Privacy policy according to the DSGVO

I. Name and address of the person responsible

The responsible person 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 the:

CLASSEN Holz Kontor GmbH
Werner-von-Siemens Str. 18-20
56759 Kaisersesch

Tel: +49 2653-980-0
E-Mail: info@classen.de

Commercial register:
Handelsregister: HRA 4793
Registergericht: Amtsgericht Koblenz

Managing Directors:
Stefanie Quervel, Arne Loebel

II. Name and address of the data protection officer

The data protection officer of the data controller is:

Klaus Keukert
S&L ITcompliance
Florinstraße 18, 56218 Mülheim-Kärlich
E-Mail: kkeukert@sul.de
Website: https://www.sul.de

III. General information on data processing

1. Scope of the processing of personal data

As a matter of principle, we collect and use personal data of our users only insofar as this is necessary for the provision of a functional website as well as our contents and services. The collection and use of our users' personal data regularly only takes place with the user's consent. An exception applies in those cases in which it is not possible to obtain prior consent for actual reasons and the processing of the data is permitted by legal regulations.

2. Legal basis for the processing of personal data

Insofar as we obtain the consent of the data subject for processing operations involving personal data, Art. 6 (1) a of the EU General Data Protection Regulation (GDPR) 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 performance of pre-contractual measures.
Insofar as the processing of personal data is necessary for the fulfilment of a legal obligation to which our company 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.
If the processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6 (1) lit. f DSGVO serves as the legal basis for the processing.

3. Data deletion and storage period

The personal data of the data subject shall be deleted or blocked as soon as the purpose of the storage no longer applies. Storage may also take place if this has been provided for by the European or national legislator in Union regulations, laws or other provisions to which the person responsible is subject. The data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a necessity for the continued storage of the data for the conclusion or fulfilment of a contract.

IV. Provision of the website and creation of log files

1. 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:

  1. Information about the browser type and version used
  2. The operating system of the user
  3. The user's internet service provider
  4. The IP address of the user
  5. Date and time of access
  6. Websites from which the user's system accesses our website
  7. Websites that are accessed by the user's system via our website

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.

2. Legal basis for the data processing

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

3. Purpose of the data processing

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

The storage in log files is done to ensure the functionality of the website. In addition, we use the data to optimise the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.

These purposes are also our legitimate interest in data processing according to Art. 6 para. 1 lit. f DSGVO.

4. Duration of the storage

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.

In the case of storage of data in log files, this is the case after seven days at the latest. Storage beyond this period 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.

5. Possibility of objection and removal

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.

V. Use of cookies

a) 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 calls up 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 calling browser can be identified even after a page change.

The following data is stored and transmitted in the cookies:

  1. Language settings
  2. Log-in information

We also use cookies on our website that enable an analysis of the user's surfing behaviour.
The following data can be transmitted in this way:

  1. Search terms entered
  2. Frequency of page views
  3. Use of website functions

The user data collected in this way is pseudonymised by technical precautions. Therefore, it is no longer possible to assign the data to the calling user. The data is not stored together with other personal data of the user.
When calling up our website, the user is informed about the use of cookies for analysis purposes and his or her consent to the processing of personal data used in this context is obtained. In this context, a reference to this data protection declaration is also made.

b) Legal basis for the data processing

The legal basis for the processing of personal data using technically necessary cookies is Art. 6 para. 1 lit. f DSGVO.
The legal basis for the processing of personal data using cookies for analysis purposes is Art. 6 para. 1 lit. a DSGVO if the user has consented to this.

c) 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.
We require cookies for the following applications:

  1. Adoption of language settings
  2. Remembering search terms

The user data collected through technically necessary cookies are not used to create user profiles.
Analysis cookies are used to improve the quality of our website and its content. Through the analysis cookies, we learn how the website is used and can thus continuously optimise our offer.
These purposes are also our legitimate interest in processing the personal data according to Art. 6 para. 1 lit. f DSGVO.

d) Duration of storage, possibility of objection and elimination

Cookies are stored on the user's computer and transmitted to our site by the user. Therefore, you as a user also have full control over the use of cookies. By changing the settings in your internet browser, you can deactivate or restrict the transmission of cookies. Cookies that have already been stored 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.

VI. Tracking

1. Description and scope of data processing

Personal data of the sender and (substitute) recipient are processed for the performance of a contract.

  1. Name,
  2. Address of the sender and (substitute) recipient,
  3. E-mail address,
  4. Telephone number,
  5. Broadcast information,
  6. Delivery documentation such as signature,
  7. GPS date at the time of the delivery event,
  8. Badge data

2. Legal basis for the data processing

The legal basis is usually Art. 6 para. 1 lit. b DSGVO, as the processing is carried out for the fulfilment of a contract, as well as for the proof of correct service provision, in which you are (indirectly) involved. Furthermore, data processing is carried out for the fulfilment of legal obligations according to Art. 6 para. 1 lit. c DSGVO in connection with contract performance.

3.Purpose of the data processing

Within the scope of the services provided by W. CLASSEN GmbH & Co. KG, personal data is processed on the basis of the contracts concluded with you. This data is used, for example, to execute a (transport) contract, to manage customer data and to process payments.

4. Disclosure of data

For the purpose of delivering ordered goods, we work together with logistics service providers/transport companies: The data provided may be passed on to these for the purpose of delivering the ordered goods, for the provision of information on tracking and tracing, or - insofar as this is necessary - for their announcement. The respective data is transmitted solely for the respective purposes and deleted again after delivery has taken place, insofar as our service providers are not themselves obliged to retain the data for legal reasons.

VII. Contact form and e-mail contact

1. Description and scope of data processing

Our website contains a contact form that can be used for electronic contact. If a user makes use of this option, the data entered in the input mask is transmitted to us and stored. These data are:

  1. Name
  2. Company
  3. Phone
  4. E-mail
  5. Country
  6. Subject
  7. Message

The following data is also stored at the time the message is sent:

  1. The IP address of the user
  2. Date and time of registration

For the processing of the data, your consent is obtained during the submission process and reference is made to this privacy policy.

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

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

2. Purpose of the data processing

The processing of the personal data from the input mask serves us solely to process the contact. In the case of contact by e-mail, this also constitutes the necessary legitimate interest in processing the data.
The other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.

3. Purpose of the data processing

The processing of the personal data from the input mask serves us solely to process the contact. In the case of contact by e-mail, this also constitutes the necessary legitimate interest in processing the data.
The other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.

4. Duration of the storage

The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. For the personal data from the input mask of the contact form and those sent by e-mail, this is the case when the respective conversation with the user has ended. The conversation is ended when the circumstances indicate 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 seven days at the latest.

5. Possibility of objection and removal

The user has the possibility to revoke his consent to the processing of personal data at any time. If the user contacts us by e-mail, he or she can object to the storage of his or her personal data at any time. In such a case, the conversation cannot be continued.

You can send a revocation to info@classen.de at any time.

All personal data stored in the course of contacting us will be deleted in this case.

VIII. Google Analytics

The company uses Google Analytics, a web analytics service provided by Google Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. In the event that IP anonymisation is activated on this website, however, your IP address will be truncated beforehand by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator. The 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 the collection of data generated by the cookie and related to your use of the website (including your IP address) by Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link: tools.google.com/dlpage/gaoptout

The company uses its own cookies at various points on the website https://visiogrande.de, which serve to make the Classen Group's offer more user-friendly. Every user is free to prevent the installation of such cookies by setting their browser accordingly. However, the company points out that the user may not be able to use all functions of the website https://visiogrande.de to their full extent if such a setting is made.

IX. Privacy policy for the use of Google AdWords

We use Google AdWords, an online advertising programme from Google Inc. on our website, which also uses conversion tracking. With this tool, Google AdWords sets a cookie on your PC when you come to our website via a Google advertisement. The cookie is no longer valid after 30 days. It does not serve any personal traceability. If you visit our website as a user and the cookie is still working, it will be recognisable to us together with Google that you clicked on the corresponding advertisement and were redirected to our site. A different cookie is assigned to each Google AdWords customer. Cookies are thus not traceable via the websites of AdWords customers. Conversion statistics for AdWords customers are created with the data collected through conversion cookies. As customers, we thus learn the total number of users who responded to our ad and were then redirected to a website that was tagged with a conversion tracking tag. We do not receive any information during this process with which we could personally identify you as a user. If you reject the tracking procedure, the Google conversion tracking cookie can be deactivated via your internet browser. If necessary, use the browser's help function for further information. You can find out more about Google's privacy policy at http://www.google.de/policies/....

X. Google Maps Plugin

We use a plugin of the internet service Google Maps on our website. The operator of Google Maps is Google Inc., located in the USA, CA 94043, 1600 Amphitheatre Parkway, Mountain View. When you use Google Maps on our website, information about the use of this website and your IP address is transmitted to a Google server in the USA and also stored on this server. We have no knowledge about the exact content of the transmitted data, nor about their use by Google. In this context, the company denies the connection of the data with information from other Google services and the collection of personal data. However, Google may transmit the information to third parties. If you deactivate Javascript in your browser, you will prevent Google Maps from running. However, you will then also not be able to use any map display on our website. By using our website, you consent to the collection and processing of information by Google Inc. as described above. You can find out more about the data protection provisions and terms of use for Google Maps here: https://www.google.com/intl/de....

XI. Google ReCaptcha

We integrate the function for the recognition of bots, e.g. for entries in online forms ("ReCaptcha") of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policie... , Opt-Out: https://adssettings.google.com....

XII. Use of web fonts

External fonts, Google Fonts, are used on these Internet pages. Google Fonts is a service of Google Inc. ("Google"). The integration of these web fonts takes place via a server call, usually a Google server in the USA. This transmits to the server which of our Internet pages you have visited. The IP address of the browser of the end device of the visitor to these Internet pages is also stored by Google. You can find more information in Google's privacy policy, which you can access here:
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XIII. Social Plugins

The website https://visiogrande.de offers you so-called social buttons as an additional service, which enable interaction with social services. In order to prevent an unwanted transmission of your usage data (e.g. address of the currently visited page) to these services, you will only be able to access the services (social media buttons) by clicking on the link. On the respective service page, these social networks may collect usage data and possibly user data. The company cannot influence the extent to which this data is collected and evaluated.

Therefore, we inform you according to our state of knowledge:
Only when calling up the links does your browser possibly establish a direct connection with the servers of the aforementioned services. As a result, the information that you have visited the company's website is forwarded indirectly (referrer) to these services. If you are already logged in to the service with your personal user account
while visiting the website https://visiogrande.de, you can usually "share" the document (so-called "sharing") or leave a comment etc. after clicking on the social buttons. If you do not wish such data transmission, The Company advises you not to click on the social buttons.

The purpose and scope of the data collection by the social services, as well as the further processing and use of your data there, as well as your rights in this regard and setting options for protecting your privacy, can be found in the data protection notices of these services.

XIV. Facebook

The company's website uses plugins from the social network facebook.com, which is operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA ("Facebook").

If you call up Internet pages of the website that are provided with such a plugin, a connection to the Facebook servers is established and the plugin is displayed on the website by informing your browser. This transmits to the Facebook server which of the company's Internet pages you have visited. If you are logged in as a Facebook member, Facebook assigns this information to your personal Facebook user account. When using the plugin functions (e.g. clicking the "Like" button, submitting a comment), this information is also assigned to your Facebook account, which you can only prevent by logging out before using the plugin.

For more information on the collection and use of data by Facebook, your rights in this regard and options for protecting your privacy, please refer to Facebook's privacy policy.

XV. Twitter

Twitter is a microblogging application. It is also defined as a social network or a mostly publicly viewable diary on the internet. Companies and press media use Twitter as a platform for disseminating news. If the Twitter button is called up by the registered user, he or she can continue to "tweet" this page and add a personal text in the length of 140 characters. Twitter collects personal data of its users and shares it with third parties. Twitter sees this information as an asset and reserves the right to sell it if the company changes hands. At the moment, it is still unclear in particular whether the Twitter button also transmits personal data of website visitors to Twitter.com who are not members of Twitter.

XVI. Google+

Our pages use Google+ functions. The provider is Google Inc, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA.
Collection and sharing of information: Using the Google+ button, you can publish information worldwide. Through the Google+ button, you and other users receive personalised content from Google and our partners. Google stores both the information that you have given +1 for a content and information about the page you were viewing when you clicked +1. Your +1s can be displayed as notices together with your profile name and photo in Google services, such as search results or in your Google profile, or elsewhere on websites and ads on the internet.
Google records information about your +1 activities in order to improve Google services for you and others. In order to use the Google+ button, you need a globally visible, public Google profile, which must contain at least the name chosen for the profile. This name is used in all Google services. In some cases, this name may also replace another name you used when sharing content through your Google Account. The identity of your Google profile may be displayed to users who know your email address or have other identifying information about you.
Use of information collected: In addition to the uses explained above, the information you provide will be used in accordance with Google's applicable privacy policy. Google may publish aggregate statistics about users' +1 activities or share them with users and partners, such as publishers, advertisers or affiliated websites.

XVII. YouTube

Our 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 our pages equipped with a YouTube plugin, a connection to the YouTube servers is established. This tells the YouTube server which of our pages 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.
You can find more information on the handling of user data in YouTube's privacy policy at: https://www.google.de/intl/de/...

XVIII. Rights of the data subject

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:

1. Right to information

You may 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:

  1. the purposes for which the personal data are processed;
  2. the categories of personal data which are processed;
  3. the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;
  4. the planned duration of the storage of the personal data relating to you or, if specific information on this is not possible, criteria for determining the storage duration;
  5. the existence of a right to rectify or erase personal data concerning you, a right to have processing restricted by the controller or a right to object to such processing;
  6. the existence of a right of appeal to a supervisory authority;
  7. any available information on the origin of the data if the personal data are not collected from the data subject;
  8. 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 on the data involved.

The data subject shall be informed of the logic involved and the consequences and intended effects of such processing for the data subject.
You have the right to request information on whether personal data concerning you are transferred to a third country or to an international organisation. In this context, you may request to be informed about the appropriate safeguards pursuant to Article 46 of the GDPR in connection with the transfer.

2. Right of rectification

You have a right of rectification and/or completion vis-à-vis the controller if the personal data processed concerning you are inaccurate or incomplete. The controller shall carry out the rectification without undue delay.

3. Right to restriction of processing

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

  1. 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;
  2. the processing is unlawful and you refuse to erase the personal data and instead request the restriction of the use of the personal data;
  3. the controller no longer needs the personal data for the purposes of processing, but you need it for the assertion, exercise or defence of legal claims, or
  4. if you have objected to the processing pursuant to Art. 21 (1) DSGVO and it has not yet been determined whether the legitimate grounds of the controller override your grounds.
    If the processing of personal data relating to you has been restricted, such data may - apart from being stored - only be processed with your consent or for the assertion, 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 Union or a Member State.

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.

4. Right to erasure

a) Obligation to delete

You may request the controller to erase the personal data concerning you without delay and the controller is obliged to erase this data without delay if one of the following reasons applies:

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

b) 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) of the GDPR, it shall take reasonable steps, including technical measures, having regard to the available technology and the cost of implementation, to inform data controllers which process the personal data that you, as the data subject, have requested that they erase all links to, or copies or replications of, that personal data.

c) Exceptions

The right to erasure does not exist insofar as the processing is necessary

  1. to exercise the right to freedom of expression and information;
  2. for compliance with a legal obligation which requires processing under 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;
  3. for reasons of public interest in the area of public health pursuant to Art. 9(2)(h) and (i) and Art. 9(3) DSGVO;
  4. for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Article 89(1) of the GDPR, where the right referred to in Section a) is likely to render impossible or seriously prejudice the achievement of the purposes of such processing, or
  5. for the assertion, exercise or defence of legal claims.

5. Right to information

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

You have the right to be informed of these recipients by the controller.

6. Right to data portability

You have the right to receive the personal data concerning you that 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 whom the personal data has been provided, provided that

  1. the processing is based on consent pursuant to Art. 6 para. 1 lit. a DSGVO or Art. 9 para. 2 lit. a DSGVO or on a contract pursuant to Art. 6 para. 1 lit. b DSGVO and
  2. the processing is carried out with the aid of automated procedures.

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

7. Right of objection

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you 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 controller shall no longer process the personal data concerning you unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the purpose of asserting, exercising or defending legal claims.
If the personal data concerning you is processed for the purposes of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purposes of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
If you object to the processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.
You have the possibility, in connection with the use of information society services, notwithstanding Directive 2002/58/EC, to exercise your right to object by means of automated procedures using technical specifications.

8. Right to revoke the declaration of consent under data protection law

You have the right to revoke your declaration of consent under data protection law at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.

9. Automated decision 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

  1. is necessary for the conclusion or performance of a contract between you and the responsible person,
  2. is authorised by legislation of the Union or the Member States to which the controller is subject and that legislation contains adequate measures to safeguard your rights and freedoms and your legitimate interests, or
  3. is done with your express consent.

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

With regard to the cases referred to in (1) and (3), the controller shall take reasonable steps to safeguard the rights and freedoms of, and your legitimate interests, including at least the right to obtain the intervention of a person on the part of the controller, to express his or her point of view and to contest the decision.

10. 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 relating to 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.