Who We are

Swan Re is a reinsurance brokerage firm with offices in the United Arab Emirates, Cyprus and Lebanon. As used in this Privacy Notice, “Swan Re” refers to one of any of its entities. We have instituted a comprehensive data protection compliance framework to fulfill our responsibilities to protect personal data and to respect privacy rights in compliance with data protection and privacy laws and regulations.

Swan Re keeps this notice under regular review to make sure it is up to date and accurate. The most recent version will govern our use of your information and will always be available on the Swan Re site. By continuing to access or use this Swan Re site after any changes become effective, you agree to accept the revised privacy notice. Please visit this privacy notice on a regular basis to ensure that you have read the latest version; it was updated the last time on the date indicated below.

We are committed to protecting your privacy

This Privacy Notice explains what Personal Information we collect about you, what we use it for, who we share it with and how we protect it.  

When used in this Privacy Notice, “we”, “us” and “our” refer to Swan Re. In this Privacy Notice, information about you, which may be referred to as personal data in some jurisdictions, is referred to as “Personal Information”. Personal Information refers to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual.

We may also sometimes collectively refer to handling, collecting, protecting, and storing your Personal Information as “processing” such Personal Information.

What kind of personal information data we process

We may process a combination of the following:

  • Contact information – in some cases, for example, we may receive your email, address, or phone number.
  • Risk and fraud related data – for example sanctions and criminal offences, and information received from various anti-fraud databases. 
  • Employment history – for example information on previous or current employer, job role, salary, employment benefit options, educational background or professional licenses and qualifications.

Log information, cookies and web beacons: We may process Personal Information from you when you interact with the Website. For example, we or our service provider(s) may also use cookies (small text files stored in a user’s browser) or web beacons (electronic images that allow us to count users who have accessed particular content and to access certain cookies) to collect aggregate data. Where applicable, additional information on how we may use cookies and other tracking technologies, and how you can control these, can be found in the Cookie Notice on the applicable Website. 

Media

If you upload images to the website, please avoid including embedded location data (EXIF GPS). Visitors can download and extract location data from images on the site.

Cookies

If you leave a comment, you may opt to save your name, email address, and website in cookies for convenience. These cookies will last for one year.

When you visit our home page, a temporary cookie will be set to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

Upon logging in, several cookies will be set to save your login information and screen display choices. Login cookies last for two days, while screen options cookies last for a year. If you select “Remember Me,” your login will persist for two weeks. Logging out will remove the login cookies.

If you edit or publish an article, an additional cookie will be saved in your browser, indicating the post ID of the article you just edited. This cookie expires after one day.

In addition to the above, our website uses cookies for the following purposes:

  • Google Analytics: We use Google Analytics to track visitor interactions and gather statistics about how users navigate our website. Google Analytics sets cookies to help analyze traffic and user behavior. You can learn more about Google Analytics cookies here.
  • Google Ads, Meta (Facebook Pixel), LinkedIn (if applicable): We use these advertising and tracking services to measure the effectiveness of our ads and track conversions. These services set cookies to track user activity across different websites. You can manage how these platforms track your information through their respective privacy settings:
    • Google Ads Cookies
    • Meta (Facebook) Privacy Policy
    • LinkedIn Privacy Policy
  • Wordfence: We use Wordfence for website security and threat detection. Wordfence sets cookies to identify malicious activity and improve site security. More information can be found in Wordfence’s privacy policy.

Please note that you can manage or delete cookies through your browser settings. However, disabling cookies may affect the functionality of certain features on this site.

Why do we process this data

We use your personal data primarily only to the extent that it is necessary for the purposes of conducting our business, and only for the purpose for which it was originally collected and any other permissible, related purpose.

We may use your Personal Information for the purposes of, or in connection with:

  • managing and/or improving our Website;
  • managing and promoting collaboration and communication;
  • tailoring the content of our Website to provide you with a more personalized experience;
  • managing our relationship with you and responding to any request you submit through our Website;
  • conducting data analysis including, for example, regarding usage of the Website and demographics analyses of Website users;
  • monitoring and enforcing compliance with applicable terms of use, and that only authorized parties are accessing the Website.
  • dealing with requests and communications from competent authorities;
  • investigating or preventing security incidents;
  • conducting and analyzing our marketing activities;
  • Fulfilling legal or regulatory obligations and protecting ourselves and our clients against fraud, money laundering, terrorism and other crimes.

Legal basis for processing this data

We are required by law to set out in this Privacy Notice the legal grounds on which we rely to process your Personal Information. We rely on one or more of the following lawful grounds when we use your Personal Information for the purposes outlined above:

  • the processing is necessary for compliance with a legal obligation we have such as keeping records or providing information to a public body or law enforcement agency;
  • the processing is necessary for the purposes of a legitimate interest pursued by us or a third party (and are not outweighed by your privacy interests), such as the effective delivery of our Website and related services offered to you; the effective and lawful operation of our Website; to prevent fraud or criminal activity or to safeguard our technology systems and/or data security; to support or protect our business interests; to ensure that complaints are investigated; to evaluate, develop or improve our services or products; or
  • you have consented to us processing your information for a specific reason, consent that you can always withdraw.

To the extent that we process any sensitive Personal Information relating to you for any of the purposes outlined above, we will do so because either: (i) you have given us your explicit consent to process that data; (ii) we are required by law to process that data, or (iii) the processing is necessary for the establishment, exercise or defense of legal claims or (iv) you have made the data manifestly public.

Please note that in certain circumstances it may be still lawful for us to continue processing your information for separate purposes even where you have withdrawn your consent, if one of the other legal bases described above is applicable.

Disclosure of information to third parties

 In connection with one or more of the purposes outlined in the “Information use” section above, we may disclose details about you to: other members of Swan Re for legitimate business-related purposes; third parties that provide services to us and/or Swan Re; as part of a corporate transaction (such as a sale, divestiture, reorganization, merger or acquisition); competent authorities (including courts and authorities regulating us or another member of the Swan Re entity) and other third parties that reasonably require access to Personal Information relating to you for one or more of the purposes outlined in the “Information use” section above.

We may also need to disclose your Personal Information if required to do so by law, by a regulator or during legal proceedings.

Please note that some of the recipients of your Personal Information referenced above may be based in countries without data protection laws. In such cases, we will ensure that you consent to the transfer or that there are adequate safeguards in place to protect your Personal Information that comply with our legal obligations.

We may share non-personal, de-identified and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional purposes.

Selling of Information

 We do not sell your personal information.

Privacy Practices of Third Parties

 This Privacy Notice addresses only the use and disclosure of information we collect through your interaction with the Websites. Other websites or applications that may be accessible through links from the Websites have their own privacy notices and Personal Information collection, use and disclosure practices. We encourage you to familiarize yourself with the privacy notices provided by these other parties prior to providing them with information.

Information retention

We keep your personal information in compliance with applicable legal retention periods, in accordance with the purpose and the legal ground it was collected, and to comply with our legal and regulatory requirements. This may include keeping your information for a reasonable period of time after your relationship with us or our client has ended.

Information Security

We take particular care when working with third parties. We only share personal data with entities, business partners, third party service providers or vendors when we have a legitimate business purpose for doing so and when permissible by law. We require third parties to maintain similar standards to ours for the protection of personal data, as verified by our due diligence process. 

Although we use appropriate security measures once we have received your Personal Information, the transmission of data over the internet (including by e-mail) is never completely secure. We endeavor to protect Personal Information, but we cannot guarantee the security of data transmitted to us or by us over the internet.

Your Privacy rights

You may have various rights under your local law in relation to the Personal Information we hold about you. In particular, you may have a legal right to:

  • obtain confirmation that we are processing your Personal Information and request a copy of the Personal Information we hold about you;
  • ask that we update the Personal Information we hold about you, or ask that we correct such Personal Information that you think is incorrect or incomplete;
  • ask that we delete Personal Information that we hold about you, or restrict the way in which we use such Personal Information; withdraw consent to our processing of your Personal Information (to the extent such processing is solely based on previously obtained consent);
  • receive a copy of the Personal Information concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and to transmit such Personal Information to another party (to the extent the processing is based on consent or a contract); and
  • object to our processing of your Personal Information.

To help us maintain the accuracy of your Personal Information, please contact us by using the “Contact Us” section if any of your personal details have changed.