This Personal Data Processing Policy (the “Policy”) defines the procedure and conditions for the collection, processing, storage, and protection of personal data of users of the website https://philipp-cca.de/ (the “Website”) in accordance with the Law of the Republic of Kazakhstan “On Personal Data and Their Protection”.
1. General Provisions
1.1. By using the Website, the User confirms their consent to this Policy and to the processing of their personal data.
1.2. The personal data operator is Philipp TOO, duly registered in accordance with the legislation of the Republic of Kazakhstan (the “Operator”).
1.3. If the User does not agree with the terms of this Policy, they must stop using the Website.
2. Definitions
For the purposes of this Policy:

• Personal Data means information relating to an identified or identifiable individual;
• Processing of Personal Data means any action or set of actions performed with personal data, including collection, recording, systematization, storage, use, transfer, blocking, deletion, and destruction;
• User means an individual using the Website;
• Operator means the entity that processes personal data.

3. Personal Data Collected
The Operator may process the following personal data:

• first name and last name;
• phone number;
• email address;
• messenger account data (WhatsApp, Telegram) if the User initiates communication;
• any other information voluntarily provided by the User via forms on the Website or during correspondence.

The Website may also automatically collect anonymized technical data:

• IP address;
• cookies;
• browser, device, and website usage data.

4. Purposes of Personal Data Processing
Personal data is processed for the following purposes:

• handling user requests, inquiries, and applications;
• providing services and feedback;
• communication with Users via the Website, WhatsApp, and Telegram;
• improving the quality and functionality of the Website;
• sending informational and marketing messages with the User’s consent;
• compliance with the legislation of the Republic of Kazakhstan.

5. Legal Grounds for Processing
Personal data is processed on the basis of:

• the User’s consent to the processing of personal data;
• the necessity to perform obligations to the User;
• requirements of the legislation of the Republic of Kazakhstan.

6. Conditions of Personal Data Processing
6.1. Personal data processing is carried out in a lawful, fair, and confidential manner.
6.2. Personal data is not disclosed to third parties except in cases:

• provided for by the legislation of the Republic of Kazakhstan;
• necessary to fulfill obligations to the User;
• related to the use of communication services (WhatsApp, Telegram) within their functional purpose.

6.3. Personal data is stored only for the period necessary to achieve the purposes of processing.
7. Use of WhatsApp and Telegram
7.1. The Operator may use WhatsApp and Telegram to communicate with Users.
7.2. By initiating communication through these messengers, the User consents to the processing of the personal data transmitted in such communication.
7.3. Correspondence may be stored for the purpose of processing requests and improving service quality.
7.4. Personal data processing within messengers is carried out in accordance with the privacy policies of the respective services.
8. Rights of the Data Subject
The User has the right to:

• receive information about their personal data and its processing;
• request clarification, blocking, or deletion of personal data;
• withdraw consent to personal data processing;
• protect their rights in accordance with the legislation of the Republic of Kazakhstan.

9. Personal Data Protection Measures
9.1. The Operator takes necessary organizational and technical measures to protect personal data from unauthorized access, alteration, disclosure, or destruction.
9.2. Access to personal data is granted only to authorized persons.
10. Final Provisions
10.1. The Operator has the right to amend this Policy without prior notice to Users.
10.2. The current version of the Policy is publicly available on the Website.
11. Operator Contact Information
For matters related to personal data processing, the User may contact:

• Company name:: Philipp TOO
• Email: info@philipp-ca.de
• Phone / WhatsApp / Telegram: +7-771-759-9002

Effective date: 20.01.2026