Updated:              17 April 2026

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If you need a pdf version of this policy document, please email us at info@tricio-advisors.com. 

 

Tricio Investment Advisors Limited (“Tricio” “Us,” or “We”) is committed to protecting the privacy of the users of our subscription or consulting services and our company website (www.tricio-advisors.com) (thereafter the “Web Site”).

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The Web Site was designed to help you and your company develop a good understanding of Tricio’s service offerings. Certain areas on the Web Site can only be accessed by registered users.

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This privacy policy (the “Policy”) discloses Tricio’s information privacy practices for the Web Site, and is intended to inform registered users and other visitors to the Sites of the data collection and use practices of the “Sites” (i.e. both “Web Site” and other sites that we may notify you from time to time).

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This Policy explains how Tricio Investment Advisors Limited collects, uses, and protects your personal information. We process your personal data only where we have a lawful basis to do so under UK GDPR. Depending on the activity, this may include the performance of a contract with you, compliance with a legal obligation, our legitimate interests as a provider of research and consulting services, or other areas that require your consent. The specific legal basis applicable to each type of processing is set out in the relevant sections of this Policy.

 

Amendments to this Policy will be posted on www.tricio-advisors.com and will be effective upon being posted. Your continued use of the Sites following the posting of any amendment will constitute your acceptance of that amendment, except if your personally identifiable information will be used in a materially different manner. See the Notification of Changes section below for further information.

 

If you have questions or concerns regarding this Policy, you should contact Tricio by e-mail at ‘info@tricio-

advisors.com’.

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Legal Bases for Processing

UK GDPR requires us to identify a lawful basis for each type of personal data processing we carry out. The bases we rely on are:

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Performance of a contract — where processing is necessary to provide the subscription, consulting, or other services you have requested from us, including managing your account and delivering publications.

 

Legitimate interests — where we have a genuine business interest in processing your data that is not overridden by your rights and interests. This includes sending research materials, publications and updates to individuals who have registered for our webinars or expressed an interest in our services, improving our website and services, and maintaining the security of our systems. Where we rely on legitimate interests, you have the right to object to that processing (see “Your Rights” below).

 

Legal obligation — where processing is necessary to comply with our legal and regulatory obligations.

 

Consent — where we ask for and receive your specific agreement to a particular use of your data. Where consent is the basis, you may withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.

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Registered Users

Registration is not mandatory to access certain public areas of the Web Site. A pre-paid subscription or trial registration is, however, required for access to certain areas of the Web Site. There are also certain products and services that are only provided through these areas of the Web Site. When you sign up for a subscription or register for a trial use of Tricio’s services, you are given an account with Tricio (your “Account”). You will then set up or be assigned a username and password for purposes of accessing your Account and the portions of the Web Site available to registered users.

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You agree that you will not share your username and password with others.

 

For users who have signed up to receive our regular publications and reports, Tricio may also send these materials, newsletters and other materials like multi-media files to the email addresses that the users provide on registration. These materials may be sent as links to the password protected area of Tricio’s Web Site, or to other third party websites where any multi-media materials will be stored.

 

If you are subscribing for a service on Tricio’s Web Site, you may be taken to selected websites of third party service providers (“Third Party Service Sites”). You will only be accessing these Third Party Service Sites for certain specific activities, like making payments to Tricio via these third party service providers. The Third Party Service Sites will have their own privacy and data protection policies, which you need to read and confirm before completing any payment or other activities via these third party service providers. You would also need to enter details relating to your payment card, bank account or other payment services in these Third Party Service Sites. These data will not be held by Tricio.

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See also the section CONSENT TO THE USE OF THIRD PARTY PROVIDERS below for further information.

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Research Publications, Webinars and Electronic Communications

Where you register for a Tricio event including online webinars, we will use the email address you provide to send you materials directly related to that event. That will include complimentary copies of relevant presentations, papers, research publications, multi-media files. We do this on the basis of our legitimate interests as a research service provider, and in reliance on the soft opt-in provisions of the Privacy and Electronic Communications Regulations 2003 (PECR), which permit us to contact individuals who have expressed an interest in our services with information about similar products and services.

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You may opt out of these communications at any time by contacting us at info@tricio-advisors.com, or – if available - by clicking the unsubscribe link in any email we send. We will action all opt-out requests promptly and within no more than five business days.

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We will retain your contact details collected at webinar registration for the duration of any complimentary access period of relevant materials and for a further period of 90 days thereafter, unless you have subscribed to a paid Tricio service or otherwise agreed to ongoing communications, in which case our standard subscriber retention terms apply.

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Personally Identifiable Information

We collect and share personally identifiable information regarding users of the Web Site as described in this Policy. Except as noted in this Policy, personally identifiable information collected on the Web Site is not shared with third parties without your consent.

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We may automatically collect personally identifiable information from you when you access the Web Site. We may also collect personally identifiable information from you through a number of voluntary sources on the Web Site, such as emails, postings, messages or other electronic submissions and communications sent by you to Tricio or the Web Site.

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The personally identifiable information we may collect from you will include, by way of example:

• Full name

• Company name

• Contact information (including, address, postal/zip code, country, and phone number)

• E-mail address

• Other information volunteered by users, such as information provided during surveys and the Web Site’s registration

• Internet Protocol or IP address

• User specific and aggregate information on the areas of the Web Site accessed

• User name and password information for the Web Site.

 

YOU SHOULD NOT PROVIDE TRICIO WITH ANY PERSONALLY IDENTIFIABLE INFORMATION OR SUBMIT OR POST ANY PERSONALLY IDENTIFIABLE INFORMATION TO THE WEB SITE UNLESS YOU WOULD LIKE THAT INFORMATION TO BE USED BY TRICIO IN ACCORDANCE WITH THIS POLICY.

 

LIKEWISE, YOU SHOULD NOT SUBMIT OR POST ANY PERSONALLY IDENTIFIABLE INFORMATION TO THE WEB SITE UNLESS YOU WANT THAT INFORMATION TO BE ACCESSIBLE BY OTHER USERS OF THE WEB SITE, AS INFORMATION POSTED ON THE WEB SITE MAY BE MADE AVAILABLE TO OTHER USERS OF THE WEB SITE. PERSONALLY IDENTIFIABLE INFORMATION POSTED TO RESTRICTED AREAS OF THE WEB SITE IS NOT ACCESSIBLE BY OTHER REGISTERED USERS OF THE WEB SITE.

 

The personally identifiable information that Tricio collects from users of the Web Site (both registered and unregistered) may be used for a variety of purposes, for example to provide the services and products offered through the Web Site to users of the Web Site, to customise content and/or layout of the Web Site for each individual user of the Web Site, to notify users of the Web Site about updates to and activities on the Web Site and about goods and services that we feel may be of interest to you, to improve the content of the Web Site, to analyse data and patterns regarding usage of the Web Site, to contact users of the Web Site for marketing purposes, and to contact users of the Web Site for information verification purposes.

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Tricio may collect and publish statistics and usage information related to the users consumption and feedback of content only in anonymous information cases. We may publish consumption data associated with a certain keyword or piece of content, but never in relationship to your Account. We may collect certain information from visitors to the Web Site and users of Tricio services, such as Internet addresses. This information is logged to help diagnose technical problems and prevent security breaches.

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Disclosure as Required by Law

Though we make every reasonable effort to preserve user privacy, we may need to disclose personally identifiable information of certain users of the Web Site when we have a reasonable and good-faith belief that the disclosure is necessary to comply with a current judicial proceeding, a court order, or legal process served on Tricio or the Web Site. In this situation we will use reasonable efforts to provide notice of this disclosure to all affected users, to the extent reasonably possible under the circumstances.

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Communication with Users and Clients

We may contact you to notify you regarding your Account, to troubleshoot problems with your Account, to notify you about temporary suspension to the service provided by the Web Site, to resolve a dispute, to collect fees or monies owed, or as otherwise necessary to contact you to enforce our service agreement, applicable national laws, and any agreement we may have with you. For these purposes we may contact you via email, telephone, text messages, and postal mail.

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In some circumstances, we may send new registrants of the restricted area of the Web Site or of relevant Tricio service a welcoming email to verify password and username. Generally, users cannot opt-out of these communications.

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Special Offers and Updates

Established members and registered users will occasionally receive information on products, services and special deals, and periodic newsletters in accordance with their subscription agreements.

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Data Retention

We retain personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable law or regulation. As a guide:

• Account and subscriber data is retained for the duration of your subscription and for up to two years following termination or expiry, to allow for reactivation and to meet any regulatory record-keeping obligations.

• Webinar and event registration data is retained for the duration of any associated complimentary access period and for 90 days thereafter, unless you become a subscriber or consent to ongoing communications.

• Website usage and analytics data is retained in anonymised form for up to 12 months.

• Legal and compliance records are retained for the periods required by applicable laws and regulations.

 

Where data is no longer required, it is securely deleted or anonymised.

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Non-Personally Identifiable Information

Where possible, our system automatically recognises each visitor’s Internet Protocol addresses. We also collect information about how visitors use the Web Site (for example what pages are viewed and products and services are purchased). This information, which is collected and maintained in an anonymous and non-personally identifiable form, allows us to improve the content of the Web Site and facilitate market research. Sometimes, we utilise the services of a third party to help us understand this information better, although the information that is disclosed to these entities remains at all times in anonymous and non-personally identifiable form. Other than improving the Web Site and the experience of visitors to the Web Site, we make no other use of this information.

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Transfer of Information

As we continue to develop our business, we may participate in corporate transactions such as mergers and acquisitions, and it is possible that another company may acquire Tricio or its business assets in the future. If Tricio elects, in its reasonable discretion, to transfer ownership or control of the Web Site to a third party, whether or not in the context of an acquisition of Tricio or a merger of Tricio with a third party, you consent to the transfer of your personally identifiable information and non-personally identifiable information to that third party, provided that all use of your information by that third party remains subject to the terms of this Policy.

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International Transfers of Personal Data

Tricio is based in the United Kingdom and your personal data is primarily processed within the UK. However, some of our third party service providers — including our website hosting provider, payment service provider and email distribution platform — may process data in countries outside the UK, including the United States.

 

Where personal data is transferred outside the UK, we ensure that appropriate safeguards are in place in accordance with UK GDPR. These safeguards may include:

• Transfers to countries covered by UK adequacy regulations;

• Use of the UK International Data Transfer Agreement (IDTA) or UK Addendum to the EU Standard Contractual Clauses; or

• Other lawful transfer mechanisms approved by the ICO.

 

Details of the safeguards applicable to transfers made by our key third party processors are available on request by contacting info@tricio-advisors.com.

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Cookies

Tricio uses “cookies” to improve the experience of the Web Site. A cookie is a text file that is placed on your hard disk by a web page server, often including an anonymous unique identifier. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

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We may use cookies for various purposes, for example, to save user preferences, customise Web Site content for individual users, to ensure that users are not repeatedly sent the same content, to record session information, to alert users to new areas that might be of interest upon return to the Web Site, and to save certain information about users of the Web Site and others who visit the Web Site. We also use cookies to record current login information; however, you are still required to log in to your Account after a certain period of time has elapsed to protect you against others accidentally accessing your Account.

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For more information about cookies in general and how they are used in Tricio’s Web Site, please visit www.tricio-advisors.com.

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Consent to the Use of Third Party Providers

In addition to the Third Party Service Sites noted in this Policy, Tricio may also contract with other third parties to provide various services to Tricio relating to the Web Site on an outsourced basis rather than performing the services itself. For example, Tricio may contract with an email provider to handle the distribution of email messages to registered members of the Web Site and/or related services. Likewise, Tricio may contract with a web site hosting provider to host all or a portion of the Web Site for Tricio.

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Where Tricio engages third party providers to deliver services on its behalf — such as email distribution, website hosting, or payment processing — those providers act as data processors and are permitted to process your personal data only on Tricio’s instructions and for the purposes described in this Policy. We rely on our legitimate interests, or the performance of a contract with you, as the lawful basis for sharing your data with these processors. We do not authorise third party processors to use your personal data for their own marketing or commercial purposes.

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It’s important to note that these third-party providers including the Third Party Service Sites may place cookies or utilising other tracking technologies. These third-party providers have their own privacy and data collection policies and practices. Tricio is not responsible for any actions or privacy policies of such third parties. You should check the applicable privacy and data tracking policies of those third parties when providing personally identifiable information through linked web sites and Third Party Service Sites.

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Notification of Changes

If we decide to change the Policy, we will either notify users by way of an email or post material changes on the Web Site so our users are aware of what information we collect, how we use it, and if we disclose it. Unless we seek and receive your consent, we will use information in accordance with the Policy under which the information was last collected. Users may prevent their information from being used for purposes other than those for which it was originally collected by emailing us at ‘info@tricio-advisors.com’.

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Security

Tricio’s company web site is currently hosted on a third party web site hosting provider. That gives us an integrated platform that allows us to describe Tricio’s service offering, sell our products and provide services to you. Your data may be stored through the third party web site provider’s data storage, databases and related applications. They store your data on secure servers behind a firewall. The Web Site is protected by an SSL certificate, with the data encrypted and authenticated for security purpose following the current standards.

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All direct payment gateways offered by the third party web site hosting provider and used by our company adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card, payment card or other information through the Web Site and its service providers.

 

We also limit access to your data to our employees who we believe reasonably need to come into contact with that information. While no system is guaranteed to be completely secure, we work hard to ensure our security measures protect all information in a responsible manner.

Your Rights

Under UK GDPR, you have the following rights in relation to your personal data:

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Right of access — you may request a copy of the personal data we hold about you.

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Right to rectification — you may ask us to correct inaccurate or incomplete data.

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Right to erasure — you may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, or where you have withdrawn consent and there is no other lawful basis for processing.

 

Right to restriction — you may ask us to restrict processing of your data in certain circumstances, for example while a complaint is being resolved.

 

Right to data portability — where processing is based on your consent or a contract, you may request that we provide your data in a structured, commonly used, machine-readable format.

 

Right to object — you have the right to object at any time to processing based on legitimate interests, including where that processing involves direct marketing. Where you object to direct marketing, we will cease that processing promptly as detailed in the section Research Publications, Webinars and Electronic Communications. Where you object to other legitimate interests processing, we will cease unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms.

 

Right to withdraw consent — where we rely on your consent as the legal basis for processing, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

 

To exercise any of these rights, please contact us at info@tricio-advisors.com. Unless it has been specified differently in other parts of this Policy, we will respond within one calendar month of receiving your request.

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Right to complain — if you are unhappy with how we have handled your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at www.ico.org.uk or by calling 0303 123 1113. We would, however, welcome the opportunity to address your concerns directly before you contact the ICO.

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Contact Information

Any questions or suggestions about this Privacy Policy, including changing your preferences in communications, should be addressed via email to: ‘info@tricio-advisors.com’.

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Tricio Investment Advisors Ltd

 

T +44 (0)20 3855 5830

E info@tricio-advisors.com

 

The Old Town Hall, Market Place, Oundle, Peterborough, England, PE8 4BA

 

© Copyright Tricio Investment Advisors Ltd