Twomey Partners respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use and protect personal data when you visit our website, submit an enquiry, book a meeting or otherwise communicate with us about our services.

Twomey Partners is operated by Jordan Twomey as a sole trader in Ireland. For the purposes of applicable data protection law, Jordan Twomey trading as Twomey Partners is the data controller responsible for the personal data described in this Privacy Policy.

If you have any questions about this Privacy Policy or how your personal data is handled, you can contact: Jordan Twomey Trading as Twomey Partners Ireland [email protected]

1. Information we collect The personal data we collect depends on how you interact with Twomey Partners. Information you provide to us If you submit an enquiry or request a Client Acquisition Review through our website, we may collect: your first and last name; email address; mobile number, where provided; law firm or organisation; your professional role; your client acquisition priorities; information you provide about your firm's current acquisition position; and any other information you choose to provide when communicating with us. Providing a mobile number is optional. If you subsequently communicate with us by email or telephone, we may also retain relevant information from those communications as part of our record of the enquiry. Meeting and booking information If you choose to book a meeting through a scheduling service such as Calendly, information such as your name, email address, meeting details and any information you provide during the booking process may be processed in order to arrange and manage the meeting. Meeting information may also be added to our Google Calendar and associated Google Workspace services. Information collected when you use the website When you visit our website, certain technical information may be collected automatically. Depending on your cookie preferences and the technologies in use at the time, this may include: IP address; browser and device information; pages visited; referring website or source; approximate location derived from technical information; interactions with the website; and advertising or campaign attribution information. Some of this information is only collected where you have given the appropriate cookie consent.

2. How we use your information We may use personal data to: respond to enquiries; provide information about Twomey Partners and our services; assess whether our services may be suitable for your firm; arrange and conduct meetings; follow up in relation to an enquiry or prospective engagement; maintain records of prospective client relationships; operate, maintain and secure our website; understand how visitors use our website; measure the effectiveness of our marketing and advertising; improve our website, services and client acquisition processes; establish, exercise or defend legal claims; and comply with legal or regulatory obligations. Submitting an enquiry does not automatically subscribe you to a general marketing newsletter or mailing list. Communications directly relating to an enquiry you have made, including reasonable follow-up about the services you expressed an interest in, may form part of our handling of that enquiry. Any separate electronic direct marketing will be carried out in accordance with applicable requirements.

3. Our legal bases for processing Under applicable data protection law, we must have a lawful basis for processing personal data. Depending on the circumstances, we may rely on: Steps taken at your request before entering into a contract Where you contact us to discuss potentially engaging Twomey Partners, request information about our services or arrange a Client Acquisition Review. Legitimate interests Where processing is reasonably necessary for the operation and development of our business, including managing enquiries, maintaining appropriate business records, improving our website and services, protecting our systems, and understanding the effectiveness of our client acquisition activity, provided those interests are not overridden by your rights and interests. Consent Where we ask for your consent, including for certain non-essential cookies, analytics technologies and advertising technologies. Legal obligations Where processing is necessary for us to comply with applicable law or regulatory requirements. Where processing is based on consent, you may withdraw that consent at any time.

4. Cookies and similar technologies Our website uses cookies and may use similar technologies. Cookies are small pieces of information stored on or accessed from your device when you use a website. They can be used for purposes including enabling website functionality, remembering preferences, understanding website usage and measuring advertising performance. Essential cookies Some cookies or technologies are necessary for the website to operate correctly or to provide functionality you have requested. These may operate without consent where permitted by law. Analytics and performance With your permission, we may use analytics technologies to understand how visitors find and use our website, which pages are viewed and how visitors interact with the site. This may include technologies provided by services such as Google Analytics. Advertising and measurement With your permission, we may use advertising and measurement technologies to understand whether our advertising results in visits, enquiries or other relevant actions. These may include technologies associated with: Google Ads; Google Tag Manager; Meta advertising and the Meta Pixel; and other advertising or measurement services we may introduce in the future. These technologies may use online identifiers and information about your interaction with our website to help measure advertising performance. Non-essential analytics, advertising and conversion-tracking cookies require consent under Irish cookie rules. Your cookie choices When you first visit our website, our cookie consent tool allows you to accept all cookies, accept essential cookies only, or manage your preferences. Non-essential cookies and tracking technologies that require consent should not be activated unless the required consent has been provided. You can withdraw or change your consent using the cookie preference controls made available through the website. Withdrawing consent does not affect the lawfulness of processing carried out before consent was withdrawn. Irish DPC guidance requires users to be able to withdraw or vary cookie consent and says doing so should be as easy as giving consent.

5. Third-party service providers We use third-party providers to help operate our website, manage enquiries, schedule meetings, communicate with prospective clients and measure website and marketing performance. These may include: HighLevel (GHL) Used for website functionality, enquiry capture, customer relationship management and related business processes. Calendly Used where you choose to schedule a meeting with us. Google We use Google services including Google Workspace and Google Calendar. Where implemented and subject to your cookie choices, we may also use Google Analytics, Google Ads and Google Tag Manager. Meta Where implemented and subject to the appropriate consent, Meta technologies may be used to measure and improve advertising performance. These providers may process personal data on our behalf or, in some circumstances, for their own purposes subject to their respective terms and privacy practices. We may also use other professional, technical, hosting, security or business service providers where reasonably necessary to operate Twomey Partners. We do not sell your personal data.

6. International transfers Some of the service providers we use operate internationally. As a result, personal data may in some circumstances be processed or stored outside Ireland or the European Economic Area. Where personal data is transferred outside the EEA, we take appropriate steps where required to ensure that the transfer is made in accordance with applicable data protection law. Depending on the destination and provider, this may include reliance on an adequacy decision of the European Commission or appropriate contractual safeguards such as Standard Contractual Clauses. GDPR protections continue to apply to transfers outside the EU, with mechanisms including adequacy decisions and appropriate safeguards used to govern such transfers.

7. How long we keep your information We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including where necessary to meet legal, regulatory, accounting or legitimate business requirements. Information relating to prospective clients who do not engage Twomey Partners is generally retained for up to 24 months from our last meaningful interaction with you, unless there is a reason to retain it for longer. Information may be deleted sooner where it is no longer required. If an enquiry develops into a client relationship, additional information may be retained for periods appropriate to that relationship and our legal and business obligations. Cookie durations may vary depending on the technology involved and your consent preferences. GDPR does not prescribe one universal retention period. Controllers are expected to retain identifiable personal data only for as long as necessary for the relevant purpose.

8. How we protect your information We take reasonable technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration or disclosure. However, no internet transmission or information storage system can be guaranteed to be completely secure. Access to personal data is limited to those who reasonably require it for the purposes described in this Privacy Policy and to relevant service providers where necessary.

9. Your data protection rights Depending on the circumstances and applicable law, you may have the right to: request access to personal data we hold about you; request correction of inaccurate or incomplete personal data; request deletion of your personal data; request restriction of processing; object to certain processing, including processing based on legitimate interests; receive certain personal data in a portable format; withdraw consent where processing is based on consent; and lodge a complaint with a data protection supervisory authority. These rights are subject to certain conditions and exceptions under applicable law. To exercise a data protection right or ask a question about your personal data, contact: [email protected] We may need to verify your identity before responding to certain requests.

10. Complaints If you have concerns about how we handle your personal data, we encourage you to contact us first so that we can try to resolve the issue. You also have the right to lodge a complaint with the Data Protection Commission (DPC) in Ireland or, where applicable, another competent supervisory authority. Data Protection Commission

11. Children Our website and services are intended for businesses and professional users. They are not directed at children, and we do not knowingly seek to collect personal data from anyone under the age of 18 through this website.

12. Third-party websites Our website may contain links to third-party websites or services, including scheduling services. If you follow a link to another website or service, that provider may collect and process information under its own privacy practices. We encourage you to review the privacy information provided by those third parties.

13. Automated decision-making We do not currently use personal data submitted through this website to make decisions about you based solely on automated processing that produce legal or similarly significant effects.

14. Changes to this Privacy Policy We may update this Privacy Policy from time to time to reflect changes to our website, services, technology, legal obligations or how we process personal data. The latest version will be published on this page and the Last updated date will be revised accordingly.