PRIVACY POLICY

Last updated: May 2026

Introduction

This Privacy Policy for Barrett Values Centre, LLC (doing business as “BVC,” “we,” “us,” or “our”) describes how and why we may access, collect, store, use, disclose, and otherwise process (“process”) your personal information when you use our services (“Services”), including when you:

• visit our website at https://www.valuescentre.com;

• use Barrett Values Centre services, including culture assessment tools, surveys, diagnostic reports, consulting, and training; and

• engage with us in other related ways, including communications, events, and support.

In many cases, Barrett Values Centre acts as a data processor on behalf of its clients. In other situations, Barrett Values Centre acts as a data controller, for example when you interact directly with us.

If you have questions or concerns, you may contact us at privacy@valuescentre.com.

Summary of Key Points

• We process personal information to deliver Services, communicate, improve our offerings, and comply with legal obligations.

• We generally do not seek to collect sensitive personal data unless required for a specific engagement and legally permitted.

• We may receive personal data from client organizations that engage us.

• We protect personal data with appropriate technical and organizational measures.

• You may have rights depending on your location, including access, correction, deletion, and complaint rights.

• We transfer personal data internationally in compliance with applicable laws, including the EU–U.S. Data Privacy Framework.

1. What Information Do We Collect?

We collect personal information that you provide when using our Services, including names, email addresses, phone numbers, postal addresses, job titles, organization details, survey responses, participation data, preferences, communications, and payment-related details where applicable.

We may also receive personal information from client organizations that engage us to deliver Services.

We may also receive personal information from authentication providers (such as single sign-on services) and other integrations used by client organizations to access or support our Services.

We generally do not seek to collect sensitive or special category personal data unless necessary, legally permitted, and appropriately disclosed. Where we collect or process sensitive personal data, we will obtain your affirmative express (opt-in) consent before using it for a purpose materially different from that for which it was originally collected or subsequently authorized by you, except where otherwise permitted by law or the DPF Principles. Because our culture, values, and leadership assessments may elicit responses that reveal sensitive information, we treat such survey content with heightened care and only use it to deliver the services requested by you or your organization.

We also collect certain technical data automatically, including IP address, device and browser information, usage activity, and approximate location derived from IP.

2. How Do We Process Your Information?

We use personal data to deliver Services and results, manage accounts and communications, provide support, improve Services and analyze usage, maintain security and detect misuse, and comply with legal obligations.

Where we act as a processor, we process data only under client instructions.

3. Legal Bases for Processing

Where applicable (for example, under GDPR), we rely on consent, contract performance, legitimate interests, legal obligations, and vital interests.

When acting as a processor, the legal basis is determined by the client.

4. When and With Whom Do We Share Information?

We may share personal data with client organizations, cloud and hosting providers, analytics and service providers, payment processors, professional advisers, and regulators or authorities where required.

We do not sell personal data.

The categories of third parties identified above are those to which we may disclose personal data received in reliance on the EU–U.S. DPF and the UK Extension. Where we act as a data controller, you may choose (opt out) whether your personal data is disclosed to a third party acting as a controller, or used for a purpose materially different from the purpose for which it was originally collected or subsequently authorized by you. To exercise this choice, contact privacy@valuescentre.com. Where we act as a processor on behalf of a client organization, such choices are directed by that client, and we will refer your request to the relevant client and assist as required.

5. Cookies and Tracking Technologies

We use cookies and similar technologies to support functionality, maintain security, understand usage, and improve performance.

Marketing-related use is subject to applicable law and user choice.

6. International Data Transfers

We may process personal data in the United States, the European region, the United Kingdom, Canada, and other countries where authorized personnel operate.

Barrett Values Centre, LLC complies with the EU–U.S. Data Privacy Framework (EU–U.S. DPF) and the UK Extension to the EU–U.S. DPF.

We have certified to the U.S. Department of Commerce that we adhere to the DPF Principles with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU–U.S. DPF and the UK Extension. If there is any conflict between this Privacy Policy and the DPF Principles, the Principles shall govern.

Learn more about the DPF program at https://www.dataprivacyframework.gov/.

To view our certification, please visit the Data Privacy Framework website at https://www.dataprivacyframework.gov/ and search for “Barrett Values Centre, LLC”.

Barrett Values Centre, LLC is subject to enforcement by the U.S. Federal Trade Commission (FTC).

If you have a complaint, contact us at privacy@valuescentre.com and we will respond within 45 days.

If unresolved, you may contact your local Data Protection Authority. This independent recourse mechanism is available to you free of charge.

In compliance with the UK Extension to the EU–U.S. DPF, Barrett Values Centre commits to cooperate and comply with the advice of the UK Information Commissioner’s Office (ICO) with regard to unresolved complaints concerning human resources data received in reliance on the UK Extension to the EU–U.S. DPF in the context of the employment relationship.

In compliance with the EU–U.S. Data Privacy Framework and the UK Extension to the EU–U.S. Data Privacy Framework, Barrett Values Centre commits to cooperate with and comply with the advice of the panel established by the EU data protection authorities (EU DPAs) and the UK Information Commissioner’s Office (ICO) with regard to unresolved complaints concerning personal data received in reliance on the EU–U.S. DPF and the UK Extension.

Under certain conditions, and where your concern remains unresolved through the other mechanisms described above, you may be able to invoke binding arbitration before a Data Privacy Framework Panel. This option, and the conditions and limitations that apply to it, are described in Annex I to the DPF Principles, available at https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction.

We may disclose personal data in response to lawful public authority requests.

We remain liable for onward transfers to third parties unless we demonstrate we are not responsible.

7. Data Retention

We retain personal data only as long as necessary for service delivery, contractual obligations, legal requirements, and dispute resolution.

Where possible, data is deleted, anonymized, or de-identified.

Survey response data may be retained where necessary to provide longitudinal services requested by clients and in accordance with applicable contractual agreements and legal obligations. Retention periods may vary depending on the engagement.

Where possible, survey data is anonymized or de-identified and may be retained for research and analytics purposes.

8. Security

We implement technical and organizational controls including access controls, encryption, monitoring, secure hosting, and incident response.

Barrett Values Centre operates an ISO 27001-certified information security management system.

9. Children

We do not knowingly collect or process data from individuals under 16.

10. Your Privacy Rights

Depending on your location, you may have rights to access, correction, deletion, restriction, objection, portability, withdraw consent, and lodge complaints. In particular, and consistent with the DPF Principles, individuals whose personal data we hold in reliance on the EU–U.S. DPF or the UK Extension have the right to access that personal data, and to have it corrected, amended, or deleted where it is inaccurate or has been processed in violation of the DPF Principles, subject to the limitations permitted by those Principles.

Contact privacy@valuescentre.com to exercise privacy rights.

11. Do Not Track

We do not respond to Do Not Track signals unless required by law.

12. U.S. Privacy Rights

Residents of certain U.S. states may have additional rights.

We do not sell personal data.

13. Other Regions

Additional rights may apply depending on your jurisdiction.

14. Updates

We may update this policy periodically.

15. Contact

Barrett Values Centre, LLC
Privacy Contact
P.O. Box 960
Waynesville, NC 28786
United States
privacy@valuescentre.com

16. Data Requests

Requests may be submitted via https://www.valuescentre.com/contact.

17. EEA and UK Representative

Barrett Values Centre has appointed VeraSafe as its representative in the European Economic Area (EEA)  under Article 27 GDPR and our UK office under UK GDPR.

VeraSafe acts as a contact point for data subjects and supervisory authorities regarding data protection matters. You may contact our EEA representative at:  

Online Form: https://verasafe.com/public-resources/contact-data-protection-representative
via telephone at: +420 228 881 031.

Alternatively, VeraSafe can be contacted at:

VeraSafe Ireland Ltd.
Unit 3D North Point House
North Point Business Park
New Mallow Road
Cork T23AT2P
Ireland

Barrett Values Centre has appointed its United Kingdom office as its representative in the United Kingdom under UK GDPR Article 27. You may contact our UK representative at:

Barrett Values Centre LTD
The Courting House
4A Moss Lane
Swinton
Manchester
M27 9SA
United Kingdom

privacy@valuescentre.com

+44 1524 964868

ACCESSIBILITY POLICY

Barrett Values Centre is committed to making its website accessible to all users, and we have included several features designed to improve accessibility for users with disabilities. Some of these features are described below.

Images on the site contain “alt tags” with descriptions of the image, which aid users who listen to the content of the site by using a screen reader, rather than reading the site.

Articles and other special publications that are made available on the Website are generally available in HTML. In some cases, we may publish a document using Adobe Portable Document Format (PDF). Barrett Values Centre welcomes comments on how to improve the site’s accessibility for users with disabilities.

If you use assistive technology and the format of any material on our websites interfere with your ability to access the information, please use the following point of contact for assistance. To enable us to respond in a manner most helpful to you, please indicate the nature of your accessibility problem, the preferred format in which to receive the material, the web address of the requested material, and your contact information.

If you have any comments or questions regarding our Online Accessibility Policy, please contact us.