Employee Wellbeing Survey Privacy Notice

This Privacy Notice explains how your personal data is handled when you take part in a workplace wellbeing survey provided through the Arab Therapy platform. It is addressed to you, the employee invited to complete the survey.

The survey is provided by Arab Therapy LLC and is commissioned by your Organization. For the purposes of this survey programme, Arab Therapy and the Organization act as joint controllers: together we decide why the survey is run and how it is carried out. Arab Therapy operates the survey technology, collects responses anonymously, and produces combined results; the Organization commissions the survey and receives only combined, anonymous insights.

Taking part is entirely your choice. You are free to decline, to skip questions, or to stop before submitting, without any need to give a reason and without any consequence to your employment, standing, or relationship with your employer or with Arab Therapy.

We collect only your survey responses, meaning the answers you choose to provide to the survey questions.

We do not ask for or collect information that identifies you personally, such as your name, employee number, email address, or phone number, and we do not attach your identity to your responses.

Your responses may include information about your emotional state, stress, or mental wellbeing. Under applicable data protection laws this is considered sensitive personal data (also called special-category or health-related data), and we apply additional safeguards to it as described below.

The survey is designed to be anonymous. Responses are collected without identifiers, and neither Arab Therapy nor your employer can link a set of answers back to you as an individual. Results are only ever compiled and presented in aggregate, meaning combined across many participants. To protect against indirect identification, combined results are displayed only where a sufficient number of responses has been received for a given group (a minimum group-size threshold); where a group is too small, its results are withheld or merged into a larger group.

Your responses are used only to:

• measure and understand the overall wellbeing of the workforce at an organizational or group level;
• help the Organization identify themes and improve workplace wellbeing and mental-health support; and
• operate, maintain, and improve the survey itself.

Your responses are not used to assess, monitor, rate, reward, or take any decision about you as an individual. No automated decision-making or profiling is carried out about you, and the results are not used for marketing.

Because your responses may include sensitive (wellbeing) data, we rely on your explicit consent, which you give by voluntarily choosing to complete and submit the survey. Processing is also grounded in the legitimate purpose of understanding and improving workplace wellbeing, carried out on an anonymous, aggregated basis. You may decline before submitting; withdrawing at that stage simply means your responses are not collected.

Your employer sees only combined, anonymous results, presented through a reporting dashboard (the "agent dashboard"). Your employer cannot see your individual answers, cannot identify who said what, and cannot single you out. Only aggregate insights, such as group-level trends and scores, are made available, and only above the minimum group-size threshold described in section 4.

Because the survey is anonymous, no one will contact you, offer you services, or take any action directed at you personally based on your answers. Your responses are not linked to any therapy booking or to any Arab Therapy user account. If you separately choose to seek therapy or support through Arab Therapy, that is a distinct service governed by its own terms and privacy policy.

We keep your individual responses only for as long as needed to compile the combined results. Once responses have been aggregated into anonymous insights, the raw individual responses are deleted. Only the aggregated, anonymous results are retained thereafter, for the Organization's reporting and for improving the survey.

We may use trusted service providers (for example, secure hosting and survey-technology providers) to help us operate the survey on our behalf. They may process the data only on our instructions, under confidentiality and data-protection obligations, and may not use it for their own purposes. We do not sell your data, and we do not share it with any third party for advertising.

The survey data may be stored and processed outside your country of residence, including on cloud infrastructure located abroad. Where data is transferred across borders, we take steps intended to ensure it remains protected to a standard consistent with applicable data protection laws, through appropriate contractual and technical safeguards. Given the anonymous and aggregated nature of the data, the privacy impact of any such transfer is minimized.

We apply appropriate technical and organizational security measures to protect the data against unauthorized access, loss, or misuse. This includes encryption in transit, access controls limiting who can handle the data, and the anonymization and aggregation measures described above.

Applicable data protection laws, including the Saudi Personal Data Protection Law, Jordan's Personal Data Protection Law No. 24 of 2023, and Egypt's Personal Data Protection Law No. 151 of 2020, give you rights over your personal data, which may include the right to be informed, to access your data, to have it corrected, to have it deleted or destroyed, to object to or restrict its processing, and to withdraw consent.

Please note an important consequence of anonymity: once you submit your responses anonymously, they can no longer be connected to you, so Arab Therapy and the Organization are generally unable to locate, retrieve, correct, or delete your specific responses on request, simply because we cannot tell which responses are yours. You remain fully in control before you submit: you may decline to participate, skip any question, or stop at any point, and nothing is collected until you submit. Where you believe any information that could identify you has been handled (for example, an invitation sent to your work contact by your employer), you may exercise your rights through the contact points below.

The survey is intended for adult employees (18 years and older). It is not directed at children, and we do not knowingly collect data through this survey from anyone under the applicable age of majority.

We may update this notice from time to time to reflect changes in the survey or in legal requirements. The current version, with its effective date, will always be the one made available to you when you take the survey.

This notice is intended to comply with the personal data protection laws applicable to survey participants, including in the Kingdom of Saudi Arabia (Personal Data Protection Law, overseen by the Saudi Data & Artificial Intelligence Authority – SDAIA), the Hashemite Kingdom of Jordan (Personal Data Protection Law No. 24 of 2023), and the Arab Republic of Egypt (Personal Data Protection Law No. 151 of 2020, overseen by the Personal Data Protection Center). If you have a concern, please contact us first (section 17). You also have the right to lodge a complaint with the competent data protection authority in your country.