Penombra by Systema360 Privacy Policy
1. Who we are and what we answer for
Penombra by Systema360 is developed by Systema360 S.r.l.. You can reach us at info@systema360.it, at the certified address systema360@pec.it or at 85100 Potenza (PZ). For privacy matters write to privacy@systema360.it. VAT or tax code: 02227730765.
There is a distinction worth making straight away, because it changes what you can expect from us. The data the app handles stays on your Mac and never reaches us: we do not see it, we do not keep it and we do not determine its purposes or means, so for that data we are not the controller and we would have nothing to hand over if you asked us for it. We are the controller only of what we actually receive, and from the app we receive nothing. From the website we receive only the address you leave for the waiting list, handled as described in point 8.
2. Data the app handles on your device
Penombra by Systema360 handles the presets you create, with their name, icon, dim level, wakefulness settings and shortcut, and the app preferences, meaning automation rules, schedules, battery threshold and transition duration. There is no account and no personal data is requested to use the app.
3. Where data stays
Everything stays on your Mac, in two files inside the application container. There is no synchronisation, there is no Systema360 backend receiving this content, there are no ads, no profiling and no usage analytics. The app makes no network connections to us.
4. Optional permissions and lawful basis
Location is requested only if you choose to start a preset at sunset or switch it off at dawn, and it is used solely to compute those times for your area. The computation happens on the device and the location is not transmitted to us or to third parties. Notifications are requested only if you turn on the end of session alert.
The lawful basis for both is your consent, given by granting the permission to macOS and withdrawable at any time in System Settings, without losing the rest of the app. For the Penombra Pro purchase state the basis is performance of the contract, because without it the app would not know whether the unlock is active.
5. The microphone and running programs
Two of the rule conditions deserve an explicit explanation. Penombra by Systema360 can react to the microphone being in use by someone else, but it does not access the microphone, it does not listen and it records nothing: it only reads the system indication that says whether the microphone is active. In the same way it can react to a program being present, and to do so it reads the list of running process names from the system and compares it with the name you typed. None of these readings leaves your Mac.
6. Purchases and Apple's role
Penombra Pro is purchased through Apple, which is the seller and acts as an independent controller for payment, invoicing and purchase records, under its own privacy policy. The app receives from Apple only the StoreKit state needed to know whether the unlock is active, and that check happens on the device. Systema360 does not receive your card details and keeps no purchase information. Any transfers of data outside the European Economic Area connected with payment take place within your relationship with Apple, not ours.
7. Retention and deletion
The data lives and dies with the app: deleting it from the Mac also removes presets and preferences. Purchase records are handled by Apple and remain subject to its policies, including backup copies, with no promise of immediate deletion on our side.
8. The waiting list on the website
If you leave your address to be notified at launch, that address is handled by the systema360.it website and not by the app. The terms of that processing are described in the website privacy policy.
9. GDPR rights
You can exercise the rights granted by the GDPR by writing to privacy@systema360.it or using the other contacts above. You also have the right to lodge a complaint with the competent supervisory authority.
10. Changes and effective date
We may update this policy when the processing described here changes. Effective date: 23 August 2026.