DirectAccess Privacy Policy

Thank you for visiting DirectAccess ("Site"). This Site is owned and operated by Baxter Healthcare Corporation ("Baxter"). For purposes of the DirectAccess Privacy Policy ("Policy"), references to "we," "our," and "us" mean Baxter.

The Site facilitates communication between you, your clinic and Baxter in order to provide certain online dialysis patient and prescription product information transmission and management. We collect information from your clinic?s designated Site Administrator to set up your account, including collecting personally identifiable information (your full name, business address, e-mail address, business phone, mobile number, fax number and NPI number).We may compare the information provided to us against our existing files or otherwise available data.

We use the information provided to us to deliver and improve our products and services to you, and, if you have expressed a desire to receive electronic updates, to contact you regarding our products and services. We also collect nonpersonally identifiable information (e.g., aggregate statistics about what sections of the Site are used the most).

This Policy is designed to tell you about our information collection practices for the Site, that is, the ways we collect information; what kinds of information we collect; why we collect information; how we use information we collect; with whom we share information we collect; how you can access, amend, and delete information we collect from you; and what kinds of security we use to protect information you provide.

Before using the Site and, particularly before submitting personally identifiable information, you should read this entire Policy. You will be asked to indicate your acceptance of the Privacy Policy and Terms and Conditions prior to accessing the Site. If the terms and conditions of the Policy are not acceptable to you, and you do not accept, you will not be able to enter the site.

SCOPE OF POLICY

Please be aware that this Policy applies to DirectAccess. Within this Site, you may see links or references to other Web sites, which are not covered by this Policy and are likely to have different information practices. We therefore encourage you to read the privacy policy of each Web site you visit. We provide these references and links for your convenience; they should not be construed as an endorsement of such sites, their content, or their information practices. You are solely responsible for any interactions you may have with such Web sites.

ACTIVE INFORMATION COLLECTION

This Site collects information from its visitors in two ways: actively and passively.

Active information collection refers to instances in which we gather information from you when you fill it in and send it to us, such as by completing a registration form, signing up for an electronic newsletter, submitting information regarding products being prescribed to a patient, or sending us a message via an e-mail reply mechanism provided by this Site. Active information collection can include both personally identifiable information (e.g., your full name or a government identification number unique to you) and nonpersonally identifiable information (e.g., if we were to ask for your first name and a list of the top three things you like about our Site).

Passive information collection refers to instances in which we collect information from you that you have not actively provided (please see the next section of this Policy for a summary of our passive information collection practices).

Below, we have summarized the primary means of active information collection at our Site. By submitting such information at these various information collection points, you specifically consent to the collection, use, and dissemination of such information in accordance with this Policy. At each active information collection point, we have marked which information is required and which is optional. Unless otherwise specified below, failure to provide required information might mean that you cannot participate in the identified activity or have access to the Site. Failure to provide optional information will not prevent your participation in the identified activity or prevent your access to the Site, but it may inhibit our ability to customize the Site for you and better understand your interests and needs.

Site Access

All functions of the Site will be unavailable to you without completion of a DirectAccess on-line training tutorial and acceptance of the DirectAccess Privacy Policy and Terms and Conditions. You acknowledge that you are solely responsible for any unauthorized use of this Site conducted via your personal username or password. If, at any time, you know or suspect that your personal username or password has been compromised, you must immediately notify us at DirectAccess_Support@Baxter.com.

Data provided by, or collected from you, will be held on a server in the United States. We have selected a third party in the United States to house and maintain your data, and this company has agreed in writing to protect the privacy of your information.

Feedback Information

We welcome your comments and feedback regarding the Site and our products, services, and programs. This Site provides an e-mail reply mechanism that permits you to send us your own e-mail address, comments, attachments selected by you, and any other information you choose to include. E-mail submitted via this Site may not be secure. As a result, you should carefully consider what information you wish to send to us via e-mail.

PASSIVE INFORMATION COLLECTION

We may use special technologies to passively collect information while you are visiting our Site (that is, you do not actively provide this information). These technologies allow us to collect certain kinds of nonpersonally identifiable information, including your Internet domain name, the type of Web browser you use, the operating system you use, the date and time you visit the Site, the specific pages you visit on the Site, and address of the Web site you visited prior to entering this Site. We reserve the right to share with third parties, including our business partners and advertisers, the anonymous aggregated information that we have passively collected via this Site.

Below we have summarized the primary means of passive information collection at our Site.

Internet Protocol (IP) Addresses

This Site uses Internet protocol (IP) addresses. IP addresses are unique identifiers automatically assigned to each computer when logging onto the Internet. IP addresses allow us to collect much of the same information we collect through cookies, including browser-type, what pages you visit, and how long you stay on the Site. In general, IP addresses allow us to identify problems with our servers, prepare aggregate demographic information and other information regarding the use of this Site, and improve the functions of this Site.

Other Passive Tracking at This Site

For security reasons we track each time a user enters the site and when their profile was last updated.

WHAT WE DO WITH YOUR INFORMATION

The personally identifiable information we collect from you will only be used and disclosed in accordance with this Policy or as specifically disclosed to you at the time you provide the information. We will not sell, lease, transfer, share, or otherwise permit access to your personally identifiable information with any third parties other than to contractors who may provide technical, administrative, or market research support to Baxter,or to governmental officials with apparent authority to request or view the information.

We reserve the right to sell, lease, transfer, or otherwise share without restriction aggregated, deidentified, and other nonpersonally identifiable information regarding Site usage, sales, traffic patterns, demographics, and other statistics about our Site or those from whom we collect information via this Site. We reserve the right to use or disclose personal information provided via this Site as necessary to respond to your requests, comply with applicable laws, regulations, legal process, and law enforcement inquiries, as required by litigation, to take precautions against liability, and protect the security and integrity of the site and the safety of its users.

OPTING OUT

We do not seek to collect personally identifiable information from you that you do not want collected. Toward that end, we indicate at all active information collection points whether requested information is required or optional. We also attempt to tell you at the point of collection and in this Policy what the consequences will be (e.g., inability to access important functions of the Site) if you do not provide the required or optional information. When you submit personally identifiable information via this Site, whether such information is required or optional, you consent to its disclosure and use in accordance with this Policy.

INFORMATION ACCESS

We take reasonable steps to ensure that personally identifiable information that you send us via this Site is accurate, current, and complete. Toward that end, we provide you with reasonable access to your personal information to correct errors or delete the information you have provided. If you wish to correct your personally identifiable information, update your information in the Edit My Profile section of the Site. If you wish to delete your personally identifiable information, please contact us by e-mail at DirectAccess_Support@Baxter.com. To respond to your request or inquiry, we may require follow-up or contact information to allow us to verify that you are the person authorized to view the information you are requesting. We may, at our discretion, refuse to allow you access to certain information if, in our view, to provide such access would jeopardize another person's privacy; would violate any applicable federal, state, or foreign law, regulation, or directive; or would unreasonably burden this Site.

DATA SECURITY

Although we take reasonable steps in order to protect the personally identifiable information that you provide via this Site, no system is 100% secure or error-free. Therefore, we cannot guarantee the security or accuracy of the information we gather. Baxter is committed to keeping secure the data you provide us and will take reasonable precautions to protect your Personally Identifiable Information from loss, misuse or alteration. Agents or contractors of Baxter who administer the Site and have access to your Personally Identifiable Information in connection with providing services for Baxter are required to keep the information confidential and are not permitted to use this information for any other purpose than to carry out the services they are performing for Baxter.

One way we protect your personally identifiable information is through username and password. This safety measure is only effective if you protect the secrecy of both your username and password. If you ever suspect your username or password may have been compromised or subject to unauthorized use, contact us immediately at DirectAccess_Support@Baxter.com

We take other steps to secure your data. For example, any data you provide is sent by a secure link using encryption. Encryption is the translation of data into a secret code. To read an encrypted file, you must have the key that allows you to read it, so that even if someone were able to obtain the data, they would not be able to make sense of it.

THIS SITE IS NOT INTENDED FOR USE BY CHILDREN

This Site is not directed to children under the age of 16.

CONTACT US / ENFORCEMENT OF PRIVACY POLICY

If you have any questions, comments, concerns or complaints about this Policy, or the information practices of this Site, send us an e-mail at DirectAccess_Support@Baxter.com. We will take reasonable steps to respond to your inquiry and remedy problems you bring to our attention.

CHANGES TO THIS POLICY

We reserve the right to change this Policy at any time and in our sole discretion. If we do change the Policy, the new Policy will be posted here, along with its revision date, and all information collected following the posting of such changes will be subject to the new Policy. We want you to know, however, that before we use or disclose your previously collected personally identifiable information in a materially different manner from that to which you agreed, we will first secure your affirmative consent for such use or disclosure. Absent such consent, we will use your personally identifiable information in accordance with the Policy in effect at the time we collected the information. In the event that you do not consent to the terms and conditions of the new Policy, contact us via email at DirectAccess_Support@Baxter.com and we will advise you as to how to disable your account. We encourage you to check this Policy periodically and, at a minimum, before each instance in which you provide personally identifiable information via this Site.

This Policy was last revised December 2009.