Feb 2019: Games Workshop – Niches, money trees and margins of safety

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Games Workshop – Niches, Money Trees and Margins of Safety

Feb 2019 (£30)

 

We have spent some time looking at the unusual company that is Games Workshop (GAW). We conclude to like much about it from both its exceptional financial metrics (high margins and high returns) and the tailwind that we conclude will likely drive its online profits and IP monetisation in the future. The problem (if there is one) is the Margin of Safety we are offered – or lack of it. Normally we like to find companies that are under-priced and under-earning at the time of purchase. A cursory glance at the profits and share price charts of GAW suggests this is perhaps not the case for this investment. However, two factors stood out in our work that we thought worthy of investor attention. These are:

  • The huge boost to margins that is taking place by retail sales becoming online sales
  • The fact that the group’s Intellectual Property looks substantially under monetised
Never has the word ‘niche’ been so apt

Late last year we visited Games Workshop at their Head Office and Manufacturing facility in Nottingham (Thank you Client X for kindly organising this). It is a company that for a few years we have been recommended to meet and we only wish we had heeded that advice earlier! From this trip and a studious look at the company’s past accounts we have learnt a great deal. Below we offer a few observations.

This is a company with a wonderful global niche product sold to a widespread but dedicated fan base. Games Workshop is a ‘miniature wargaming manufacturing company’ that is, it sells figurines of mythical characters, fantasy storylines. Its bestselling series being Warhammer.

Suffice to say that it is an unusual product to understand unless you are immersed in that niche (which we doubt many readers of this research will be – but see section later for help). What is striking however is the widespread global following of the product and that it has just grown almost by worth of mouth, but done so consistently over the last 30 years. Indeed, when asking the company about why it may open a store in a particular city and the data/research behind such a decision it is clear there is surprisingly little. They just look for geographic areas where they think there night be demand in and crucially try to find store manager for that local business that are/will be passionate about the product. On this point (i.e. the recruitment of the right people) however they are very clear in what they seek. This all suggests long term growth has been disciplined, but perhaps not very dynamic, especially in the online world that we now all live in. We will return to this point.

Financial metrics to die for

The output of this quirky company making games characters and shipping them globally from Nottingham, are some simple financial metrics e.g.

  • RONTA (Return on Net Tangible assets) = 150%,
  • Gross margin 70%
  • EBIT Margin 33%

In addition, the company has longstanding managers who communicate a great understanding of Intellectual Property protection, innovation and economic value creation. The company also has an excellent record of capital allocation with no acquisitions and a pay-out ratio that ranges from 70%-170% in the last 10 years. They also appear prudent. On our trip we were shown character moulds that the company created 10 years ago that occasionally are re-used for repeat product runs. We note that in the accounts however all moulds are characterised as development costs and are written off at a declining balance rate of 50% over 4 years (so 75% in first 24 months).

The business is also still growing. Store rollouts globally are adding c.+5% pa to the existing estate and most recent sales grew at 14% in 1H 2019 over the same period last year – which had itself seen very strong growth as our Appendix shows. With the shares of the company changing hands for c.17x earnings (and the Balance Sheet sitting on net cash) they appear to be reasonably priced vs. the Rare Bird characteristics that we conclude the company seemingly demonstrates.

If there is a catch, we will come to it shortly, but first we point out the two factors at GAW that excite us even more than the impressive numbers we outlined above.

They are:

1. Online sales increase will be a huge driver for profitability

The table below extracted from the group R+A shows the company’s sales and profits by different channels. In our model in the Appendix we have laid this and more past period data out to show the remarkable growth that has occurred at this company in recent years. But leaving such growth aside for a moment, another startling point we think can be seen. This being the stark difference in margins it makes between its different routes to market

Source: Games Workshop Annual Report 2018

What is not stated above but can easily be derived is the EBIT Margin each distribution channel generates. These can be easily calculated in the year to June 2018 as:

  • ‘Retail’ (i.e. own stores) 8%
  • Trade (i.e. wholesale) 34%
  • Online 64%

A visit to the company’s factory shows clearly why this is the case. Production of small, but intricate plastic modelled characters if done in scale is a very high margin activity (Ref# the companies sustained high gross margin of 71%. It has never been below 65%).

As these plastic components are sold for high prices, but are small and light, so shipping costs are low. However, to sell these in store requires a store workforce and store running costs. Those familiar with the company’s history will know that this issue, i.e. store manning and its cost structure have been the key issue for the company in the last 10 years. Whilst we are new (late?) to this company and as such we must be careful of our inexperience in its markets. That said maybe we bring a fresh pair of eyes to this long running Opex cost issue? Some years ago, we were stuck by a brilliant quote from Charlie Munger:

“you have to work out when Technology is going to kill you and when it is going to help you.” Charlie Munger

On many occasions he has used this reference to explain the tailwind that helped certain companies (the Video Recorder for Disney and Refrigeration for Coke). In today’s investment world there are many old economy business models that technology has helped kill. This quote immediately came to mind when we both listened to the GAW management talk about their business and noticed the dramatic difference in distribution channel margins for selling the exact same product.

Money tree?

We could now go off on a tangent showing a great number of companies with the exact opposite metrics, however we hope our readership has the necessary experience to agree with the following conclusion. This being that for the vast majority of retail-facing companies we meet, making money online today is a lot harder than it had been in store years before. In many cases due to the increased distribution costs or because they have lost a once dominant position due to new online competitors. There are some exceptions. A few that have been built from scale (Next like to bundle Directory purchases to enable it to make better margins than in store) and for others a higher Average Selling Price helps cover distribution costs (Ted Baker make this point stating that its online margin are as good as their best store).

However we have yet to see a company (until now) with a Store EBIT margin that has bumped around breakeven (0-10%) for 20 years only to see online sales generate 65% EBIT Margins!

Currently GAW online sales are only £44m vs. £83m in store and £94m in wholesale, but in profit terms the company makes a whopping £28m EBIT online and only £7m in store. As more and more sales may move online responding to the group’s investment in this channel, we see a continued and natural boost to margins. We also observe that:

  • A proportion (undisclosed) of the group’s wholesale sales are online also
  • Like other Intellectual Property companies (Ref our Disney and WWE work) as it spreads the word of it products/brand better internal online sales will generate higher margin that external ones (which currently lose the wholesale mark-up)
Changing guard – Changing attitudes

The company’s seemingly long-held belief (given by the ex-CEO) that the way for the business to promote itself was via its own stores. Via this channel its games characters and worlds can be explained by a local expert it has claimed. Again, we may find our lack of experience comes to bite us here, but we observe that not only do we feel that this modus operandi for the spread of the brand is outdated, it is also perhaps unnecessary.

Whilst not a perfect example one of your authors and his family are big fans of Star Wars and Lord of the Rings. Whilst these are not games, but films, importantly we have not required anyone to explain the backstories or worlds they inhabit to us. This was a process we enjoyed finding out for ourselves. However, under the previous CEO of the company (much admired we might add) a belief seemed to take hold that it was only really by a trip to the stores where a customer would find out about the storylines and game products the company possessed.

Crucially on visiting GAW this was something that we feel has been a real change of culture in the organisation on the last 1-2 years. A new CEO has welcomed more ideas from the organisation below him and these have often come in the form of ‘let’s tell our stories to the world in whatever medium we can, or whatever way they want to hear it in’ (The favourite channel being making far greater use of the company’s own website). We see this as pushing on an open door.

Having observed the staff at head office talk about ‘significant changes under the new CEO’, we looked at how long he had been there. The answer being that he was CEO since Jan 2015, so not that new we concluded? But also COO from 2011-2015. Strange we thought that such changes are seemingly heralded by staff in 2018. We conclude that this new attitude is less about the abilities of the new CEO and more about the freedom that he and his staff have found since the departure of long-standing Chairman/CEO and then Chairman again, charismatic and we guess domineering, Tom Kirby. Whilst we have enjoyed reading Mr Kirby’s past letters as much as any other shareholder and think he likely brought great financial discipline to the company with a cash and ROIC focus we think it right to conclude that when he finally left the Board completely in September 2017 it freed up those around him to develop this company to its full potential.

Pushing on an open door

For years Mr Kirby outlined the groups four key elements, they remained largely unchanged whilst he was CEO or Chair. We paraphrase below:

  1. Make high quality miniatures
  2. That are based in our imaginary worlds
  3. Global nature of our business
  4. We are focused on making money (cash) doing it

Indeed, there is nothing wrong with these building blocks for they explain the group well to outsiders like ourselves. However, we noticed some additions in the 2018 annual report. Mr Rountree and team, we suggest are opening their shoulders somewhat. Two new drivers of this business were highlighted:

“The third element is that we are customer focused. We talk to our customers. We aim to communicate in an open, fun way. Whoever and wherever our customers are, and in whichever way they want to engage with Warhammer, we will do our utmost to support them.”

“We believe our IP to be among the best in the world.”

“The Warhammer settings are incredibly rich and evocative backdrops. They’re populated by more than three decades of fantastical characters and comprise of thousands of exciting narratives. Going forward, we want to make it easier than ever for people to engage with and immerse themselves in our IP. To that end, I have a small, senior team to help me find new partners to help us bring the worlds of Warhammer to life like never before. Together, we’ll explore animation, live action and more, while ensuring we do not harm our core miniatures business.” CEO statement 2018 Report and Accounts

The above comments by us on Management and its somewhat changed focus in recent months are not to try and suggest there were problems that needed solving. They are only to try and assess the group’s potential in the two key areas that we think are crucial for its future financial success. These are its future online communication with its fan base and the sales via that profitable channel that could result and the monetisation of its IP.

Just a word on typecasting

When perhaps seeking out to typecast (an unfair activity which we apologise for, but a useful short cut maybe for investors unfamiliar with the business) a standard Games Workshop customer we are minded to think of The Big Bang Theory*. The intelligent but nerdy characters portrayed in the series are often engaged in two pastimes: 1. Playing fantasy games such as those made by GAW, and 2. Spending time online. Hence our conclusion above that the company is pushing on an open door with its new online communication with its fan base. If this were a retirement home company hoping to only explain itself by a teenage mobile app – well, take up might be hard! But this is a company that until recently chose to explain its product to perhaps the most connected social set of people on the planet, by making them go to a store…and one that just might be a long way away!

*Very good/ funny if you have never seen it and on its 12th and last season (for perspective Friends has 10 seasons!).

2. The group has enormous Intellectual Property – yet to be monetised

The second area of huge potential for this business we feel is its Intellectual Property. This is a company that has fantasy worlds and story lines galore. It is developing them all the time with new characters and new story lines and it has done so for 30 years. It also owns and controls all of its IP. How are they being played out in this digital world…? Almost solely by board games and the hobby miniatures they sell! This to us smacks of under-monetisation and post our trip to Nottingham we were delighted to hear numerous members of staff make that point themselves. They also stated that this was a point of resistance for the previous CEO, but one that the current CEO and his team are embracing more fully. The above quote from the current CEO in his 2018 letter on IP makes this clear. It is in contrast to Tom Kirby’s chairman letter of 2016 which we extract below:

Games Workshop – the IP play

Over the years we have been exhorted by some to develop our revenue stream by ‘leveraging’ our IP. Using our great imagery we could do all sorts of lucrative and exciting value-enhancing (i.e. take private and re-float) deals. Actually, what they really mean is: do a movie!

We have never NOT done licensing deals, as you can see from the steady stream of royalties we earn; it’s just that we believe we must do them on our terms and not prostitute the business to any and every deal that comes along. If we do a movie (along with the concomitant abandonment of the toy rights*) it will be on terms that do not compromise our business. It isn’t likely.

Long term owners will notice a big increase in royalty income this year. Have we sold out at last? No, it’s just that working closely with the myriad app developers, and being more precise with the terms we offer, we have increased the number of ‘computer’ games in the market.

*Anyone doubting this aspect of movies needs to read how Marvel prevented an Iron Man movie having a female as the main baddie because it would hurt the toy salesExtract from 2106 Chairman Letter – Tom Kirby

Whilst we admire this company’s determination, both past and present to defend its IP. We conclude that Mr Kirby was maybe somewhat stuck in the past. Also, that whilst scepticism of all new ideas emanating from the city is always wise, unchecked scepticism can become cynicism.

Time spent studying Disney’s development of the many brands within it we think is illustrative. A new modern iteration of a brand, if well-constructed can bring its values and enjoyment to many more customers. We offer for reference the new Mary Poppins movie, or Rogue One from Star Wars. We must be clear, we are not saying “Do a Movie” we are saying modernise your IP, whilst protecting it and communicating with your current and new customers in ways they want in todays world. Thankfully we do not think that this a message Mr Rountree needs to hear from us. He and his passionate staff concluded as such some time ago it seems.

The big caveat – has the business been over-earning?

So what holds us back from shouting from the rooftop that this share is a buy? Only the recent trajectory of profits and the lack of Margin of Safety an investor may get from buying at the top of the hockey stick. The chart below shows the enormous leaps in profit this company has achieved in recent years. Unsurprisingly the share price has mirrored this, jumping from £5 in 2015 to £30 today.

Fig.1: Operating Income

  Source: Bloomberg

A longer term perspective also shows that the company has had reductions in sales levels before, i.e. this has not been a linear growth story of just more players spending a little more gradually over time.

As a result, this is the analytical challenge/question we are looking at. We need to better understand whether this company has been overearning in recent years. This is not meant as a criticism, or to suggest the results have been artificially boosted in anyway. Only that with different product releases at different times, depending on the scale of customer take up could have seen a period of very strong sales growth that is then followed by a quieter period. Buying into the shares at say a reasonable valuation for such franchise (16x unlevered) is all well and good but if this is based on a level of profits that are latterly observed to have been elevated an investor may have either over paid for the Franchise or at the very least seen his Margin of Safety evaporate. The group disclosed that in 2018, 38% of its sales were ‘new products’.

Whilst this is an impressive Phil Fisher esq. stat, it does pose the question of whether the group has overtraded for a period selling strong new products into an exciting customer base that might re-trench for a while…? Or have they reached a new much wider number of customers. On that point we currently do not have enough information to judge either way. That said we thought the most recent new chairman’s statement was of interest:

This is my first statement as non-executive chairman of Games Workshop Group PLC: …..Your board believes that the Company has achieved a new order of magnitude, driven by the strategy devised and implemented by our CEO, Kevin Rountree. Chairman’s Letter 2018

Whilst we have work to do to try to better understand this company’s current and near future earning power, the Board it seems believes that Mr Rowntree has built something that is sustainably bigger and will grow further.

We pause – for now

For now, we will leave our observations there. We very much like this company’s:

  • Great financials characteristics
  • Global niche
  • The tailwind that more online sales with bring to EBIT margin upside
  • That its fully controls and owns all its IP, but has yet to fully monetise its full potential
  • That is has a management team seeming focused on these opportunities

We are looking at the Margin of Safety (i.e. peak profitability or not) actively and would happily share/learn from those that know the company a little better than us newbies.

Kind regards

Andrew Hollingworth & Mark Power

The Directors and employees of Holland Advisors may have a beneficial interest in some of the companies mentioned in this report via holdings in a fund that they also act as advisors to.

Appendix

Fig.2: Holland Summary Model

  Source: Holland Advisors, Company Reports

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Disclaimer
Please read the following conditions of use of this website. This website is directed at high net worth experienced investors and institutional investors who understand the risks involved with the investments being promoted and it should not be relied upon by retail clients (as defined by Financial Conduct Authority). The information on this website is issued by Holland Advisors (London) Limited (hereafter referred to as “Holland Advisors”), a limited liability company (7431314) incorporated in England and Wales, which is authorised and regulated by the Financial Conduct Authority (FRN: 538932). This website is for information purposes only and does not constitute an offer or solicitation to buy or sell securities, funds or any other financial instrument. The information is directed inside the United Kingdom and is not directed at any persons in jurisdictions where it would be against local law or regulation.  In particular, information on this site is not directed at any person, partnership or corporation being resident in the United States of America. Holland Advisors disclaims all responsibility if you access or download any information in breach of any law or regulation of the country in which you reside. Information on this site The information provided does not constitute advice. Holland Advisors believes that the sources of the information in this website are reliable. However it cannot and does not guarantee, either expressly or implicitly, and accepts no liability for, the accuracy, validity, timeliness or completeness of any information or data (whether prepared by it or by any third party) for any particular purpose or use or that the information or data will be free from error. Holland Advisors does not undertake any responsibility for any reliance which is placed by any person on any statements or opinions which are expressed herein. Neither Holland Advisors nor any of its directors, officers or employees will be liable or have any responsibility of any kind for any loss or damage that any person may incur resulting from the use of this information. This does not exclude or restrict any duty of liability that Holland Advisors has to its customers under the regulatory system in the United Kingdom. All Information may be changed or amended without prior notice although Holland Advisors does not undertake to update this site regularly. Marketing Communications Documents on this site do not constitute investment research as they have not been prepared in accordance with UK legal requirements designed to promote the independence of investment research. Therefore, even if they contain research recommendations they should be treated as marketing communications and as such will be fair, clear and not misleading in line with Financial Conduct Authority rules. These communications are not personal recommendations to you and any opinions cited are subject to change without notice. Holland Advisors takes all reasonable care to ensure that the information on this site is accurate and complete; however no warranty, representation, or undertaking is given that it is free from inaccuracies or omissions. Documents on this site are based on, and contain, current public information, data, opinions, estimates and projections obtained from sources we believe to be reliable. Past performance is not necessarily a guide to future performance. The content of these documents may have been disclosed to the issuer(s) prior to dissemination in order to verify their factual accuracy. Investments in general involve some degree of risk, therefore Prospective Investors should be aware that the value of any investment may rise and fall and you may get back less than you invested. Value and income may be adversely affected by exchange rates, interest rates and other factors. The investments discussed on this website may not be eligible for sale in some states or countries and may not be suitable for all investors. If you are unsure about the suitability of an investment given your financial objectives, resources and risk appetite, please contact your financial advisor before taking any further action. Holland Advisors and/or its officers, directors and employees may have or take positions in securities, funds or derivatives mentioned on this site (or in any related investment) and may from time to time dispose of any such securities (or instrument). Holland Advisors manages these potential conflicts of interest internally via its compliance procedures. Fund Information Parts of this site may refer to Funds managed or advised by Holland Advisors. These are not solicitations to invest and any potential investors should refer to the “Our Funds” section of the website in order to learn more about these Funds and find out how and where to obtain the relevant full legal documentation. Linked Websites This site may be linked to third party websites or contain information provided by third parties. Holland Advisors does not make any representation as to the accuracy or completeness of such websites or information, has not and will not review or update such websites or information, and cautions browsers that any use made of such websites or information is at their own risk. Holland Advisors does not accept any liability arising out of the information contained on any linked website or Information provided by a third party and the use of such sites and information is at your own risk. This does not exclude or restrict any duty or liability that Holland Advisors has to its customers under the regulatory system in the United Kingdom. Indemnity You agree to indemnify and defend Holland Advisors, its affiliates and licensors, and the officers, directors, employees, and agents of Holland Advisors and its affiliates and licensors, from and against any and all claims, liabilities, damages, losses, or expenses, including legal fees and costs, arising out of or in any way connected with your access to or use of this website and the Information. Use of Cookies If you agree to these terms and conditions a “cookie” might be placed on your computer. A cookie is a packet of information that does not identify individual users of a website, but allows the collection of website activity (such as the number of users who visit our website, the date and time of visits, the number of pages viewed, navigation patterns, what country and what systems users have used to access the site). We can use this information for statistical purposes, which allows us to analyse and improve our website. The cookie will expire automatically after 6 months or you can manually remove cookies in your browser settings. Copyright, Trademarks and Other Rights Copyright, trademarks, database rights, patents and all similar rights in this site and the information contained in it are owned by Holland Advisors or relevant third party providers. You may use the Information and reproduce it in hard copy for your personal reference only. The information contained herein and any supplemental documentation provided is confidential and should not be copied, reproduced or redistributed without the prior consent of Holland Advisors. Governing Law You agree that your use of this site and any dispute arising from this use is subject to English law and you submit to the jurisdiction of the Courts of England & Wales.
Privacy Notice
This is the privacy notice of Holland Advisors London Ltd our company number is 07431314. Our registered office is at The Halt, Smugglers Way, The Sands, Farnham, Surrey, GU10 1NB.
Introduction
This notice describes how we collect, store, transfer and use personal data. It tells you about your privacy rights and how the law protects you. In the context of the law and this notice, ‘personal data’ is information that clearly identifies you as an individual or which could be used to identify you if combined with other information. Acting in any way on personal data is referred to as ‘processing’. This notice applies to personal data collected through our website www.hollandadvisors.co.uk. Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
Data Protection Officer
We have appointed a data protection officer (‘DPO’) who is responsible for ensuring that our privacy policy is followed. If you have any questions about how we process your personal data, including any requests to exercise your legal rights, please contact our DPO, Claire Brunt at  claire@hollandadvisors.co.uk.
Personal data we process
1. How we obtain personal data The information we process about you includes information:
  • you have directly provided to us
  • that we gather from third party databases and service providers
  • as a result of monitoring how you use our website or our services
2. Types of personal data we collect directly When you use our website, you may provide personal data by submission of data by our Sign Up or Contact Us forms. This can be categorised into the following groups:
  • personal identifiers, such as your first and last names
  • contact information, such as your email address and your telephone number for communication
  • records of communication between us including messages sent through our website, email messages and telephone conversations
  • marketing preferences that tell us what types of marketing you would like to receive
3. Types of personal data we collect from your use of our services By using our website and our services, we process:
  • technical information about the hardware and the software you use to access our website and use our services, including your Internet Protocol (IP) address, your browser type and version and your device’s operating system
  • usage information, including the frequency you use our services, the pages of our website that you visit, whether you receive messages from us and whether you reply to those messages
  • your preferences to receive marketing from us; how you wish to communicate with us; and responses and actions in relation to your use of our services.
4. Our use of aggregated information We may aggregate anonymous information such as statistical or demographic data for any purpose. Anonymous information is that which does not identify you as an individual. Aggregated information may be derived from your personal data but is not considered as such in law because it does not reveal your identity. For example, we may aggregate usage information to assess whether a feature of our website is useful. However, if we combine or connect aggregated information with your personal data so that it can identify you in any way, we treat the combined information as personal data, and it will be used in accordance with this privacy notice. 5. The bases on which we process information about you The law requires us to determine under which of six defined bases we process different categories of your personal data, and to notify you of the basis for each category. If a basis on which we process your personal data is no longer relevant then we shall immediately stop processing your data. If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information. 6. Information we process with your consent Through certain actions when there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, you provide your consent to us to process information that may be personal data. Wherever possible, we aim to obtain your explicit consent to process this information, for example, we ask you to agree to our use of non-essential cookies when you access our website. We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists. You may withdraw your consent at any time by instructing us  claire@hollandadvisors.co.uk. 7. Information we process for the purposes of legitimate interests We may process information on the basis there is a legitimate interest, either to you or to us, of doing so. Where we process your information on this basis, we do after having given careful consideration to:
  • whether the same objective could be achieved through other means
  • whether processing (or not processing) might cause you harm
  • whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
  • improving our services
  • record-keeping for the proper and necessary administration of our business
  • responding to unsolicited communication from you to which we believe you would expect a response
  • preventing fraudulent use of our services
  • exercising our legal rights, including to detect and prevent fraud and to protect our intellectual property
  • insuring against or obtaining professional advice that is required to manage business risk
  • protecting your interests where we believe we have a duty to do so
How and when we process your personal data
8. Your personal data is not shared We do not share or disclose to a third party, any information collected through our website.
Use of information we collect through automated systems
9. Cookies Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit a website that uses them. They allow information gathered on one web page to be stored until it is needed for use at a later date. They are commonly used to provide you with a personalised experience while you browse a website, for example, allowing your preferences to be remembered. They can also provide core functionality such as security, network management, and accessibility; record how you interact with the website so that the owner can understand how to improve the experience of other visitors. Some cookies may last for a defined period of time, such as one visit (known as a session), one day or until you close your browser. Others last indefinitely until you delete them. Your web browser should allow you to delete any cookie you choose. It should also allow you to prevent or limit their use. Your web browser may support a plug-in or add-on that helps you manage which cookies you wish to allow to operate. The law requires you to give explicit consent for use of any cookies that are not strictly necessary for the operation of a website. 10. Personal identifiers from your browsing activity Requests by your web browser to our servers for web pages and other content on our website are recorded. We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution. We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
Other matters
11. Your rights The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data. We do this now, by requesting that you read the information provided at  http://www.knowyourprivacyrights.org 12. Communicating with us When you contact us, whether by telephone, through our website or by email, we collect the data you have given to us in order to reply with the information you need. We record your request and our reply in order to increase the efficiency of our business. We may keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service. 13. Complaining If you are not happy with our privacy policy, or if you have any complaint, then you should tell us. When we receive a complaint, we record the information you have given to us on the basis of consent. We use that information to resolve your complaint. 14. Retention period Except as otherwise mentioned in this privacy notice, we keep your personal data only for as long as required by us to provide you with the services you have requested. 15. Compliance with the law Our privacy policy complies with the law in the United Kingdom, specifically with the Data Protection Act 2018 (the ‘Act’) accordingly incorporating the EU General Data Protection Regulation (‘GDPR’) and the Privacy and Electronic Communications Regulations (‘PECR’). 16. Review of this privacy policy We shall update this privacy notice from time to time as necessary.