Privacy Notice

Adaptive Sensory Technology (AST) is committed to protecting the personal data of individuals who interact with us.

This Privacy Notice explains how we collect, use, disclose, and protect your personal data when: You visit our website You apply for a position with us You work for an organization using AST’s Manifold platform and reading center services as part of a clinical trial or research project You work for an organization supplying products or services to AST

Data controller

Adaptive Sensory Technology, Inc. and its subsidiary Adaptive Sensory Technology, GmbH may act as data controllers either independently or jointly for the purposes outlined in this Privacy Notice. Adaptive Sensory Technology, GmbH acts as the EU representative for Adaptive Sensory Technology, Inc.

Please note that in instances where AST processes visual function data collected with the Manifold platform on behalf of a customer as part of reading center services, the customer is the data controller and AST is the data processor.

Contact

Adaptive Sensory Technology, Inc.
9823 Pacific Heights Blvd, Suite CD
CA 92121 San Diego
USA
Adaptive Sensory Technology, GmbH
Gottfried-Keller-Str. 33
81245 Munich
Germany
For privacy queries, please contact AST’s Data Protection Officer at dpo@adaptivesensorytech.com.

What personal data we process

We may process the following personal data:

  • Your IP address, browser type and configuration, pages viewed on our site, date/time of visit

  • Your name, title, contact details (e-mail, phone number, fax number, mailing address), current employment (role, employer)

  • Your job application materials (CV, cover letter, diplomas, transcripts, certificates)

  • Your Manifold training status and certificates

Most of the personal data we process is collected from you directly. However, depending on your relationship with our company, we may also receive information about you from other sources. These may include:

  • Clinical trial sponsors or partners, who share the names and contact details of staff involved in a project.

  • Our suppliers or service providers, who may give us the contact details of their representatives so we can manage our business relationship.

  • Publicly available sources such as professional websites or directories, where you have chosen to make your information available.

We process your data for the following purposes:

  • Website operation and security (legal basis: GDPR Art. 6(1)(f) - legitimate interests)

  • Recruitment (legal basis: GDPR Art. 6(1)(b) - pre-contractual steps)

  • Project management, customer support (legal basis: GDPR Art. 6(1)(b) - contractual necessity; GDPR Art. 6(1)(f) - legitimate interests).

  • Contract management, management of supplier relationships (legal basis: GDPR Art. 6(1)(b) - contractual necessity; GDPR Art. 6(1)(f) - legitimate interests).

  • Compliance with legal obligations (legal basis: GDPR Art. 6(1)(c))

Who we share your data with

We may share your personal data with service providers who assist us in operating our business and delivering our services. These may include:

  • Website hosting and maintenance providers

  • Cloud-based communication tools

  • Customer relationship management tools

We may also need to disclose your personal data if we are required to do so by law. This could include situations where we must respond to lawful requests from public authorities, such as courts, law enforcement agencies, or regulators.

International transfers of personal data

When recipients of your personal data are located outside of the European Economic Area (EEA), we ensure that any transfer of personal data is carried out in compliance with Chapter V GDPR, for example by relying on an adequacy decision of the European Commission or by using standard contractual clauses and supplementary safeguards where necessary.

How long we retain your data

We retain personal data only for as long as is necessary for the purpose(s) for which it was collected and in accordance with any applicable laws. Data will be securely destroyed upon request by a data subject (when applicable), or the data is no longer needed for the purpose(s) it was collected for.

Cookies

We do not use cookies or other tracking technologies.

Automated decision-making

We do not use automated decision-making processes.

Your rights as a data subject

Under the GDPR, you have the following rights in relation to your personal data*:

  • Right of access (Art. 15)

  • Right to rectification (Art. 16)

  • Right to erasure (“right to be forgotten”) (Art. 17)

  • Right to restriction of processing (Art. 18)

  • Right to data portability (Art. 20)

  • Right to object (Art. 21)

If you have given us consent to process your personal data, you have the right to withdraw that consent at any time (Art. 13(3)). You also have the right to lodge a complaint with a supervisory authority if you consider that the processing of your personal data by AST infringes GDPR (Art. 77). A list of each EU country’s data protection authority is available here: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.
*Not all data subject rights can be exercised in all situations, depending on factors including the legal basis for processing.

Updates

We may update this Privacy Policy from time to time. The latest version will always be available on this page.
This Privacy Policy was last updated in November 2025.