Privacy Policy

SERVICE PRIVACE POLICY

PURPOSE OF PRIVACY POLICY

This privacy policy (“Privacy Policy”) explains how we process data, including personal data, in connection with the use of the website at: http://www.vertex.pl/ (the “Website”) by any individual visiting the Website or using one or more of the services or functionalities made available on the Website (“User”). 

The privacy policy also fulfills the information obligation under REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ.EU.L.2016.119.1 of 2016.05.04), hereinafter “RODO”. 

PERSONAL DATA CONTROLLER

The administrator of your personal data is VERTEX S.A. with its registered office in Czechowice-Dziedzice, ul. Elizy Orzeszkowej 26, 43-502 Czechowice-Dziedzice, entered in the register of entrepreneurs of the National Court Register kept by the District Court of Katowice-Wschód in Katowice VIII Economic Department of the National Court Register under the KRS number: 0000288773, possessing the NIP number: 6381532552 (“Administrator”). You may contact the Administrator by writing to the postal address: 26 Elizy Orzeszkowej Street, 43-502 Czechowice-Dziedzice or to the e-mail address: poczta@vertex.pl or by phone at: (32) 214 53 30.

PURPOSES OF PERSONAL DATA PROCESSING AND LEGAL GROUNDS FOR PROCESSING

Use of the Service

The Service performs the functions of obtaining information about Users and their behavior in the following ways:

  • By recording technical logs at the web server level,
  • by voluntarily entering in the form on the Contact Us tab, 
  • By storing cookies (so-called “cookies”) in the end devices.

Information about certain behaviors of Users is subject to logging in the server layer. 

The resources viewed are identified by URLs. In addition, the following, among others, may be recorded: 

  • time of arrival of the query,
  • time to send a response,
  • The name of the client station – identification implemented by the HTTP protocol,
  • domain name,
  • information about the IP address assigned to the User’s device or the external IP address of the User’s ISP,
  • Information about errors that occurred during the execution of HTTP transactions,
  • URL address of the page previously visited by the User (referer link) – in case the access to the Website was through a link,
  • information about the User’s web browser,
  • Information about the operating system the User is using.

Personal data of Service Users (including IP address or other identifiers and information collected through cookies or other similar technologies), are processed by the Administrator:

  • in order to make available the content collected on the Service – the legal basis for the processing is our legitimate interest in disseminating our content (Article 6(1)(f) RODO);
  • for analytical and statistical purposes, to conduct analyses of Users’ activities, as well as their preferences, to improve the functionalities used and services provided, and to optimize both its website and advertising – the legal basis for processing is our legitimate interest (Article 6(1)(f) RODO);
  • for the purpose of possibly establishing, investigating or defending against claims – the legal basis for the processing is our legitimate interest (Article 6(1)(f) RODO) in protecting our rights.

The data recorded in the server logs are not associated with specific individuals using the Website and are not used by us to identify you. The information collected in the logs is processed primarily for the purpose of providing services and making available the content collected on the Website – the legal basis for the processing is our legitimate interest in distributing our content (Article 6(1)(f) RODO). The content of the logs is not disclosed to anyone except those authorized to administer the server. The Administrator also processes this data for technical, administrative purposes, for the purposes of ensuring the security of the IT system and its management, as well as for analytical and statistical purposes – in this regard, the legal basis for processing is the Administrator’s legitimate interest (Article 6(1)(f) RODO).

Contact form under “Contact Us” 

Using the contact form located on the website http://www.vertex.pl/ in the “Contact Us” tab requires providing personal data marked as mandatory – name, surname, email. Failure to provide them will result in the inability to service the request. Provision of other data is optional. Personal data collected through the contact form are used only to send inquiries related to the Administrator’s activities. 

Your personal data provided in the form is processed:

  • for the purpose of identifying the sender, dealing with the matter described in the form and responding to the inquiry addressed to the Administrator in the content of the contact form – the legal basis for processing is the previously given consent referred to in Article 6(1)(a) of the DPA or the necessity to take action at your request (Article 6(1)(b) of the DPA);
  • for analytical and statistical purposes – the legal basis for the processing is our legitimate interest (Article 6(1)(f) RODO), which consists in keeping statistics on cases reported by users via the Service, among other things in order to improve its functionality;
  • for the purpose of establishing, investigating or defending against claims related to your inquiry and ensuring accountability (demonstrating the Administrator’s compliance with its obligations under the law) – the legal basis for processing is necessity for the purposes of the legitimate interests pursued by the Administrator (Article 6(1)(f) RODO);
  • in order to carry out activities in the form of direct marketing consisting in sending commercial information, in particular sending information about the Administrator’s activities, events organized by the Administrator, the Administrator’s products, services, – if you request us to send such information – the legal basis for processing is the previously granted consent referred to in Article 6(1)(a) RODO. 

Email correspondence (via the email addresses listed in the Contact Us tab)

Your personal data provided in the e-mail is processed:

  • for the purpose of identifying the sender, dealing with the matter described in the email, and responding to the inquiry addressed to the Administrator in the body of the email – the legal basis for processing is the necessity to take action at your request (Article 6(1)(b) RODO);
  •  in order to conduct email exchanges regarding the Administrator’s business, to conclude and execute an agreement, to take actions that are the subject of the Administrator’s business, and to take necessary actions before concluding an agreement/preceding actions that are the subject of the Administrator’s business – the legal basis for processing is Article 6(1)(b) of the DPA;
  • in order to fulfill the Administrator’s legal obligations in connection with the conclusion and performance of the contract (tax, accounting, archiving obligations) – the legal basis for processing is Article 6(1)(c) of the DPA;
  • in order to carry out activities in the form of direct marketing consisting in sending commercial information, in particular sending information about the Administrator’s activities, events organized by the Administrator, the Administrator’s products, services, – if you request us to send such information – the legal basis for processing is the previously granted consent referred to in Article 6(1)(a) RODO ;
  • for the purpose of possible establishment, investigation of claims or defense against claims, arising from a concluded contract or statutory activity, which is a legitimate interest of the Administrator – the legal basis for processing is Article 6(1)(f) RODO,
  • for archival (evidential) purposes to secure information in the event of a legal need to prove facts, which is a legitimate interest of the Administrator – the legal basis for processing is Article 6(1)(f) of the RODO.

The provision of personal data by you is voluntary, but the consequence of failure to provide the necessary data will be the inability to conclude and perform a contract or undertake activities that are the subject of the Administrator’s activities, and the inability of the Administrator to fulfill the purpose of processing with respect to the activities in which personal data obtained from you are processed.

Phone call (via the phone numbers listed in the Contact Us tab)

In the case of a telephone call, we ask for personal information only if it is necessary to handle the matter with which you are calling us.

Your personal data provided in the phone call is processed:

  • for the purpose of having a conversation with you and settling the matter to which it relates – the legal basis for processing is the necessity to take action at your request (Article 6(1)(b) of the DPA).

COOKIES

Cookies are computer data, in particular small text files, recorded and stored on the terminal devices through which you use the Website. The next time you visit the Website, using the same device, the information stored in the Cookies will be transmitted to our website (“own Cookies”) or to another website to which the Cookies belong (“external Cookies”).  

Cookies are safe for your end device. In particular, by this route it is not possible for viruses or other unwanted software or malware to enter your end device. These cookies allow us to identify the software used by the User and customize the Service for each individual User. We use Cookies in order to be able to design and display the Service in an optimal way, adapted to your preferences. In this respect, only the Cookies themselves are identified on your device. Outside of this scope, your personal data will be stored with your express consent, or if it is absolutely necessary in order to be able to use the services offered appropriately used by you.

More information about cookies can be found in the “Help” section of your browser and in the description of the aforementioned tools implemented on our website in this privacy policy. 

The website uses the following cookies, the scope and functionality of which are explained below:

  • Technical Cookies,
  • Functional and performance cookies 
  • Consent-based cookies (e.g. Marketing) 

Re. a) Technical Cookies enable you to use the services available on the Website and are necessary for the proper operation of the Website. Technical Cookies ensure the operation of functions without which you would not be able to use our Site properly. We use them in order to: maintaining the session of the User of the Website, correct configuration of selected functions of the Website, enabling, in particular, verification of the authenticity of the browser session, ensuring proper display of the website – depending on which device the User uses, adapting our services to your choices that are technically relevant to the operation of the Website, ensuring the security and reliability of the Website. These Cookies are proprietary Cookies. This means that all data stored in these Cookies will be returned to our website. The use of technical Cookies on the Website is possible without your consent. Therefore, Technical Cookies cannot be activated or deactivated individually. However, you can deactivate Cookies in your browser at any time. Legal basis: Article 6 (1) (b) RODO (situation similar to a contract).

Ad. b) Functional cookies enable “remembering” the User’s selected settings and personalizing the User’s interface, e.g. with regard to the User’s selected language or region of origin, font size, website design, etc. Performance Cookies enable the collection of information about the use of the Website’s pages in order to improve its attractiveness, content and functionality. These Cookies, for example, allow us to determine whether and which subpages of our website are visited, as well as which content Users are particularly interested in. Specifically, we record the number of visits to the site, the number of sub-pages visited, the time spent on our site, the order of pages visited, what search terms led you to us, the country, region and, if applicable, the city from which access was made. Based on this, we can more accurately tailor the content on our website to the needs of our users and optimize our offerings. The IP address of your computer that is transmitted for technical reasons is automatically anonymized and does not allow us to draw any conclusions about the individual user. You can adjust your cookie settings in your browser at any time. Legal basis: Article 6(1)(f) RODO (legitimate interest).

Ad. c) Cookies that are not technical cookies or functional or performance cookies will be used with your explicit consent, such as marketing cookies. With these cookies, we profile the advertisements displayed both on external websites and on this Website, according to the users’ preferences in choosing services, based on the data held by the Administrator, including the users’ behavior on the Website. If you consent to marketing cookies, then we will be able to use information about your behavior on the Website to tailor advertisements. We believe that you, as a user, will benefit from such a solution because we display ads or content that we think will match your interests based on your online behavior. As a result, you will see fewer random advertisements or content that may be of less interest to you.

By accessing the Website, you may choose not to consent to the use of cookies for marketing purposes. We also reserve the right to use information we have obtained from Cookies from anonymous analysis of the behavior of visitors to our website to display specific advertisements on our websites. Marketing Cookies come from third-party advertising entities (third-party Cookies) and are used to collect information about the websites you visit in order to create a profiled advertisement for you. Legal basis: Article 6(1)(a) RODO (consent). Marketing cookies will be valid for a maximum period of 12 months from the moment of their installation.

You may withdraw your consent to the use of consent-based Cookies at any time, with effect for the future, by adjusting your settings accordingly Cookies. Legal basis: Article 6(1)(a) RODO (consent). In addition, we use technology provided by Google to broadcast advertisements on the Internet, so you can additionally specify whether you consent to the profiling of advertisements on the Internet at this address: https://myadcenter.google.com/home?hl=pl&sasb=true&ref=ad-settings. 

We also divide all cookies by the length of time they are installed in the User’s browser into:  

  • Session cookies: these are temporary files, stored on the User’s device and remain there until the end of the session of a given web browser (until you leave the Website or turn off the software (web browser). The stored information is then permanently deleted from the device’s memory. The mechanism of session cookies does not allow the collection of any personal data or any confidential information from the User’s device.
  • Persistent cookies: these are files stored on the User’s device and remain there until they are deleted. Ending the session of a particular browser or switching off the device does not delete them from the User’s device. The mechanism of persistent cookies does not allow the collection of any personal data or any confidential information from the User’s device.

Social plugins

The Administrator processes personal data of Users visiting the Administrator’s profiles maintained on social media (Facebook, YouTube, LinkedIn, Instagram) . The data is processed solely in connection with the operation of the profile, including for the purpose of informing Users about the Administrator’s activities and promoting its activities and various events, services and products. The legal basis for the Administrator’s processing of personal data for this purpose is its legitimate interest (Article 6(1)(f) of the DPA), which is to promote the Administrator’s activities. 

 

Facebook, Instagram

Our website uses social plug-ins from the social networks Facebook.com and Instagram.com managed by Meta Platforms Ireland Limited (“Facebook”). The plug-in is identified by the Facebook or Instagram logo. When a User visits a page on our website containing a plug-in, they are initially deactivated. The plug-ins are not activated until the User clicks on a button on the page. By activating the plug-ins, the User establishes a connection to Facebook or Instagram and consents to the transfer of data to Facebook or Instagram, respectively. When browsing the content of our Service in which a social plug-in has been integrated, the social network establishes a direct connection with the browser. Through this, the social network receives, among other things, information that you have visited us from a particular IP address or device ID. This occurs regardless of whether you are currently logged in or registered with the social network at all. If you are simultaneously logged in to a particular social network, the social network automatically attributes your visit to the site to your profile. Also, when you use social plugins and, for example, recommend an article or other content, the social network may attribute this information to your profile. For information on the scope and purpose of data collection, its further processing and use by Facebook, Instagram or Twitter, your rights and the settings you can configure to protect your privacy, please refer to Facebook(https://pl-pl.facebook.com/privacy/explanation) and Instagram (https://help.instagram.com/833836199971426/?locale=pl_PL) data protection regulations. If you do not want Facebook or Instagram to collect data about you through our website, you should log out of Facebook or Instagram before visiting our websites.

YouTube

Our website uses the YouTube video platform, currently managed by Google Ireland Limited. YouTube is a platform that enables the playback of audio and video files. When a page is loaded on our website, the integrated YouTube player establishes a connection with YouTube to guarantee technical transmission of the audio or video file. Once the connection to YouTube is established, data transfer to YouTube takes place. For information on the scope and purpose of data collection, its further processing and use by YouTube, and your rights and the settings you can configure to protect your privacy, please refer to YouTube’s data protection regulations (https://policies.google.com/privacy?hl=pl)

LinkedIn

Our website uses a social plug-in from the Linkedin.com social network, managed by LinkedIn Ireland Unlimited Company (“LinkedIn”). The plug-in is marked with either the LinkedIn logo or the ”Share on LinkedIn” button. When a User visits a page on our website containing the plug-in, it is initially deactivated. The plug-in is not activated until the User clicks on the button on the page. By activating the plug-in, the User establishes a connection to LinkedIn and agrees to transfer data to LinkedIn. If the User is logged into LinkedIn, LinkedIn can associate the visit with the User’s LinkedIn account. When the appropriate button is pressed, the relevant information is transferred directly to LinkedIn via the User’s browser and stored there. For information on the scope and purpose of data collection, its further processing and use by LinkedIn, the User’s rights and the settings the User can configure to protect his or her privacy, please refer to LinkedIn’s data protection regulations (https://www.linkedin.com/legal/privacy-policy?_l=pl_PL).

Google Analytics

In order to analyze the statistics of the Website, the Administrator uses Google Analytics – a tool for statistical analysis of websites created by Google Ireland Limited, which collects information about visits to the Website, such as sub-pages displayed, time spent on the website or transitions between different sub-pages. Analysis of Users’ use of the Site is performed using cookies stored on the User’s computer. This information is used to create statistics and traffic report on the Site, as well as statistics related to the activity of visitors to the Site. Detailed information on Google’s terms of use and privacy policy can be found at https://policies.google.com/privacy?hl=pl.

You may prevent your data from being used in Google Analytics by downloading and installing the Google Analytics Blocking Browser Add-on, available at: https://tools.google.com/dlpage/gaoptout?hl=pl. 

The information collected by Google Analytics and stored as described above, may also be used to create remarketing groups and use this remarketing list data to target ads in Google Ads to specific audiences from among those collected in Google Analytics remarketing groups. For this purpose, the Service also uses additional Google Analytics functions (Google Analytics Advertising Functions). The Google Analytics Advertising Functions implemented on this Website are:

– Google ad network impression reports;

– Google’s demographic and interest data reports;

– Integrated services that require Google Analytics to collect data for advertising purposes, including the collection of data via advertising cookies and identifiers.

For this reason, we use Google Analytics cookies, as well as advertising cookies and identifiers to optimize the performance of our website.

You can prevent your participation in this tracking process in various ways:

(a) by setting your browser software accordingly;

(b) by your advertising settings on Google at: https://www.google.com/ads/preferences/?hl=pl; c) by setting your preferences cookies accordingly.

Alternatively, you will find more information on the Network Advertising Initiative (NAI) website at http://www.networkadvertising.org.

Cookies are used on the basis of your consent. For further information, please refer to the paragraph on Cookies.

Period of use Cookies: up to 13 months. 

Legal basis: Article 6(1)(a) RODO (consent).

Google Signals

Google Signals collects cross-device data from users who have signed into their Google account on multiple devices and have ad personalization enabled on their account, such as Gmail, Google+, YouTube, Google Play and other Google platforms.  This feature enables the creation of personalized themes for Users, displaying campaigns of interest to them using different devices and analyzing their behavior using specific reports that do not collect personally identifiable information. For more information, please visit: https://support.google.com/analytics/answer/7532985?hl=pl#zippy=%2C. You can prevent your participation in this tracking process in various ways:

(a) by setting your browser software accordingly;

(b) through Google’s ad settings at: https://www.google.com/ads/preferences/?hl=pl; https://support.google.com/analytics/answer/9050852?hl=pl

(c) by setting your cookie preferences accordingly

Google reCAPTCHA 

We use the reCAPTCHA service on our website. A query via Google reCAPTCHA is used to distinguish whether the input data is entered by a human or by automated, mechanical processing. The query involves sending Google the IP address and other data required by Google for the reCAPTCHA service. 

The legal basis for the processing in such a case is the Administrator’s legitimate interest (Article 6(1)(f) RODO) in protecting Customer forms and its website from attacks and checking that such forms are used by Customers and not by bots.

For more information on Google’s reCAPTCHA service and related privacy statement, visit: https://policies.google.com/privacy?hl=pl. 

Google Ads

We use conversion tracking and remarketing to measure the effectiveness of advertising our Service through the Google Ads platform and to optimize our ads that appear there. These are tools that allow us to find out what happened after a potential customer’s interaction with an ad-whether he or she completed an action that we determined to be valuable.  This allows us to optimize the promotional activities we conduct within the Google Ads platform. Using the Google Ads tool: (a) we can see which keywords, ads, ad groups and campaigns are most effective in attracting valuable actions from people, (b) we know our return on investment (ROI) in advertising and make informed decisions related to ad spending, (c) we automatically optimize ongoing campaigns for our business goals, (d) we can see how many people interact with our ads on one device or browser and convert on another, (e) we can display AdWords ads to people who have visited our sites. The remarketing feature allows us to present Service Users with ads based on their interests from other websites belonging to Google’s advertising network (on Google’s search engine or YouTube, the so-called “Google Ads” or other websites). For this purpose, users’ interaction on our website is analyzed, e.g. which content interested the user, so that we can display targeted ads to users even if they visit our website on other sites. To achieve this, Google stores cookies in the browsers of users who visit certain Google services or websites. Cookies are used on the basis of your consent. For further information, cf. the paragraph on Cookies. Details related to data processing within Google AdWords can be found at: https://policies.google.com/privacy.

You can prevent your participation in the tracking process in various ways: a) by setting your browser accordingly; b) by deactivating cookies for conversion tracking, by setting your browser to block cookies from the domain www.googleadservice.com, https://www.google.pl/settings/ads, https://adssettings.google.com, this setting will be removed when you delete your cookies; c) by deactivating vendor ads, based on interests, which are part of the “About Ads” self-regulatory campaign available at http://www.aboutads.info/choices, this setting will be removed when you delete your cookies; d) by permanently deactivating ads in Firefox, Internet Explorer or Google Chrome in your browsers using the link http://www.google.com/settings/ads/plugin; e) by appropriately setting your preferences cookies. 

Time of use of cookies: up to 360 days.

Legal basis: Article 6(1lit a) RODO (consent).

Google AdSense

We belong to the Google AdSense advertising network. This involves the use of cookies from Google regarding the Google AdSense service (displaying ads based on your previous visits). Within the mechanism for managing your cookie settings, you have the opportunity to decide whether or not we will be able to use personalized Google AdSense ads for you. Just go to https://adssettings.google.com/authenticated. 

THE ABILITY TO SPECIFY THE CONDITIONS UNDER WHICH COOKIES ARE STORED OR ACCESSED

The User may independently and at any time change the settings for Cookies, specifying the conditions for storing and accessing by Cookies to the User’s Device. The User may change the settings referred to in the preceding sentence by means of the settings of the Internet browser or by means of the configuration of the service. These settings can be changed, in particular, in such a way as to block the automatic handling of cookies in the settings of the web browser or inform on their placement on the User’s device each time. Detailed information about the possibility and methods of handling cookies is available in the settings of your software (your web browser).

The user can delete cookies at any time by using the available functions in the web browser they are using.

Restricting the use of cookies, may affect some of the functionality available on the Website.

PERIOD OF PROCESSING OF PERSONAL DATA

The period of processing of personal data by the Administrator depends on the type of service provided and the purpose of processing. However, the Administrator ensures that it keeps the data only for the time that is necessary to achieve the aforementioned purposes. As a rule, data are processed: – for the duration of providing the service, – for the duration of carrying out activities that are the subject of the Administrator’s activities, – until the withdrawal of the consent given (in the case of data processing on the basis of consent), – for the duration of verifying the undertaking of activities that are the subject of the Administrator’s activities, – until the expiration of any statute of limitations, – until the termination of the Administrator’s legitimate interest (in the case of data processing on the basis of the Administrator’s legitimate interest), or until the filing of an effective objection against further processing by the data subject. The period of data processing may be extended in case the processing is necessary for the establishment, investigation or defense against possible claims, but for no longer than 6 years, and after this period, only in case and to the extent required by law. After the expiration of the processing period, the data are irreversibly deleted or anonymized.

RIGHTS OF DATA SUBJECTS

Under the RODO, you are entitled to:

  1. The right to access your data, under the terms of Article 15 of the RODO,
  2. The right to rectify data, under the terms of Article 16 of the RODO,
  3. The right to erasure, under the terms of Article 17 of the RODO,
  4. The right to restrict data processing, under the terms of Article 18 RODO,
  5. The right to data portability, under the terms of Article 20 of the RODO;
  6. The right to object to the processing of data, under the terms of Article 21 of the RODO [where the basis for the processing of personal data is the pursuit of legitimate interests by the Administrator (referred to above), under the terms and in the cases provided for in the RODO regulations, the persons whose personal data are processed have the right to object to the processing of data at any time to the Administrator on grounds relating to their particular situation],
  7. The right to withdraw consent to the processing of personal data, if the processing is carried out on the basis of Article 6(1)(a) RODO or Article 9(2)(a) RODO. Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.

The personal data you provide is not subject to automated decision-making (profiling). 

If you consider that the Administrator’s processing of your personal data violates the provisions of the RODO, you have the right to file a complaint with the supervisory authority, which is the President of the Office for Personal Data Protection.

DATA RECIPIENTS

In connection with the processing of data for the purposes indicated above, your personal data may be shared with other recipients of personal data. Your personal data will/may be transferred to:

  1. entities authorized to process personal data on behalf of the Administrator, i.e., among others, the Administrator’s employees and/or persons employed on a basis other than the Administrator’s employment relationship (providing work on the basis of civil law contracts and on the basis of business activity),
  2. entities authorized to receive your personal data under the relevant laws, mainly public authorities and entities performing public tasks or acting on behalf of public authorities, to the extent and for the purposes that result from the provisions of generally applicable law,
  3. Entities that process your personal data on behalf of the Administrator (entities whose services the Administrator uses in carrying out its tasks) on the basis of an agreement concluded with the Administrator for the entrustment of personal data processing (so-called processors), e.g. providers of analytical and marketing functionalities, providers responsible for the operation of IT systems, entities providing accounting, tax, HR and payroll services, IT and hosting services, document archiving services, services providing legal assistance, companies providing courier and parcel services, marketing agencies. 

TRANSFER OF DATA OUTSIDE THE EUROPEAN ECONOMIC AREA

The Administrator will not transfer personal data to third countries (outside the European Economic Area), or to international organizations.

The website is hosted on a server https://dhosting.pl/. Hosting is provided by dhosting.pl Sp. z o.o headquartered at Warsaw at Al. Jerozolimskie 98, 00-807 Warsaw, hereinafter referred to as “Host”. 

You can learn more about Host’s operations and its privacy policy on its website: https://dhosting.pl/polityka_prywatnosci.html.

PRIVACY POLICY CHANGES

The policy is continuously reviewed and updated as necessary. The Administrator reserves the right to change this policy. Changes will be published in the form of a consolidated text of the policy on the Website, along with information about the changes made.

The current version of the Policy has been adopted and is effective as of 16.02.2024.