This privacy policy is applicable to the Sama mobile application (hereinafter referred to as "Application"), developed by Darmac (hereinafter referred to as "Service Provider") as a Freemium service. This service is provided "AS IS".
1. Data Controller
The data controller for the Application is: Darmac, Milan, Italy. Contact: darbio86@gmail.com.
No Data Protection Officer (DPO) has been appointed, as the Service Provider does not meet the thresholds set out in Article 37 of GDPR Regulation 2016/679.
2. Data We Collect and Legal Basis
The Application processes the following categories of personal data:
Purchase confirmation (legal basis: Article 6(1)(b) GDPR — performance of a contract): When you purchase Premium Content, the relevant app store (Google Play Store or Apple App Store) sends the Service Provider a technical confirmation of the completed transaction. The Service Provider does not receive or store your payment details, credit card information, or banking data.
Technical data collected automatically (legal basis: Article 6(1)(f) GDPR — legitimate interest in monitoring technical performance and improving the Application): The Application may collect the following data automatically through the operating system or the app store platform:
- Type of mobile device and unique device identifiers.
- IP address of your mobile device.
- Mobile operating system (Android or iOS).
- Information about how you use the Application (e.g., duration of meditation sessions, most used features).
This data is used solely to monitor the technical performance of the Application and improve the user experience. It is not transmitted to or stored on any server operated by the Service Provider.
3. Data Storage and Retention
The Service Provider does not operate any server-side infrastructure for data storage. All data generated by your use of the Application is stored exclusively on your device and is never transmitted to servers controlled by the Service Provider.
Usage statistics (e.g., minutes meditated) are stored locally on your device or, if you use the backup features of your Google or Apple account, are managed privately within those accounts. The Service Provider has no access to such data.
Upon uninstallation of the Application, all locally stored data is deleted. For data managed through your Google or Apple account, deletion is governed by the settings of the respective account.
4. Wellness Data
The Application is dedicated to meditation and mindfulness. The Service Provider does not collect biometric, health, or clinical data. Usage statistics are stored locally as described in Section 3 and are never sold or shared with third parties for advertising or profiling purposes.
5. Third-Party Services and International Data Transfers
The Application integrates exclusively with the official app store platforms for payment processing. No additional third-party SDKs, analytics services, or advertising networks are integrated into the Application.
The providers listed below have their own privacy policies and process personal data as independent controllers. Both Google and Apple may transfer personal data outside the European Economic Area (EEA). Such transfers are governed by Standard Contractual Clauses (SCCs) adopted pursuant to Article 46(2)(c) GDPR, or other adequacy mechanisms recognised by the European Commission.
For Android:
For iOS:
6. Your Rights (GDPR — EU Regulation 2016/679)
Since the Service Provider is based in the European Union, the following rights apply to all users under Regulation 2016/679. To exercise any of these rights, contact us at darbio86@gmail.com. We will respond within 30 days.
- Access (art. 15): You may request confirmation of whether personal data concerning you is being processed and, if so, obtain a copy.
- Rectification (art. 16): You may request correction of inaccurate or incomplete personal data.
- Erasure / Right to be Forgotten (art. 17): You may request deletion of data concerning you, subject to applicable legal grounds for retention.
- Restriction of processing (art. 18): You may request that processing of your data be restricted in certain circumstances.
- Opposition (art. 21): Where processing is based on legitimate interest (art. 6(1)(f)), you may object at any time on grounds relating to your particular situation.
- Portability (art. 20): Where processing is based on consent or contract and carried out by automated means, you may request your data in a structured, machine-readable format.
- Withdrawal of consent: You may withdraw consent at any time without affecting the lawfulness of prior processing. You may also stop all data collection by uninstalling the Application or managing permissions in your device settings.
- Complaint to the supervisory authority: You have the right to lodge a complaint with the Italian data protection authority (Garante per la Protezione dei Dati Personali) at www.garanteprivacy.it, or with the supervisory authority of your country of residence within the EU.
7. Children’s Privacy
Under Article 8 of GDPR Regulation 2016/679, as implemented in Italy, the Application is not directed at individuals under the age of 16. The Service Provider does not knowingly collect personal data from minors. If we become aware that a person under 16 has provided personal data, we will promptly delete it. Parents or guardians who believe their child has submitted personal information may contact us at darbio86@gmail.com.
8. Security
We are committed to safeguarding your information. Since the Service Provider does not operate server-side infrastructure, the primary security of your data depends on your device’s security features. Please ensure your device is protected with appropriate access controls. No method of electronic storage is 100% secure.
9. Changes to this Policy
The Service Provider may update this Privacy Policy from time to time to reflect changes in the Application or applicable regulations. Where changes materially affect your rights or the way your data is processed, you will be notified in advance through the Application or by other appropriate means. For minor or non-material updates, the updated policy will be posted on this page and the effective date will be revised.
Effective Date: 2026-05-01
Contact Us
If you have any questions regarding privacy or wish to exercise your rights, please contact us at: darbio86@gmail.com.