO serves as the legal basis.

In the event that the processing of personal data is necessary in order to perform a task in the public interest incumbent upon the City of Jena or the processing is carried out in the exercise of official authority, Article 6 (1) (e) DSGVO serves as the legal basis for the processing.

If the processing is necessary to protect a legitimate interest of the City of Jena or a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Article 6 (1) (f) DSGVO serves as the legal basis for the processing.

Legal or contractual provisions for the provision of personal data; necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of non-provision.

The provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual regulations (e.g. information on the contractual partner). Sometimes, in order to conclude a contract, it may be necessary for a data subject to provide personal data that must subsequently be processed by the city.

For example, the data subject is obliged to provide personal data when the City concludes a contract with him or her. Failure to provide the personal data would mean that the contract with the data subject could not be concluded.

Before providing personal data by the data subject, the data subject must contact the City. The data subject will then be informed on a case-by-case basis whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and what the consequences of not providing the personal data would be.

Existence of automated decision-making

The City of Jena does not use automated decision-making or profiling.

Use of YouTube

This website uses plugins from the YouTube site operated by Google. The operator of the pages is YouTube, LLC, 901 Cherry Ave, San Bruno, CA 94066, USA. When you visit one of the websites equipped with a YouTube plugin, a connection to the YouTube servers is established. In doing so, the YouTube server is informed which Internet page you have visited.

If you are logged into your YouTube account, you enable YouTube to assign your surfing behaviour directly to your personal profile. You can prevent this by logging out of your YouTube account.

For more information on the handling of user data, please refer to YouTube's privacy policy.

Use of other services

The following services of Google Inc. are used on this website:

  • Google Fonts
  • Google Translate (website translator)
  • Google reCAPTCHA

Further information and the applicable privacy policy of Google Inc. can be found here.

Social networks

The city of Jena takes the current discussion about data protection in social networks very seriously. It is currently not conclusively clarified in legal terms whether and to what extent all social networks offer their services in accordance with European data protection regulations.

It is therefore expressly pointed out that the services used by the city of Jena Twitter, Facebook, Xing, Google+, Instagram and YouTube store the data of their users (e.g. personal information, IP address) according to their data use policies and use them for business purposes. The city of Jena has no influence on the data collection and its further use by the social networks.

Thus, there is no knowledge about the extent to which, where and for how long the data is stored, to what extent the networks comply with existing deletion obligations, which evaluations and links are made with the data and to whom the data is passed on.

Right to complain to 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 residence, place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 GDPR.

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