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Privacy Notice Effective Date:  [June 24, 2020]

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:

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:

Baxter will process your personal data based on your consent.  You have the right to withdraw your consent 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 particular 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 in order 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 only to the extent the training is a prerequisite to participation in subsequent training activities.     

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

Some of the individuals and entities who will receive your personal data may be located both within and outside of your country, including in countries that have less adequate protections, safeguards and rules to protect personal data and where you may not have the same rights to your data that you do in your own country. Baxter is a global company and therefore uses global vendors and subcontractors as well as global IT systems and applications. As a result, your personal data may be transferred to our vendors, subcontractors, global affiliates and to our employees and contractors who work for us and are located outside of the EU/EEA or the country where you are located, such as in the United States for the purposes described in this Notice. These countries may have less strict data protection laws compared to your country.  If this is the case, we will take legally required steps to ensure that adequate safeguards are in place (e.g., standard contractual clauses) to protect your personal data. You may contact us for a copy of the safeguards which we have put in place to protect your personal data and privacy rights when your personal data is transferred outside of your country or region.

Your Rights

Depending on where you are located, you may have the following rights with respect to your personal data:

Please note that not all countries and privacy laws may grant these rights.

You also have the right to withdraw your consent at any time and can do so by contacting us at learnersupport@baxter.com or otherwise by contacting Baxter using the contact information provided below. 

Please address your requests to exercise your rights described above, or questions concerning this Notice or the processing of your personal data, to the Data Protection Officer using the contact information below.

Contact Us

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

Email us with any privacy questions or concerns at privacy@baxter.com

Privacy telephone:  Ethics and Compliance Hotline at 1-844-294-5418

Privacy mail:          Baxter Healthcare Corporation
                               Baxter International Inc.
                               ATTN: Data Protection Officer
                               Global Privacy Office
                               1 Baxter Parkway
                               Deerfield, IL USA 60015