Privacy Policy

1. The key points in brief

2. Controller (verantwortliche Stelle)

The controller for data processing on this website is:

Grone-Bildungszentren Nordrhein-Westfalen GmbH – gemeinnützig –
Königswall 28
44137 Dortmund
Germany

Telephone: 0231 914550-82
Email: projekt@vielfalt-begleiten.nrw
Managing Director authorised to represent the company: Silvana Bluhm

The website belongs to the project “Vielfalt-begleiten.NRW – Integrationsbegleiterinnen in Kitas und der OGS” (integration support workers in daycare centres and after-school care at primary schools). The project is funded by the Ministry of Children, Youth, Family, Equality, Refugees and Integration of the State of North Rhine-Westphalia.

3. Data protection officer (Datenschutzbeauftragter)

You can reach the data protection officer of Grone-Bildungszentren at:

Maximilian Mertin
c/o intersoft consulting services AG
Beim Strohhause 17
20097 Hamburg

Telephone: +49 40 790235-291
Email: datenschutzbeauftragter@grone.de

4. Your rights

You have the following rights towards us with regard to your personal data:

• Access to information on whether we process data about you and, if so, which data (Art. 15 DSGVO [Art. 15 GDPR; DSGVO is the German abbreviation for the General Data Protection Regulation])
• Rectification of inaccurate data (Art. 16 DSGVO [Art. 16 GDPR])
• Erasure, insofar as we no longer need the data and no obligation to retain it prevents this (Art. 17 DSGVO [Art. 17 GDPR])
• Restriction of processing (Art. 18 DSGVO [Art. 18 GDPR])
• Data portability in a commonly used format (Art. 20 DSGVO [Art. 20 GDPR])
• Objection to processing that we base on a legitimate interest (Art. 21 DSGVO [Art. 21 GDPR])
• Withdrawal of consent with effect for the future (Art. 7 Abs. 3 DSGVO [Art. 7(3) GDPR])

For all of these requests, an informal message to projekt@vielfalt-begleiten.nrw or to the data protection officer is sufficient.

Right to lodge a complaint

You also have the right to lodge a complaint with a data protection supervisory authority (Art. 77 DSGVO [Art. 77 GDPR]). You can contact a supervisory authority of your choice, in particular a supervisory authority in the Member State of your habitual residence, your place of work or the place of the alleged infringement. For North Rhine-Westphalia, this is:

Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen (State Commissioner for Data Protection and Freedom of Information of North Rhine-Westphalia)
Kavalleriestraße 2–4, 40213 Düsseldorf
www.ldi.nrw.de

5. Hosting and server logs

This website is hosted by united-domains GmbH, Gautinger Straße 10, 82319 Starnberg. The servers are located in Germany. A data processing agreement pursuant to Art. 28 DSGVO (Art. 28 GDPR) is in place with the provider.

Each time the website is accessed, log files are created on the server. They store:

• the address accessed
• date and time of access
• the amount of data transferred
• browser type and operating system
• the referring page, if your browser transmits it
• the IP address of the requesting device

This information is technically required to deliver the pages and serves to detect faults and attacks. The legal basis is Art. 6 Abs. 1 lit. f DSGVO (Art. 6(1)(f) GDPR); our legitimate interest lies in the secure and error-free operation of the website. The logs are rotated weekly and deleted after eight weeks at the latest. This information is not combined with other data.

6. Cookies, consent and audience measurement

We set technically necessary cookies without consent, because the website does not work without them (§ 25 Abs. 2 Nr. 2 TDDDG [section 25(2) no. 2 of the Telekommunikation-Digitale-Dienste-Datenschutz-Gesetz, the German Telecommunications Digital Services Data Protection Act], Art. 6 Abs. 1 lit. f DSGVO). For everything else we ask you: on your first visit, a consent banner appears in which you can agree to audience measurement or decline it. For the embedded video (section 8), for the AI mode of the tools and for the chat with Luma (section 9) we additionally obtain consent at the point of use before anything is transmitted.

• Login to the editorial area: When a member of the editorial team logs in, WordPress sets a cookie that keeps the login active. For visitors, nothing is created in the process.
• Your decision in the banner: A cookie (adjet_consent, lifetime 365 days) records whether you agreed to audience measurement or declined it, so that we do not ask you again on every visit. It contains only this decision, no identifier of your person.
• Storage used by the tools: The tools in the AI toolbox use the local storage of your browser to remember which role you have selected, which tools you have already opened and whether you have made the companion figure quieter. Luma also remembers there your consent to the chat and whether answers should be read aloud; the conversation itself is kept only in the browser’s session storage and disappears when you close the window. This information does not leave your device and can be deleted at any time using the “Auswahl zurücksetzen” (reset selection) button or via your browser settings.

Section 10 explains which access figures individual plugins of the website record themselves.

Audience measurement with Google Analytics

We want to know which content of this website is needed and which is not. For this we use Google Analytics 4, integrated via the WordPress plugin “Site Kit by Google”. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Measurement starts only when you agree in the consent banner. Before that, no analytics cookies are set and no measurement data is transmitted. If you decline, measurement stays off and the website continues to work in full.

With your consent, Google sets two cookies (_ga and _ga_NXQMX3TFS8, lifetime 400 days each) and processes: the pages viewed, date and time, the approximate region of origin, browser and device type, the referring page and a random identifier that makes your visit distinguishable from others. According to Google, your IP address is used only for rough location determination and is not stored permanently. We receive only aggregated evaluations and cannot identify any individual person from them.

This may involve a transfer to Google LLC in the USA. Google LLC is certified under the EU-US Data Privacy Framework; for companies certified in this way, an adequacy decision of the European Commission exists (Art. 45 DSGVO). The legal basis for the measurement is your consent under Art. 6 Abs. 1 lit. a DSGVO and § 25 Abs. 1 TDDDG.

You can change your decision at any time. With the link at the end of this section you delete the cookies that have been set, and the banner appears again. This withdraws your consent with effect for the future. You can also delete the cookies via your browser settings. Google’s privacy policy is available at policies.google.com/privacy.

Site Kit also connects the website with Google Search Console. There we see which search terms lead to the site in Google Search. No data about your visit is transmitted to Google for this; the information comes from the search itself and contains no names.

Change cookie settings and withdraw consent

7. Contacting us

There is no contact form on this website. You can reach us by email at one of the addresses given or by telephone.

If you contact us by email, we store your message together with the information it contains in order to deal with your request. The legal basis is Art. 6 Abs. 1 lit. b DSGVO (Art. 6(1)(b) GDPR) insofar as the matter concerns initiating or carrying out a collaboration, otherwise Art. 6 Abs. 1 lit. f DSGVO (legitimate interest in answering your enquiry). We do not pass this data on, and we delete it as soon as it is no longer required for the purpose and no statutory retention period prevents this.

8. Embedded video

On the home page you will find a film by AWO Ostwestfalen-Lippe that is published on YouTube. We embed it as a preview image that comes from our own server. As long as you do not click play, nothing is sent to YouTube.

Only when you click is the film loaded from youtube-nocookie.com. The provider then learns that you have visited this page and receives your IP address; depending on your browser settings, further data may be transmitted and content may be stored on your device. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. This may involve a transfer of data to Google LLC in the USA. Google LLC is certified under the EU-US Data Privacy Framework; for companies certified in this way, there is an adequacy decision of the European Commission (Art. 45 DSGVO [Art. 45 GDPR]). We have no influence on further processing by Google.

The legal basis is your consent pursuant to Art. 6 Abs. 1 lit. a DSGVO (Art. 6(1)(a) GDPR) and § 25 Abs. 1 TDDDG (section 25(1) TDDDG), which you give by clicking play. You can withdraw it for the future by not starting the film again and by deleting the data set by YouTube via your browser settings. You can find Google’s privacy policy at policies.google.com/privacy.

9. AI-assisted tools

Under “AI toolbox”, we offer tools that generate texts for you, simplify wording or simulate conversations. You can also chat and talk with Luma, the companion figure at the bottom right of every page.

Practice mode: nothing leaves your device

All tools start in practice mode. In this mode, the page does all its computing exclusively in your browser. No input is transmitted to us or to third parties.

AI mode: transmission to a processor

If you use a tool in AI mode, your input is transmitted via our server to Anthropic PBC, 548 Market Street, San Francisco, CA 94104, USA, and processed there in order to generate the response.

• The transmitted data consists exclusively of your input, the name of the language model used and a description of the task that the tool is meant to perform.
• Not transmitted are your name, your email address, your IP address, any user account or your location.
• Stored on our server are only counter values that we use to limit the number of requests per hour and per day. Your IP address is not stored for this purpose. We merely form a checksum from it using a secret additional value that changes every hour. This checksum is only used within the current hour and is then deleted during the server’s daily clean-up. For Luma we additionally form a checksum with a daily changing additional value in order to limit the number of questions per visitor and day; it is deleted the following day.

Anthropic processes the data as a processor on the basis of a contract pursuant to Art. 28 DSGVO and is contractually not permitted to use it to train its models. The transfer to the USA is based on standard contractual clauses pursuant to Art. 46 Abs. 2 lit. c DSGVO (Art. 46(2)(c) GDPR).

The legal basis for the processing is your consent pursuant to Art. 6 Abs. 1 lit. a DSGVO: for each tool, you decide for yourself whether to use AI mode. Without this decision, no transmission takes place. You can withdraw your consent at any time with effect for the future by no longer using AI mode.

Luma: chat and voice

Luma answers questions about the website and the project. When you type a question to Luma, the same applies as in the AI mode of the tools: your message is transmitted via our server to Anthropic. Along with it we transmit the public texts of this website as the knowledge base and your previous conversation with Luma, so that follow-up questions are understood. The conversation is not stored on our server; your browser keeps it only until you close the window.

When you talk to Luma, your browser starts recording only after you click the microphone; your browser additionally asks you to allow access to the microphone. The recording is transmitted via our server to OpenAI Ireland Ltd., 1st Floor, The Liffey Trust Centre, 117-126 Sheriff Street Upper, Dublin 1, Ireland, and converted into text there; the processing takes place on OpenAI servers in the USA. Luma’s answer is generated as speech at OpenAI and played back to you as an audio file. Neither the recording nor the audio file is stored on our server. OpenAI processes the data as a processor pursuant to Art. 28 DSGVO (Art. 28 GDPR), is contractually not permitted to use it to train its models and deletes it after 30 days at the latest. The transfer to the USA is based on standard contractual clauses pursuant to Art. 46 Abs. 2 lit. c DSGVO (Art. 46(2)(c) GDPR).

Here, too, the legal basis is your consent pursuant to Art. 6 Abs. 1 lit. a DSGVO (Art. 6(1)(a) GDPR) and § 25 Abs. 1 TDDDG (section 25(1) TDDDG), which you give with one click before your first message to Luma; your browser remembers this decision. You withdraw it for the future by no longer using Luma and by deleting this website’s local storage in your browser. Please do not tell Luma any names or personal details.

10. Software used

This website runs on WordPress. For design and functions, we use the theme Hafen and several plugins from the provider hafenstudios. All of these components run on our own server; no data is transferred to the software provider. Only in the AI mode of the tools does anything go to other third parties, and only as described in section 9.

• Hafen and Hafen Core are responsible for design and basic functions and do not process any personal data of visitors.
• Wellenbrecher protects forms and comments against spam. In doing so, technical characteristics of the request and the IP address are assessed. The IP address is stored exclusively as a checksum using a random value that changes weekly; permanent attribution is thereby technically ruled out. The legal basis is Art. 6 Abs. 1 lit. f DSGVO.
• Wimpel provides the pages in several languages and does not process any personal data in doing so.
• Linkjet manages short URLs and redirects. When such a URL is accessed, we store the time, the destination, the referring page and the truncated IP address in order to see which routes are used. The full IP address is not stored. We delete this data after 90 days. The legal basis is Art. 6 Abs. 1 lit. f DSGVO.
• Leadlotse provides forms. No such form is currently set up on this website. As soon as there is one, we will store your details together with the date and time in order to process your enquiry (Art. 6 Abs. 1 lit. b or lit. f DSGVO).
• Hafenstudios Ads can display our own notices and count how often they are viewed. No such notice is currently set up. If one were added, the IP address would be processed to protect against manipulated clicks and, in the process, stored exclusively as a checksum with a secret additional value (Art. 6 Abs. 1 lit. f DSGVO).
• Heckgalerie displays image galleries and does not process any personal data.
• MemberJet would be responsible for protected member areas. As long as no such area is offered and you do not create a user account, MemberJet does not process any data of visitors.
• VB KI-Toolbox provides the tools and the Luma chat described in section 9.

11. Encrypted transmission

This website is delivered exclusively in encrypted form (TLS). You can recognise this by the “https://” in the address bar and by the padlock symbol in your browser. Content that you transmit to us cannot be intercepted and read by third parties.

12. Changes to this policy

This privacy policy is current as of 12 October 2026. If we develop the website further or the legal situation changes, we will adapt it. You will always find the current version on this page.

This is a convenience translation. In case of doubt, the German version applies.