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Privacy Notice Effective Date: [Updated 24 April 2023]

Baxter is the Data Controller

This Privacy Notice (“Notice”) will provide you with information on the data processing activities of Baxter Healthcare Corporation located at One Baxter Parkway, Deerfield, Illinois 60015, together with its affiliates and subsidiaries (collectively “Baxter,” “we,” “us”). This Notice applies to registered healthcare professionals and other authorized users (“users,” “you”) of Baxter’s Learning Portal (“the Portal”) and describes what personal data is collected about you when you use and/or interact with the Portal.

The Portal allows users to complete clinical and/or product training modules and other available content (collectively, “Services”). This Privacy Notice provides you with information on how Baxter will process your Personal Data and how you can exercise your rights regarding your personal data.

What Personal Data we Collect

We may obtain the following categories of personal data about you:

Contact information, including name and email address
Information regarding your title and your profession, including your place of employment and/or affiliation
Information regarding your educational background and/or specialty
Healthcare identification numbers
Username and password used to access the Portal
Information required to register you for an account
Information regarding a user’s session, including user ID, date registered, last login date and time, language selection, and any downloaded content and a corresponding timestamp, as well as information on training completion status and completion date for training courses.
Your IP address.

Other information derived from cookies and other similar technologies collected by Baxter’s subcontractor, Cornerstone on Demand, which hosts the Portal. See Cornerstone on Demand’s Cookie Notice.

How we Process Your Personal Data

We will process your personal data for the following purposes:

To provide you with the Portal and related services
To customize the Services for you including recommendations and personalized content and learning
To measure and understand the Services are being used to help improve the Services
To support your user account and assist with registration
To respond to your requests, inquiries, or questions
To track your usage of the Portal

We may use your data to stay in contact with you by phone and/or sending you, including via email, marketing communications, for our products, therapies and services, activities such as market research, as well as sharing information about events, webinars and other virtual activities and educational opportunities.

Baxter will process your personal data based on your consent. You have the right to withdraw your consent, or as otherwise specified below. You at any time by contacting us at learnersupport@baxter.com or by using the contact details provided in the Contact Us section below. Withdrawal of your consent does not affect the lawfulness of the processing that we conducted prior to such withdrawal. If you withdraw your consent, you will not be able to use the Baxter Learning Portal.

Who at Baxter may Receive your Personal Data

Your personal data may be accessed by Baxter employees around the globe who support the Portal. For example, Baxter employees belonging to the Global Learning Solutions team may access to your personal data in connection with providing you the Services. Other Baxter employees serving as Portal administrators or other support staff may also access your personal data in connection with your user account.

In addition, Baxter employees who are responsible for each training program will obtain reports about your participation in such training program and the reports will include personal data about you together with the training program completion status to understand how you are progressing through your training programs and to better understand how you and other users are taking training programs. Finally, we may share your data related to training completion with your employers to the extent the training is a prerequisite to participation in subsequent training activities or as part of training accreditation, certification or similar requirements. In such an event, we will rely on the legitimate interest of your employer to obtain this information from us.

Sharing your Personal Data with our Service Providers

Baxter uses service providers and other business partners to help us process your personal data. Specifically, Baxter utilizes a service provider named Cornerstone On Demand, located in the United States, to support the administration, hosting and functionality of the Portal. Baxter has data processing agreements in place with its service providers to ensure they provide an adequate level of protection for your personal data. Service providers are only authorized to use your personal data only as necessary to provide these services to us.

How Long we Keep your Personal Data

We will keep your personal data as long as your user account exists. If you delete your account, we will delete your personal data. If you have not used your account for one year, we will treat your account as inactive and will retain your personal data for one year and then delete it, unless you reactivate your account during that one-year period. Please note that you may delete your user account at any time by accessing your user profile in the “My Profile” tab and then selecting the “Personal Data” tab.

Security

We have reasonable and appropriate security measures in place to protect against the loss, misuse, and alteration of any personal data we receive. We maintain reasonable security standards to protect personal data that we maintain. If you have any questions about the security of your personal data, you can contact us by using the other contact details in the “How to contact us” section below.

Do Not Track

Certain laws require Baxter to indicate whether we honor “Do Not Track” settings in your browser concerning targeted advertising. As of the effective date of this Privacy Statement, an industry standard has not yet been established on how to respond to these signals, and therefore Baxter does not currently respond to such signals. Instead, we adhere to the standards set out in this Privacy Statement. If you have any questions, please contact us using the information provided below.

International Data Transfers

Baxter is a global company with global affiliates, and therefore we use global vendors, subcontractors, systems, and applications. As a result, the personal data that we collect and generate about you may be transferred, stored, or accessed in a destination outside of your country which may have less strict, or no, data protection laws, when compared to the laws in your country. Any transfer of personal data to Baxter affiliates or third parties outside your local country will be conducted in compliance with the international data transfer restrictions that apply under applicable data protection laws.

We take legally required steps under applicable data protection law to ensure that adequate safeguards are in place (e.g., standard contractual clauses, data transfer agreements) to protect your personal data in accordance with this Privacy Policy. You may contact us using the information below for more information about the safeguards that we have put in place to protect your personal data and your privacy rights when we make cross-border transfers of your personal data.

Your Rights

In certain circumstances, local privacy laws may give you rights with respect to your personal data, as described in more detail below. You may exercise your rights by contacting us using the information at the end of this Privacy Notice.

We will handle any request to exercise your rights in accordance with applicable law, but please note that these rights may not be absolute. Baxter may refuse or deny a request in accordance with applicable privacy laws. Additionally, depending on the circumstances and where you are located, not all of the below rights may be available to you.

Your rights with respect to your personal data may include the following:

Withdraw Consent

If we use or share your personal data based on your consent, you may withdraw your consent at any time. Note that withdrawal of your consent will not affect the lawfulness of our uses or sharing of your personal data before you withdraw your consent.

Access

You may request access to or copies of your personal data. You may also request what types of personal data we have, the purposes for which we process it, and who has received access to your personal data.

Correction and Deletion

You may request that we correct your personal data if you think it is inaccurate or incomplete. If you want to delete your user account, you may do that anytime by can accessing your user profile in the “My Profile” tab and then selecting the “Personal Data” tab. You can also request that we erase or delete your personal data in certain circumstances.

Restrict Processing

You may request that we restrict the processing of certain personal data.

Data Portability

You may request that we provide you with your personal data that we obtained from you, and you can ask us to provide it to another entity.

Object

You may have the right to object to our processing of your personal data for certain purposes.

Lodge a Complaint

If you believe we are using, disclosing, or otherwise processing your personal data in a way that is not in accordance with applicable law, you can lodge a complaint with the relevant data protection authority in your country.

Contact Us

Email us with questions about the Portal and/or Services: learnersupport@baxter.com

If you have questions or concerns about this Privacy Policy, our information practices, or any other aspect of the privacy and security of your personal data, please contact us using the information below.

Email: privacy@baxter.com

Mail: Baxter International Inc.

ATTN: Global Privacy Office

1 Baxter Parkway, Deerfield, IL USA 60015

Ethics and Compliance Hotline

1-844-294-5418

Local Contact Details: https://www.baxter.com/contact-us

ADDITIONAL INFORMATION ON ALLEGO PRIVACY PAGE

California Supplement:
Supplemental Privacy Statement For California Consumers Effective Date: April 17, 2023
Last Updated: April 17, 2023

As a global company, Baxter Healthcare Corporation (“we,” “us,” “our”) proudly serve persons residing in the State of California. We have prepared this supplemental privacy statement (“Supplement”) for our California consumers (“California Consumers,” “you”), in addition to our Privacy Notice, to inform California Consumers of their rights under the California Consumer Privacy Act of 2018 and its implementing regulations (“CCPA”). We will review this Supplement at least annually and update as needed.

If you would like to receive a copy of this Supplement in an alternate format (e.g., printable) or language, please contact us using the information provided in Section 7 below.

1. Personal Information We Collect and Disclose

When we use the term “Personal Information” in this Supplement, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California Consumer or household.

In particular, we have collected and disclosed the below listed statutory categories (as defined by the CCPA) of Personal Information from California Consumers and for the following purposes within the last twelve (12) months.

Categories of Personal Information Collected & Disclosed

Identifiers - A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, professional license number or other similar identifiers.

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) - A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Internet or other similar network activity - Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. We only collect this if you opt-in to analytics data usage when you set up the App. This can be disabled at any time in the “More” section of the app under “Provide Usage Data”.

Professional or employment-related information - Current or past job history or performance evaluations. We only collect employment-related information if you are a clinician.

Inferences drawn from other personal information - Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We obtain the above listed categories of Personal Information from the following sources:

Directly from you, when you submit your Personal Information to us in the Portal
Indirectly from you, for example when you interact with our Portal

We disclose the above listed categories of Personal Information to the following categories of third parties:

Our Service Providers, who have executed privacy contracts with us and have agreed to treat your Personal Information confidentially and to not sell your Personal Information.

2. Sale of Personal Information

In the last 12 months, we do not have knowledge that we sold any Personal Information of California Consumers, nor actual knowledge that we sold the Personal Information of California Consumers under the age of 16 years old. The CCPA defines “sale” as: selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s Personal Information to another business or third party for monetary or valuable consideration.

If we do sell your Personal Information, we will notify you, and if you submit to us a verifiable consumer request using the contact information in Section 7 below, we will disclose to you a list containing the categories of Personal Information that we sold in accordance with the CCPA’s requirements.

3. California Consumers’ Privacy Rights

California Consumers may exercise their CCPA privacy rights with respect to their Personal Information as set forth in the table below by following the instructions set forth in Section 4 of this Supplement. Please note that the CCPA creates a process for us to follow when evaluating your request, and there are also some exceptions to these rights.

California Privacy Rights	Description
Right to Know/Access	You have the right to request that we disclose to you what Personal Information we collect, use, disclose, and sell about you, including: The categories of Personal Information we have collected about you in the preceding 12 months; The categories of sources from which the Personal Information is collected; The business or commercial purpose for collecting or selling the Personal Information; The categories of Personal information, if any, that we disclosed for a business purpose or sold to third parties in the preceding 12 months; and The categories of third parties to whom the information was disclosed or sold.
Right to Delete	You have the right to request that we delete the Personal Information we collect about you.
Right to Opt-Out of Sale	You have the right to opt-out of the sale of your Personal Information to third parties. Currently, we do not sell your Personal Information. If you have any questions, please reach out to us by using the contact information in Section 7.
Right to Non-Discrimination	You have the right to not receive discriminatory treatment by us if you exercise any of the rights conferred to you by the CCPA.

4. How to Exercise Your California Consumer Rights

If you are a California Consumer and would like to exercise any of your rights listed above, please contact us using the information below and the contact information in Section 7.

You may also designate an authorized agent to make a request to exercise your rights on your behalf. In order to do so, you must contact us using the information in Section 7.

While we take measures to ensure that those responsible for receiving and responding to your request are informed of your rights and how to help you exercise those rights, when contacting us to exercise your rights, we ask you to please adhere to the following guidelines:

Tell Us Which Right You Are Exercising: Specify which right you want to exercise and the Personal Information to which your request relates (if it does not relate to you). If you are acting as an authorized agent on behalf of a California Consumer, please clearly indicate this fact and indicate your authority to act on their behalf.
Help Us Verify Your Identity: Contact us using the information in Section 7 and provide us with enough information to verify your identity. Please note that if we cannot initially verify your identity, we may request additional information to complete the verification process. Any Personal Information you disclose to us for purposes of verifying your identity will solely be used for the purpose of verification.
Direct Our Response Delivery: Inform us of the delivery mechanism with which you prefer to receive our response. You may specify, for example, email, mail, or through your account (if you have one with us).

Please note that you do not need to create an account with us in order to make a request to exercise your rights hereunder.

5. How We Respond to California Consumers’ Requests

In all cases, we will respond to your request within ten (10) days to confirm receipt of your request and provide you with information about how we will process your request. Then we will respond substantively to your request within forty-five (45) days. However, where reasonably necessary, we may extend our response time by an additional forty-five (45) days, provided we send you notice of such extension first. We will provide the information to you via your preferred delivery mechanism. If the information is provided to you electronically, we will provide you the information in a portable format and, to the extent technically feasible, in a machine readable, readily useable format that allows you to freely transmit this information without hindrance.

Please note that we will not charge you for making a request, provided that you make no more than two (2) requests per year. If you make three (3) or more requests in any given twelve (12) month period, we may refuse to respond to such requests, if determined by us to be unfounded or excessive (e.g. repetitive in nature), or we may charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested. If we refuse to act on the request, we will provide you notice and the reason for our refusal to act.

6. Contacting the California Attorney General

The CCPA gives California Consumers the right to lodge a complaint with the California Attorney General’s office. The Attorney General’s office may be contacted at https://oag.ca.gov/contact/consumer-complaint-against-business-or-company or by telephone at: (916) 210-6276.

We encourage you to reach out to us first, however, so that we may help resolve any complaints you may have.

7. Contact Us

To exercise one or more of your CCPA rights, or to contact us with questions and concerns about our privacy policies and practices, please contact us at:

Email: privacy@baxter.com

Mail: Baxter International Inc.
ATTN: Global Privacy Office

1 Baxter Parkway, Deerfield, IL USA 60015

Ethics and Compliance Hotline

1-844-294-5418

Local Contact Details https://www.baxter.com/contact-us