Privacy Policy

This Privacy Policy explains how Better Being collects, holds, uses and discloses personal information, and how you can contact us about it. Better Being is an Australian provider of workplace wellbeing programs, including digital wellbeing challenges, leadership programs, education and coaching. We are committed to complying with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), including the additional protections that apply to health information as sensitive information. 

Document Control

Company: Stark Concepts Pty Limited trading as Better Being (ABN 49 676 731 598) 

Document Owner: Greg Stark, Director

Version: 1.1

Adopted: July 2026

Updated: September 2026

Next Review: July 2027

Applies to: All Better Being employees, contractors and subcontractors

Terms

1. WHAT WE COLLECT

Program participants

When your employer engages us to run a wellbeing program (for example, a 28-day digital challenge), we collect:

(a) Your first and last name, work email address, mobile number, business unit and location.

(b) Your responses to our Wellbeing Index (questions across Movement, Mindset, Nutrition and Recovery).

(c) Your program activity, including goal selections, habit completion and weekly self-ratings for energy, stress, sleep and mood.

(d) Any optional free-text reflections or feedback you choose to provide.

Health information

Some of the information above is self-reported wellbeing information that we treat as health information under the Privacy Act.

We only collect it directly from you, with your consent, when you register for and participate in a program. It is never a condition of your employment that you provide this information.

Clients and business contacts

We collect the names, roles, business contact details and correspondence of people at our client organisations and suppliers.

Website visitors

Our website and program platform uses cookies and similar technologies to:

• operate the service;
• remember you between visits; and
• measure engagement.

You can control cookies through your browser settings.

2. WHY WE COLLECT IT

We collect and use personal information:

(a) To deliver wellbeing programs and services to you and your employer, including personalising your program experience and displaying your own results.

(b) To produce reporting for your employer using aggregated and de-identified information so individual participants cannot reasonably be identified. We do not disclose identifiable health information to your employer without your consent.

(c) To administer our business, including invoicing, service improvement and benchmarking using de-identified data.

(d) To communicate with you about your wellbeing program and, where you have opted in, about other Better Being services.

We do not sell personal information.

We do not use participant health information for advertising.

3. HOW WE HOLD AND PROTECT IT

Participant and program data is held within our customer relationship management and content platform, HubSpot, hosted in HubSpot's cloud infrastructure.

Participant data is currently hosted in HubSpot's North American data centre.

Better Being also uses Microsoft 365 for email and business collaboration, which may contain incidental correspondence.

We protect personal information through the measures described in our Information Security Policy, including:

(a) Encryption of data in transit (TLS 1.2 or higher) and at rest (AES-256).

(b) Access restricted to authorised personnel on a least-privilege basis using multi-factor authentication.

(c) Confidentiality obligations applying to all employees and subcontractors.

(d) Secure deletion practices under our Data Retention & Secure Deletion Policy.

4. DISCLOSURE

We disclose personal information only:

(a) To our service providers and subcontractors who assist us in delivering our services (including HubSpot, Microsoft and DigiKat) under contractual confidentiality and privacy obligations.

(b) To your employer in aggregated and de-identified form only, unless you have expressly consented otherwise.

(c) Where required or authorised by law.

Overseas disclosure

Participant data is stored in HubSpot's North American data centre (see section 3).

Our platform providers are global organisations, and some infrastructure or support functions may involve access from or processing in other countries, including the United States.

Where this occurs, we take reasonable steps to ensure your information is handled consistently with the Australian Privacy Principles.

5. ACCESS, CORRECTION AND COMPLAINTS

You may request access to, or correction of, the personal information we hold about you at any time.

You may also request deletion of your program data.

Please contact:

Greg Stark
Better Being
The Commons
388 George Street
Sydney NSW 2000

Email: info@betterbeing.com.au

We aim to respond within 30 days.

If you are dissatisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

6. DATA BREACHES

We maintain a Data Breach & Incident Response Plan.

If a data breach is likely to result in serious harm, we will:

(a) Notify affected individuals.

(b) Notify the Office of the Australian Information Commissioner under the Notifiable Data Breaches Scheme.

(c) Notify affected client organisations in accordance with our contractual commitments.

7. CHANGES TO THIS POLICY

We review this Privacy Policy at least annually and may update it from time to time.

The current version is available on www.betterbeing.com.au or upon request.