Privacy Policy

Last updated: September 29, 2026 · Data controller: GOR 22 LTD. OOD (Bulgaria) · Contact: [email protected]

1. Who we are

elizwane.com (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 Trading Tool in Telegram, why we collect it, and what your rights are.

2. Data we collect

Technical / device data — IP address, user agent, country, requested pages, processed by our hosting provider to deliver and secure the Website. Aggregated visit statistics are produced without cookies and without identifying you.
Marketing measurement data — click IDs from Google Ads (GCLID, GBRAID, WBRAID) and campaign UTM parameters from the page address. They are kept in your browser's local storage together with a random visit identifier. When you tap a button leading to our Telegram bot, we send to our server: the visit identifier, these parameters, the time of the tap, the time from opening the page to the tap, the number of taps, whether the Telegram link opened, the landing page, your country and user agent. This lets us attribute a later sign-up in the bot to the ad. In the EEA, the UK and Switzerland none of this is stored or sent until you click “Accept”; if you reject, it is not stored or sent at all.
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 (until you accept, nothing is stored in your browser or sent for attribution); for visitors in other regions — our legitimate interest in measuring advertising, with the option to opt out at any time via “Cookie settings” at the bottom of the main page.
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 local storage

The Website does not load Google Analytics, Google Tag Manager or any other third-party tracking or advertising scripts. It uses only its own local storage entries described in the Cookie Policy, and a security cookie set by Cloudflare.

EEA, the UK and Switzerland (determined by your device's time zone) — a banner asks for your choice. Until you click “Accept”, the visit identifier and click IDs are not stored or sent.
All other regions — the visit identifier and click IDs are stored by default. You can opt out at any time via “Cookie settings” at the bottom of the main page.

You can change your choice at any time via “Cookie settings”, by clearing site data for elizwane.com, or by contacting us.

5. Third parties who may process data

Google LLC / Google Ireland — if you arrived from a Google ad and later sign up in our Telegram bot, the Google click ID may be reported back to Google Ads to measure the ad's effectiveness (offline conversion import). No Google scripts run on this Website. See Google Privacy Policy.
Telegram FZ-LLC — messaging and bot delivery. See Telegram Privacy Policy.
Cloudflare, Inc. — hosting of the Website and its videos, CDN, DNS and security; storage of the visit identifier and click IDs (see section 7). See Cloudflare Privacy Policy.

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. Visit identifiers with click IDs and tap data are stored on Cloudflare servers and deleted automatically after 90 days. In your browser they remain in local storage until you clear site data or opt out. Telegram bot conversations are retained for as long as needed to deliver the educational content and the AI Trading 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 Trading 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.