Privacy Policy

Last updated: September 15, 2026 · Data controller: GOR 22 LTD. OOD (Bulgaria) · Contact: [email protected]

1. Who we are

elizwane.org (the "Website") is operated by GOR 22 LTD. OOD (“ГОР 22” ООД), a company registered in Bulgaria (D-U-N-S® 503547009), 5 Dimitar Blagoev str., bl. 5, ent. В, fl. 4, ap. 47, Yambol 8600, Bulgaria ("we", "us", "our"). This policy explains what personal data we collect when you visit the Website or use our free AI Analytics Tool in Telegram, why we collect it, and what your rights are.

2. Data we collect

Technical / device data — IP address, user agent, device type, screen size, referrer, pages viewed, time on page.
Marketing measurement data — click IDs (e.g. Google click ID / GCLID), campaign UTM parameters, ad interactions.
Consent data — the choice you make in our cookie banner (accepted / declined) and when you made it.
Telegram-side data (only if you open the bot) — the Telegram user ID, username (if public), messages you send to the bot, plus the click ID passed through the CTA link so we can attribute your session correctly.

3. Purposes and legal bases (GDPR / UK GDPR)

To deliver the Website and secure it against abuse — legitimate interests.
To measure marketing performance (which ads led to which sessions and Telegram opens) — for visitors in the EEA, the UK and Switzerland — your consent via the cookie banner (before consent we operate in a cookieless, consent-denied state); for visitors in other regions — our legitimate interest in measuring advertising, with the option to opt out at any time in the cookie banner.
To respond to enquiries sent to [email protected] — legitimate interests.
To operate the Telegram bot and deliver the educational content you request — performance of an implicit agreement with you as a user.

4. Cookies and Google Consent Mode v2

We use Google Consent Mode v2 (ad_storage, ad_user_data, ad_personalization, analytics_storage). The default settings depend on where you are:

EEA, the UK and Switzerland — advertising and analytics storage is set to "denied" by default. Google Analytics 4, Google Ads and Google Tag Manager run in cookieless mode until you click "Accept" in our banner, at which point storage is set to "granted" and cookies may be written.
All other regions — advertising and analytics storage is set to "granted" by default, so cookies may be written when the page loads. You can opt out at any time: open "Settings" in the cookie banner, switch off analytics and/or advertising and click "Save choice", and storage will be set to "denied".

You can revisit your choice at any time by clearing site data for elizwane.org (the banner will appear again) or by contacting us.

5. Third parties who may process data

Google LLC / Google Ireland — Google Analytics 4, Google Ads, Google Tag Manager (measurement, advertising, tag delivery). See Google Privacy Policy.
Wistia Inc. — video hosting for the hero walkthrough and video reviews. See Wistia Privacy Policy.
Telegram FZ-LLC — messaging and bot delivery. See Telegram Privacy Policy.
Cloudflare, Inc. — CDN, DNS and security. See Cloudflare Privacy Policy.
Hosting provider — static hosting of the Website.

6. International transfers

Data may be processed outside your country of residence, including in the United States, the European Economic Area and other jurisdictions where our service providers operate. Where required, transfers are covered by appropriate safeguards (e.g. Standard Contractual Clauses).

7. Retention

Technical logs are retained for up to 12 months. Marketing measurement data is retained per the provider's default (Google Analytics 4: 14 months for user-level data unless configured otherwise). Telegram bot conversations are retained for as long as needed to deliver the educational content and the AI Analytics Tool.

8. Your rights (GDPR / UK GDPR / CCPA)

You have the right to access, rectify, delete, restrict or object to the processing of your personal data, and to data portability. Under CCPA/CPRA you additionally have the right to know, to delete, to correct, and to opt out of "sale" or "sharing" of personal information. Requests: [email protected].

9. Children

The Website and the AI Analytics Tool are not directed to individuals under 18. We do not knowingly collect personal data from minors.

10. Changes

We may update this policy. When we do, we will change the "Last updated" date at the top and, if the changes are material, notify users in the community.