Data protection declaration according to the GDPR
I. Name and address of the responsible business
The controller within the meaning of the General Data Protection Regulation and other national data protection laws of the Member States as well as other data protection provisions is:
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Company wording |
GRANDER GmbH. |
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Company register number |
44817 h |
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Commercial Register Court |
Innsbruck Regional Court |
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UID |
ATU 31886108 |
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Address |
Bergwerksweg 10, 6373 Jochberg, Tirol |
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Website |
www.sanomag.com |
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Phone: |
+43 5355 20335 |
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Fax |
+43 5355 20335 50 |
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II. General information on data processing
- Scope of processing of personal data
We generally only collect and use our users' personal data to the extent necessary to provide a functional website and our content and services. The collection and use of our users' personal data generally only occurs with the user's consent. An exception applies in cases where prior consent cannot be obtained for practical reasons and the processing of the data is permitted by law.
- Legal basis for the processing of personal data
To the extent that we obtain the consent of the data subject for processing personal data, Art. 6 (1) (a) of the EU General Data Protection Regulation (GDPR) serves as the legal basis.
For the processing of personal data necessary to fulfill a contract to which the data subject is a party, Art. 6 (1) (b) GDPR serves as the legal basis. This also applies to processing operations necessary to implement pre-contractual measures.
To the extent that the processing of personal data is necessary to fulfill a legal obligation to which our company is subject, Art. 6 (1) (c) GDPR serves as the legal basis.
In the event that the vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) (d) GDPR serves as the legal basis.
If 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 former interest, Art. 6 (1) (f) GDPR serves as the legal basis for processing.
- Data deletion and storage period
The personal data of the data subject will be deleted or blocked as soon as the purpose for which they were stored no longer applies. Storage may also occur if this has been provided for by European or national legislators in EU regulations, laws, or other provisions to which the controller is subject. Data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a need to continue storing the data for the conclusion or fulfillment of a contract.
III. Provision of the website and creation of log files
- Description and scope of data processing
Each time our website is accessed, our system automatically collects data and information from the accessing computer's system.
The following data is collected:
1. Information about the browser type and version used
2. The user's operating system
3. The user's Internet service provider
4. The user's IP address
5. Date and time of access
6. Websites from which the user's system accesses our website
7. Websites accessed by the user's system via our website
This data is also stored in our system's log files. This does not include the user's IP address or other data that allows the data to be assigned to a specific user. This data is not stored together with other personal data of the user.
- Legal basis for data processing
The legal basis for the temporary storage of data is Art. 6 (1) (f) GDPR.
- Purpose of 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 be stored for the duration of the session.
These purposes also constitute our legitimate interest in data processing pursuant to Art. 6 (1) (f) GDPR.
- Duration of storage
The data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of data collected to provide the website, this is the case when the respective session ends.
- Possibility of objection and removal
The collection of data to provide the website and the storage of data in log files are essential for the operation of the website. Therefore, the user has no right to object.
IV. Use of cookies
- Description and scope of data processing
Our website uses cookies. Cookies are text files that are stored in the Internet browser or by the Internet browser on the user's computer system. When a user visits a website, a cookie may be stored on the user's operating system. This cookie contains a characteristic string of characters that enables unique identification of the browser when the website is visited again.
We use cookies to make our website more user-friendly. Some elements of our website require that the visiting browser can be identified even after changing pages.
The following data is stored and transmitted in the cookies:
- Log-in information
We also use cookies on our website that enable us to analyze user browsing behavior.
In this way, the following data can be transmitted:
- Search terms entered
- Frequency of page views
- Use of website functions
When visiting our website, the user is informed about the use of cookies for analysis purposes and their consent is obtained for the processing of personal data used in this context. In this context, reference is also made to this privacy policy.
- Legal basis for data processing
The legal basis for the processing of personal data using technically necessary cookies is Art. 6 (1) (f) GDPR.
The legal basis for the processing of personal data using cookies for analysis purposes, provided the user has given their consent, is Art. 6 (1) (a) GDPR.
- Purpose of data processing
The purpose of using technically necessary cookies is to simplify website use for users. Some functions of our website cannot be offered without the use of cookies. For these functions, it is necessary that the browser is recognized even after changing pages.
We require cookies for the following applications:
- Log-in information
- Search terms entered
- Frequency of page views
- Use of website functions
The user data collected by technically necessary cookies is not used to create user profiles.
Analysis cookies are used to improve the quality of our website and its content. Analysis cookies allow us to learn how the website is used and thus continuously optimize our offering.
Other purposes include improving the quality of our website for our users and making it easier to return to our website.
These purposes also constitute our legitimate interest in processing personal data in accordance with Art. 6 (1) (f) GDPR.
- Duration of storage, possibility of objection and removal
Cookies are stored on the user's computer and transmitted from there to our website. Therefore, you, as the user, have full control over the use of cookies. You can deactivate or restrict the transmission of cookies by changing the settings in your internet browser. Cookies that have already been stored can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, you may no longer be able to fully use all of the website's functions.
V. Newsletter
1. Description and scope of data processing
Our website offers the option of subscribing to a free newsletter. When you register for the newsletter, the data from the input form is transmitted to us, namely:
- Email address
- First name
- Last name
The following data is also collected during registration:
- IP address of the accessing computer
- Date and time of registration
Your consent to the processing of your data is obtained during the registration process, and reference is made to this privacy policy.
No data will be passed on to third parties in connection with data processing for sending newsletters. The data will be used exclusively for sending the newsletter.
2. Legal basis for data processing
The legal basis for the processing of data after the user has registered for the newsletter is Art. 6 (1) (a) GDPR if the user has given his or her consent.
3. Purpose of data processing
The collection of the user's email address serves to deliver the newsletter.
The collection of other personal data during the registration process serves to prevent misuse of the services or the email address used.
4. Duration of storage
The data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected. The user's email address will therefore be stored as long as the newsletter subscription is active.
- Possibility of objection and removal
The user can cancel their newsletter subscription at any time. A corresponding link is provided in each newsletter for this purpose.
This also allows them to revoke their consent to the storage of personal data collected during the registration process.
VI. Contact form
- Description and scope of data processing
On our website, you can contact us via the email address or telephone number provided. In this case, the following personal data submitted by the user in the contact form will be stored:
- First name
- Last name
- Address
- Postal code
- City
- Country
This data will not be passed on to third parties in this context. The data will be used exclusively for processing the conversation.
- Legal basis for data processing
The legal basis for processing the data, provided the user has given their consent, is Art. 6 (1) (a) GDPR.
The legal basis for processing the data transmitted when sending an email is Art. 6 (1) (f) GDPR. If the email contact is aimed at concluding a contract, the additional legal basis for processing is Art. 6 (1) (b) GDPR.
- Purpose of data processing
In the case of contact by e-mail, this also constitutes the necessary legitimate interest in processing the data.
- Duration of storage
The data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected. For personal data sent via email, this is the case when the respective conversation with the user has ended. The conversation is terminated when it can be inferred from the circumstances that the matter in question has been conclusively resolved.
- Possibility of objection and removal
The user has the option to revoke their consent to the processing of personal data at any time. If the user contacts us by email, they can object to the storage of their personal data at any time. In such a case, the conversation cannot be continued.
In this case, all personal data stored during the contact process will be deleted.
VII. Transfer of data to third parties
- Scope of processing of personal data
For order processing and to support our customers in fulfilling their contracts, your personal data will be forwarded to the following companies:
- GRANDER GmbH., Bergwerksweg 10, 6373 Jochberg
The following personal data:
- Company name
- First name
- Last name
- Street / House number
- Zip code / City
- Country
- Customer number
- Email address
- Telephone number
will be forwarded to the companies mentioned.
If you request brochures and information material or purchase goods, your data will be saved so that we can successfully complete the delivery. The following personal data:
- Company name
- First name
- Last name
- Street / House number
- Postal code / City
- Country
will be passed on by us to the following transport companies:
1. General Logistics Systems Austria GmbH, Traunuferstraße 105a, 4052 Ansfelden, Austria
2. LM Logistikmakler.com e.U., Krokusstrasse 7, 4621 Sipbachzell, Austria
3. Österreichische Post Aktiengesellschaft, Rochusplatz 1, 1030 Vienna, Austria
- Legal basis for the processing of personal data
The transfer of data serves to fulfill a contract to which the user is a party or to carry out pre-contractual measures, and therefore forms the legal basis for the processing of the data in Art. 6 (1) (b) GDPR.
- Purpose of data processing
The data collected is necessary to enable the fulfillment of the contract, to enable identification of the user and to ensure proper delivery of the ordered goods.
- Duration of storage
The data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected.
This applies to data collected during the registration process for the fulfillment of a contract or for the implementation of pre-contractual measures, if the data is no longer required for the execution of the contract. Even after the conclusion of the contract, it may be necessary to store the contractual partner's personal data in order to comply with contractual or legal obligations.
- Possibility of objection and removal
As a user, you have the option to cancel your registration at any time. You can have the data stored about you modified at any time.
If the data is required to fulfill a contract or to carry out pre-contractual measures, premature deletion of the data is only possible if contractual or legal obligations do not prevent deletion.
- Processing of data for sales control
For the purpose of sales management (customer support, advice on order processing), data provided during consultation appointment requests as well as other data collected by GRANDER within the scope of the contractual relationship are used. These include, in particular:
1. Company name
2. First name
3. Last name
4. Street / house number
5. ZIP code / city
6. Country
7. Customer number
8. Email address
9. Telephone number
10. Industry-specific information about the company
11. Order and sales data
This processing is necessary so that our GRANDER consultants can provide you with comprehensive and competent advice and support. The legal basis for this processing is Art. 6 (1) (b) and (f) GDPR (contractual performance as well as comprehensive customer support and customer care). The data will be used as long as a customer relationship with you exists or legal claims can still be derived from it, or as long as statutory retention periods require the storage of the data; after this time, the data will be deleted.
VIII. Use of social media plugins
- Scope of processing of personal data
Our website uses social plugins. The social plugins on our website are deactivated by default. Data is only transferred to the respective social network after you activate the social plugins by clicking on them. Activation of the social plugins ends when your cookies are deactivated or deleted.
After activation, a direct connection is established with the server of the respective social network. The content of the button is then transferred directly from the social networks to your browser, which integrates it into the website.
After activating a button, the respective social network can already collect data, regardless of whether you interact with the button. If you are logged in to a social network, it can associate your visit to this website with your user account. If you are a member of a social network and do not want it to link the data collected during your visit to our website with your stored member data, you must log out of the respective social network before activating the buttons.
We have no influence on the amount of data collected by the social networks when you click on the buttons. The purpose and scope of data collection and the further processing and use of the data by the respective social networks as well as your rights and setting options for protecting your privacy can be found in the data protection information of the respective social networks.
- Facebook plugin (Like button)
Our web pages contain plug-ins from the social network Facebook, 1601 South California Avenue, Palo Alto, CA 94304, USA. You can recognize the Facebook plug-in by the Facebook logo or the "Like" button on our page. An overview of Facebook plug-ins can be found at: http://developers.facebook.com/docs/plugins/.
When you activate the plug-in, a direct connection is established between your browser and the Facebook server. Facebook thus receives the information that you have visited our page using your IP address. If you click the Facebook "Like" button while logged into your Facebook account, you can link the content of our pages to your Facebook profile. This allows Facebook to associate your visit to our pages with your user account. We would like to point out that, as the provider of the pages, we have no knowledge of the content of the transmitted data or its use by Facebook. For more information, please see Facebook's privacy policy at: https://www.facebook.com/policies_center
If you do not want Facebook to associate your visit to our pages with your Facebook user account, please log out of your Facebook user account.
1.2. Vimeo
Our website uses plugins from Vimeo LCC, 555 West 18th Street, New York, New York 10011, USA. When you visit one of our pages equipped with a Vimeo plugin, a connection is established to the Vimeo servers. The Vimeo server is informed which of our pages you have visited. If you are logged into your Vimeo account, you allow Vimeo to assign your surfing behavior directly to your personal profile. You can prevent this by logging out of your Vimeo account. Further information on how user data is handled can be found in Vimeo's privacy policy at http://vimeo.com/privacy.
1.3. Twitter
Our website integrates plug-ins from the service Twitter, 1355 Market St, Suite 900, San Francisco, CA 94103, USA. By using Twitter and the "Retweet" function, the web pages you visit are linked to your Twitter account and made known to other users. Data is also transmitted to Twitter in the process.
Please note that, as the provider of these pages, we have no knowledge of the content of the transmitted data or its use by Twitter. Further information can be found in Twitter's privacy policy at https://twitter.com/privacy.
You can change your privacy settings on Twitter in your account settings at http://twitter.com/account/settings.
- Legal basis for the processing of personal data
The legal basis for processing data following user consent is Art. 6 (1) (a) GDPR.
- Possibility of objection and removal
The user can revoke their consent at any time. The user must deactivate the social plugins or delete their cookies.
IX. Website analysis services
1. Scope of processing of personal data
1.1. Web analysis with Matomo
We also use Matomo to collect and evaluate statistical data on the use of our website.
Matomo is installed on our server and also stores data only on our own server in Germany (in-house solution). The data therefore remains under our control and management; it is not transmitted or transferred to an external web analysis service provider.
You can find more information about how Matomo works here.
To protect your privacy, we have implemented the following measures:
- Activation of the Matomo "Anonymize-IP" plug-in: This anonymizes each visitor's IP address before it is saved; this is done by changing the last three octets of the IP address to "0." This virtually eliminates the possibility of tracing the IP address.
- Matomo logs older than seven days are deleted by default.
- Tracking opt-out: You can decide for yourself whether you want to accept the tracking cookie set by Matomo. If you reject cookies, this cookie will not be set.
- You can also object to the tracking of other information (including the collection and analysis of your already anonymized IP address) by activating this link. This will store a Matomo deactivation cookie in your browser. Please note that the Matomo deactivation cookie will be deleted if you delete the cookies stored in your browser. You will also need to deactivate cookies separately if you access our website from a different computer or web browser.
You can change this setting again by clearing your browser's cache.
2. Legal basis for the processing of personal data
The legal basis for processing data following user consent is Art. 6 (1) (a) GDPR.
We use the functions to analyze website usage and for remarketing. These purposes also constitute our legitimate interest in data processing pursuant to Art. 6 (1) (f) GDPR.
3. Possibility of objection and removal
You can prevent the installation and storage of cookies by setting your browser software accordingly; however, we point out that in this case you may not be able to use all the functions of this website to their full extent.
You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by Google by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
3.1. Google Webfonts
This website uses external fonts, Google Fonts. Google Fonts is a service provided by Google Inc. ("Google"). These web fonts are integrated by calling a server, usually a Google server in the USA. This transmits to the server which of our websites you have visited. Google also stores the IP address of the browser on the device used by visitors to these websites. Further information can be found in Google's privacy policy, which you can access here:
https://policies.google.com/privacy
X. Advertising and Marketing Services
1. Facebook Conversion Tracking Pixels
With your consent, our website uses the Conversion Tracking Pixel service from Facebook, Inc., 1601 S. California Ave., Palo Alto, CA 94304, USA ("Facebook"). This allows us to track the actions of our users after they have been redirected to our website by clicking on a Facebook ad. This enables us to record the effectiveness of Facebook ads for statistical and market research purposes. The data collected remains anonymous. This means that we cannot view the personal data of individual users. However, the collected data is stored and processed by Facebook. We will inform you about this matter in accordance with our current information. Facebook can link the data with the data from your Facebook account and uses the data for its own advertising purposes, in accordance with the Facebook data policy https://www.facebook.com/about/privacy/.
Facebook Conversion Tracking also allows Facebook and its partners to show you ads on and off Facebook. In addition, a cookie is stored on your computer for these purposes.
- Facebook retargeting, Facebook custom audiences
This website uses the "Custom Audiences" retargeting feature of the social network Facebook, 1601 South California Avenue, Palo Alto, CA 94304, USA. When you visit our pages, a direct connection is established between your browser and the Facebook server via the retargeting tags. Facebook thus receives the information that you have visited our page using your IP address. This allows Facebook to associate your visit to our pages with your user account. We can use the information obtained in this way to display Facebook ads. Please note that, as the provider of the pages, we have no knowledge of the content of the transmitted data or how Facebook uses it. Further information can be found in Facebook's privacy policy at https://www.facebook.com/about/privacy/.
Please click here to revoke your consent
https://www.facebook.com/ads/website_custom_audiences/.
- Legal basis for the processing of personal data
The legal basis for processing data following user consent is Art. 6 (1) (a) GDPR.
We use the functions to analyze website usage and for advertising measures, which are necessary, among other things, to finance the website. These purposes also constitute our legitimate interest in data processing pursuant to Art. 6 (1) (f) GDPR.
XI. 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:
- Right to information
You can request confirmation from the controller as to whether personal data concerning you is being processed by us.
If such processing occurs, you can request information from the controller about the following:
1. the purposes for which the personal data are being processed;
2. the categories of personal data being 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 storage of the personal data concerning you or, if specific information is not available, criteria for determining the storage period;
5. the existence of a right to rectification or erasure of the personal data concerning you, a right to restriction of processing by the controller, or a right to object to such processing;
6. the existence of a right to lodge a complaint with a supervisory authority;
7. all available information about 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, referred to in Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
You have the right to request information about whether the personal data concerning you will be transferred to a third country or to an international organization. In this context, you can request to be informed of the appropriate safeguards in accordance with Art. 46 GDPR in connection with the transfer.
- Right to rectification
You have the right to request that the controller rectify and/or complete your personal data if it is incorrect or incomplete. The controller must rectify the data immediately.
- 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 oppose the erasure of the personal data and instead request the restriction of their use;
3. the controller no longer needs the personal data for the purposes of the processing, but you require them to assert, exercise, or defend legal claims, or
4. if you have objected to the processing pursuant to Art. 21 (1) GDPR and it has not yet been determined whether the legitimate reasons of the controller outweigh your reasons.
If the processing of personal data concerning you has been restricted, these data – apart from their storage – may only be processed with your consent or for the establishment, exercise, or defense of legal claims or to protect 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-mentioned conditions, you will be informed by the controller before the restriction is lifted.
- Right to erasure
4.1. Obligation to delete
You may request the controller to delete the personal data concerning you immediately, and the controller is obliged to delete this data immediately 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 withdraw your consent on which the processing was based pursuant to Art. 6 (1) (a) or Art. 9 (2) (a) GDPR, and there is no other legal basis for the processing.
3. You object to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) GDPR.
4. The personal data concerning you were processed unlawfully.
5. The erasure of the personal data concerning you is necessary to fulfill a legal obligation under Union or Member State law to which the controller is subject.
6. The personal data concerning you were collected in relation to information society services offered pursuant to Art. 8 (1) GDPR.
4.2 Information to third parties
If the controller has made the personal data concerning you public and is obliged to erase it pursuant to Art. 17 (1) GDPR, the controller shall take appropriate measures, including technical ones, taking into account the available technology and the implementation costs, to inform data controllers which process the personal data that you, as the data subject, have requested the erasure by such controllers of all links to these personal data or of copies or replications of these personal data.
- Exceptions
The right to erasure does not exist if processing is necessary
- to exercise the right to freedom of expression and information;
- to fulfill a legal obligation required by Union or Member State law to which the controller is subject or to perform 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 pursuant to Art. 9 (2) (h) and (i) and Art. 9 (3) GDPR;
- for archiving purposes in the public interest, scientific or research purposes or for statistical purposes pursuant to Art. 89 (1) GDPR, insofar as the right referred to in section a) is likely to make the achievement of the objectives of this processing impossible or seriously compromises it, or
- to assert, exercise or defend legal claims.
5. Right to information
If you have asserted your right to rectification, erasure, or restriction of processing vis-à-vis the controller, the controller is obliged to inform all recipients to whom the personal data concerning you was disclosed of this rectification, erasure, or restriction of processing, unless doing so proves impossible or involves disproportionate effort.
You have the right to be informed by the controller of these recipients.
6. Right to data portability
You have the right to receive the personal data concerning you, which you have provided to the controller, in a structured, common, 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 was provided, provided that:
- the processing is based on consent pursuant to Art. 6 (1) (a) GDPR or Art. 9 (2) (a) GDPR or on a contract pursuant to Art. 6 (1) (b) GDPR, and
- the processing is carried out using automated procedures.
In exercising this right, you also have the right to have the personal data concerning you transmitted directly from one controller to another, where technically feasible. This must not adversely affect the freedoms and rights of others.
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 to object
You have the right to object at any time to the processing of personal data concerning you based on Article 6 (1) (e) or (f) GDPR, for reasons related to your particular situation; this also applies to profiling based on these provisions.
The controller will no longer process the personal data concerning you unless they can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or the processing serves to assert, exercise, or defend legal claims.
If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purposes of such advertising; this also applies to profiling insofar as it is related to such direct marketing.
If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.
In connection with the use of information society services, you have the option of exercising your right of objection by means of automated procedures that use technical specifications, notwithstanding Directive 2002/58/EC.
- Right to revoke the data protection consent declaration
You have the right to revoke your consent to data protection at any time. Revoking your consent does not affect the legality of the processing carried out on the basis of your consent up to the time of revocation.
- Automated decision-making in individual cases, including profiling
You have the right not to be subjected to a decision based solely on automated processing – including profiling – that produces legal effects concerning you or similarly significantly affects you.
This shall not apply if the decision
1. is necessary for entering into or fulfilling a contract between you and the controller,
2. is permitted by Union or Member State law to which the controller is subject, and this law contains appropriate measures to safeguard your rights and freedoms as well as your legitimate interests, or
3. is made with your explicit consent.
However, these decisions may not be based on special categories of personal data pursuant to Art. 9 (1) GDPR, unless Art. 9 (2) (a) or (g) GDPR applies and appropriate measures to protect your rights and freedoms as well as your legitimate interests have been taken.
In the cases referred to in (1) and (3), the controller shall implement appropriate measures to safeguard your rights and freedoms and legitimate interests, including at least the right to obtain human intervention on the part of the controller, to express your point of view and to contest the decision.
10. Right to lodge a complaint with a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.
The supervisory authority with which the complaint was lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 GDPR.