Year End Investment Letter – Sep 2019

This letter is not part of the fund prospectus or offering documentation of Farnam Street Capital Fund. Opinions expressed below are only those of the manager and shared for the interest of readers only. Qualitative terms like ‘great’ and ‘compounding’ are used only to explain the managers investing approach. Readers are instructed to look at the full disclaimers and fund prospectus.

Download PDF

Year End Investor Letter – September 2019


Dear Investors and Friends,

Net Asset Value: £162.6

During the year to September 2019 the Fund’s NAV fell -4.1% to a NAV of £162.6. This figure is after all fees and the Fund’s modest day to day running costs.

The economic/investing backdrop

We have before described the macro environment as the wing mirrors on our car. We need to pay attention to them but they are not our main focus. This year however has provided an unusually volatile environment due to Brexit uncertainties affecting the share prices of some of the companies we own as well as influencing the Sterling exchange rate that our overseas investments are converted at.

We would ask those reading this letter to reflect on the fact that we have used the phrases ‘volatility’ or ‘uncertainty’ above – not ‘risk’. The distinction we think is an important one that many investors confuse. When high uncertainty (but actually low risk) events are priced in a dramatic manner wonderful opportunities can arise. During the year we have made two distinct changes to the portfolio as a result of the volatility that has been experienced. Firstly, we have sold a number of US securities reinvesting monies into some UK opportunities we assessed as cheaper post their share price falls. In addition we have hedged some of our £/$ exchange rate exposure.

Bigger than Brexit

Whilst Brexit (and US/China trade) news has dominated investors’ minds and economic commentators’ voices a bigger top-down event is affecting equity investors today. This being the polarisation of what we will call ‘growth at any price’ vs. ‘margin of safety’ investing (others might call it momentum vs. value). We wrote about this at length in a recent research report (Mr Market’s broken machine – Aug 2019). An abridged version of events goes something like this – As a knock on effect of low interest rates predictable investments such as government bonds, quality property or other utility type investments have been consistently repriced upwards. More defensive (quality) businesses have similarly been repriced as a result. Expressed in this way this is a logical sequence of events. However what started as good logic (pay a little more for a better quality business/cashflow stream) has arguably become something of a cult more recently. An example being that c.30% of global government bonds now have negative yields.

“What the wise do in the beginning, fools do in the end.” Warren Buffett

Do not get us wrong, amongst the investors who have performed well in this period are some excellent analysers of businesses who have worked hard to identify quality companies. However for each of these there are many, many momentum investors along for the ride.

Staple holdings of such quality portfolios are companies such as Unilever and Becton Dickinson. These are businesses we have analysed in-depth and owned in the past, doing so when we felt the quality they offered was mispriced on PE’s of c.13x a few years ago. Purchasing Becton at a price of c.$80 as we did in 2011 on a PE of 13x was one of our better decisions. Not continuing to hold it was one of our worst! (Today Becton’s price is $253 and its PE 25x). However owning such a company today hoping it will compound investor returns at anything like the rate it has in recent years is folly.

As the saying goes ‘price is what you pay – value is what you get.’ Below is an extract from our website that we hope illustrates this point.

A well respected global company that many investors would accept as a franchise today makes a return on its tangible capital of 15%. The intrinsic value of this company is likely to rise, we assess, by c.11% many years into the future, therefore it is an interesting company. What we believe makes it a compelling investment today, however, is its starting price of 10x current earnings (PE). We think it wrong that an investment which can compound at c.11% for many years can be purchased for 10% earnings yield and therefore, in time, its mispricing will be corrected by markets. So, a move to a justifiable PE of say 13x in 3 years’ time, added to an 11% compound annual return, results in an investor IRR of c.21% over the next three years. However, the exact same company shares purchased at, say, a PE of 20x earnings that then falls to a multiple of 15x in 3 years would make an annual return to the investor of less than 1%. Source: Holland Advisors

We wrote this in c.2014 when re-doing our website and whilst it was designed to make a generic point the company example was real. It was J P Morgan, then priced at c.$60. We are pleased to report that the expected IRR of c.21% was in fact achieved and JPM today is priced at $120 and on a PE of 13x.

We have written many times in these letters and other research reports that fundamentally we are trying to buy great companies, run by great managers at great prices. For only by doing so do we feel we stand the greatest chance of achieving the best compound returns for you and ourselves as Fund investors. The later point (i.e. ‘at great prices’) we feel is being missed by many of today’s ‘quality’ obsessed investors. Indeed by paying a little less attention to price they make their day job a little easier. For once you ignore price there are so many more great investments to choose from! Whilst we can observe how the actions of others have changed, with some now overpaying for their definition of quality our resolve is unchanged. We want to own great businesses with outstanding compounding abilities but still demand low starting valuations that bring a margin of safety. As an aside we find it interesting to note the recent investments made by Buffett and Munger. Most ‘quality’ investors today likely learnt from someone who learnt from someone who in turn was originally influenced by Munger’s superior thinking on the compounding abilities of quality businesses. As such it is interesting that in the last 5 years almost all of the new investing capital deployed by Berkshire has gone into three areas: Banks, Airlines and Apple. In each case they paid c.10x current earnings for a business they thought had better compounding and pricing power than Mr Market discounted.

As a sign off for this section we thought investors might find it interesting what prompted us to take a look at Becton Dickinson in 2011 in the first place. The answer is that Lou Simpson (who for 20 years was Warren Buffett’s unsung investing partner) bought the shares. Lou’s investing track record was exceptional (20% cagr’s for 25 years). His words hang above Andrew’s desk:

  • Think independently
  • Invest in high return businesses run for the shareholders
  • Invest for the long term
  • Do not diversify excessively
  • Pay only a reasonable price, even for an excellent business

Whilst all of these points are a great help to keep us focused on the job in hand, the last one resonates more strongly than ever today.

Owner Managers

We wrote on this subject in our interim letter so will not repeat our comments. However a pertinent question was asked by one investor in response. ‘Why do opportunities to invest in these good managers exist at all?’ There are in truth many reasons but a few common ones include:

  • An owner manager’s maverick style meaning they are misunderstood or unpopular with investors (Ryanair/Sports Direct)
  • An owner manager’s tendency to be brutal with the truth when a career CEO might sugar coat it (Next)
  • Owner manager’s plan for the very long term thus making investments that incur a shorter term cost to the business but that will position it strongly further out (Schwab).

Such actions can create investor confusion, uncertainty and falls in profitability. Thus leading to lower prices for the opportunistic investor. By way of example we give the two year share price ranges for the companies we have highlighted above. Considering the broader resilience of each of these businesses in scale and market share the size of the price volatility we think is notable:

2017-2019 share price ranges

  • Ryanair €17 – €9
  • Sports Direct 440p – 220p
  • Next £66 – £38
  • Charles Schwab $55 – $35

This is where the role of Buffett’s Mr Market comes in. Each day he chooses to price these whole companies, but we as long term shareholders need do nothing. Occasionally however we can chose to act if we assess the value offered as compelling.

Portfolio Changes

During the year two new sizeable holdings appear on our factsheet, these being S&U plc and Schwab. It will not surprise investors to know that each has a strong owner manager culture. Charles Schwab founded his company in 1971 and still owns 10% of its equity today. The value he offers customers using his company’s online dealing and custody services is extraordinary. In a research note earlier this year we described it as a ‘flywheel business’ i.e. one that is constantly reinvesting in lower prices and better services for the customer to drive future demand. This is a business model we know, like and have seen used powerfully for decades by some of the world’s most resilient businesses (a number of which we own).

S&U plc has been managed by the Coombs family for 80 years. In the last 14 years they have compounded book value per share at 12% whilst paying dividends worth a further 4%pa on average. Collectively the family own 43% of the company. We were delighted to have invested alongside them at a very advantageous price earlier in the year.

Another notable change in the last year has been a reduction in our US banking holdings. With the exception of our stake in Wells Fargo (which we have recently increased) we have now exited almost all other US bank holdings. While we still see this sector as undervalued vs. the rest of the US stock market, the mispricing is not as great as it once was and we think the comparable prices offered for Lloyds and RBS in recent months made them better investments. Both of these companies trade at or below tangible book values at the time of writing, JP Morgan by comparison now trades (at a justified) 2x tangible book. The other factor that played a big role in this decision to switch some of our US banking exposure to UK exposures was the depressed level of Sterling.

The Sterling/Dollar exchange rate is something we have reflected on a lot during the year. Clearly as Sterling falls the translation value of our Dollar investments rises. But the inverse will also be true. We are sanguine about the real impact of Brexit (in whatever form it arrives) on the UK economy and thus hope to profit from others realisation that the domestic economic damage will not be as great as expected. However it would be annoying to lose some of that upside were a stronger Sterling to impact the translation values of our US Dollar holdings. The result of this refection is that in early October 2019 we purchased a call option on £/$ at a very advantageous price. At the time of writing this covers approximately 55% of our US Dollar holdings by value and should ensure that any strong £ rally will have a reduced impact on our NAV. Were £ to fall further post a no-deal Brexit event (now looking less likely) we may well purchase further insurance. However as the hedging we have is in the form of a March 2020 Call option most improvements in Fund values from a lower £ would flow through to the NAV. As a general rule we do not undertake such hedging but we felt this was a short unusual window that could see a sharp change in sentiment towards our pricing currency.

The portfolio today is 42% invested in US Dollar assets (vs. 53% this time last year) and 27% in Sterling and 17% in Euro priced investments respectfully. Our factsheet that accompanies this letter shows our largest investments and collectively these account for 68% of the Fund’s value. It may interest investors to know that the next 7 investments account for a further 19%. As a result 20 investments make up 87% of our NAV.

Against US stock markets that trade at near all-time highs it is logical for investors to perhaps have some caution towards equity investment. However a glance at our holdings hopefully shows that most of our favoured shares have very different profiles to the overall market. The polarised nature of equity investing in recent years has meant we have underperformed US markets (but performed in line with UK indices). This environment has also thrown up some unusual bargains which we are delighted to have been able to purchase. We believe this collection of companies to have resilient growth potential that should be able to compound investor capital at high rates for many years to come. As others are overpaying for what they see as predicable growth many other shares are being discarded. This creates a wonderful environment for the patient value orientated investor.

Thanking you for your ongoing support.

With kind regards,

Andrew Hollingworth, Fund Manager

Tuesday, 22nd October 2019

Disclaimer: The information in this document is based upon the opinions of Holland Advisors London Limited and should not be viewed as indicating any guarantee of returns from any of the firm’s investments or services. The document is not an offer or recommendation in a jurisdiction in which such an offer is not authorised or to any person to whom it is unlawful to make such an offer. The information in this Report has no regard to the specific investment objectives, financial situation or particular needs of any specific recipient and is published solely for informational purposes and is not to be construed as a solicitation or an offer to buy or sell any securities or related financial instruments. In the absence of detailed information about you, your circumstances or your investment portfolio, the information does not in any way constitute investment advice. Potential investors should refer to the relevant Prospectus and Key Information Investor Document for full information. If you have any doubt about any of the information presented, you should obtain financial advice. Past performance is not necessarily a guide to future performance, the value of an investments and any income from them can go down as well as up and can fluctuate in response to changes in currency exchange rates, your capital is at risk and you may not get back the original amount invested. Any opinions expressed in this Report are subject to change without notice. Portfolio holdings are subject to change and the information contained in this document regarding specific securities should not be construed as a recommendation or offer to buy or sell any securities referred to. The information provided is “as is” without any express or implied warranty of any kind including warranties of merchantability, non-infringement of intellectual property, or fitness for any purpose. Because some jurisdictions prohibit the exclusion or limitation of liability for consequential or incidental damages, the above limitation may not apply to you. Users are therefore warned not to rely exclusively on the comments or conclusions within the Report but to carry out their own due diligence before making their own decisions. Authorised and regulated by the Financial Conduct Authority (UK), registration number 538932. All rights reserved. No part of this Report may be reproduced or distributed in any manner without the written permission of Holland Advisors London Limited. Investment Manager: Holland Advisors London Limited (registered number 538932), registered office 7 York Road, Woking, Surrey, GU22 7XH.


Related Posts

Holland_logo_RGB Agree

Welcome to Holland Advisors

By continuing to use this website you:
Terms and Conditions
Privacy Notice


Please confirm the following

Please confirm that you have read and understood the following terms of use of this website


The content of this website has been prepared by Holland Advisors (London) Ltd on the basis of information and sources believed to be reliable.

Under no circumstances should any part of this website be construed as an offering or solicitation of an offer for any investment in the products on this site Holland Advisors (London) Limited is authorised and regulated by the Financial Conduct Authority (FRN 538932).

1. Not for U.S. Persons
The provision of the information in this web site does not constitute an offer of securities to any person in the United States or to any U.S. Person as such term is defined under the Securities Act of 1933, as amended. The information contained in this site about Holland Advisors (London) Ltd is not directed to any person in the United States. Funds referred to herein are neither registered under the Securities Act 1933 of the USA, nor are they registered under the Investment Company Act of 1940. Consequently, they cannot be offered for sale or be sold in the USA, its territories, possessions or protectorates under its jurisdiction, nor to nationals, citizens or residents in any of those areas.

No investments or services mentioned on this website are directed at US Persons who are not Eligible Counterparties as defined by the UK Financial Conduct Authority (FCA) Handbook or Qualified Purchasers as defined under the Investment Company Act of 1940. The information contained herein does not constitute a distribution, an offer to sell or the solicitation of an offer to buy any securities in any jurisdiction in which such distribution or offer is not authorised.

2. Terms and Conditions of Use



3. Information on the Website
Except where stated otherwise, the information, content and services on this Website (the “Information”) are provided by Holland Advisors (London) Ltd (referred to as “we” and “us”) as at the date indicated on the relevant material.

The Information is provided for personal use and information purposes only. The Information does not take account of the investment objectives, financial situation and particular needs of any particular person and is not general advice to any class of persons. Therefore, you should not rely on the Information and should obtain relevant and specific professional advice in making any investment decision.

Furthermore, nothing on this Website constitutes or should be construed to constitute
(i) an offer, advice, invitation or solicitation from us or our affiliates to buy or sell any investments or securities, futures, options or other financial instruments;
(ii) an invitation or inducement to engage in investment activity or a financial promotion of any kind; or
(iii) investment advice or recommendation.

4. Stock exchange prices and exchange rates
The prices/values shown on this Website in relation to different underlying securities are based on the prices notified to Holland Advisors (London) Ltd as the last sale price of the relevant securities on the stock exchange on which they are traded as at the time and date shown. Those figures may vary throughout the course of, and between, stock exchange trading days, market trading times and business days in general. Holland Advisors (London) Ltd has not verified the figures with the relevant stock exchange and you should verify the accuracy of those figures separately before relying on them.

5. Permitted users of the Website
The laws and regulations of the country from which you access this Website may include restrictions on the distribution of the Information. This Website is not directed at or intended for distribution to or use by any person or entity in any jurisdiction where (by reason of that jurisdiction’s applicable securities laws, person’s nationality, residence or otherwise) such distribution, publication, availability or use of this Website or any part of its contents would be contrary to applicable law or regulation or would subject Holland Advisors (London) Ltd to any registration or licensing requirement within such jurisdiction. If you are such a person or entity, you are not authorised to enter the Website. It is your responsibility to ensure that your use of this Website complies with any restrictions or any applicable local laws regarding use of the Information on this Website. Persons or entities in respect of whom such restrictions apply must not access the relevant pages on this Website.

The Information displayed on this Website contains material that may be interpreted by the relevant authorities in the country where you are viewing this Website as a financial promotion or an offer to purchase securities. Accordingly, if you reside in any such country or fall within the scope of any law that seeks to regulate financial promotions in the country of your residence or in the country in which you are viewing this Website, please cease accessing or using this Website immediately.

If you are uncertain about your position under the laws of the country in which you are viewing this Website, then you should seek clarification by obtaining legal advice from a lawyer practicing in the country of your residence or in the country in which you are viewing this Website before accessing this Website.

You may not use any part of the material or Information on this Website to establish, maintain or provide or assist in establishing, maintaining or providing a stock market for trading in securities.

6. Investment Performance and Accuracy of Information
The Site contains material about the past performance of our Funds. The value of an investment in a Fund may go up as well down so that an investor’s investment in a Fund, when redeemed, may be more or less than the original investment amount. By its nature, investment in a Fund managed by Holland Advisors (London) Ltd is only suitable for sophisticated investors who do not require immediate liquidity for their investment, for whom an investment in a Fund does not constitute a complete investment programme and who fully understand and are willing to assume the high risk involved in the investment programme of a Fund. THE PAST PERFORMANCE OF ANY INVESTMENT, INVESTMENT STRATEGY OR INVESTMENT STYLE IS NOT INDICATIVE OF FUTURE PERFORMANCE.

Whilst the information contained on the Website has been given in good faith and every effort has been made to ensure its accuracy, the Information may not be complete or accurate for your purposes. This Website and the Information is provided on an “as is” basis and Holland Advisors (London) Ltd may not, and has no obligation to, update the Information or correct any inaccuracy which subsequently becomes apparent. The Information and/or opinions and estimates comprised in the Information may be changed or withdrawn without notice and may become outdated. You, therefore, should verify any information or other material obtained from this Website before you use it.



The Information is assembled from material prepared by Holland Advisors (London Ltd) or its agents but may not include Information made known to Holland Advisors (London) Ltd officers (or agents) subsequent to the date of publication of the Information indicated on the Website. If you use the Information, you do so at your own risk. Please recognise that the previous performance of securities or other instruments does not guarantee or predict future performance.

7. Exclusion of liability



8. Third Party Websites
We may provide, on our Website, links to websites operated by third parties as a convenience to you. If you use these other sites, you will leave this Website. If you decide to visit any linked site, you do so at your own risk and it is your responsibility to take all protective measures to guard against viruses or other destructive elements.

Holland Advisors (London) Ltd makes no representations, warranties or guarantees of any kind about any of the content of any other website which you may access by hypertext link through this Website. When you access any other website by means of a link from this Website, you should understand that your access to that other website is independent of Holland Advisors (London) Ltd and Holland Advisors (London) Ltd has no control over the content of the website, nor does Holland Advisors (London) Ltd in any way endorse or approve the content of that website. In no event will Holland Advisors (London) Ltd in any way be liable to you or any other person(s) or organisation(s) for loss or damage (whether direct, indirect, consequential, special or other) for any use of any site linked to it by means of hypertext or otherwise.

9. Indemnity
You agree to indemnify Holland Advisors (London) Ltd and its officers from and against any claim brought by third parties against Holland Advisors (London) Ltd and its officers as a consequence of your breach of the Terms of Use. Furthermore, if your use of this Website results in the need for servicing, repair or correction of equipment, software or data, you assume all costs thereof.

10. Intellectual Property Rights and Licence
The copyright, trade mark or any other intellectual property rights in the Website and the Information are owned by or licensed to Holland Advisors (London) Ltd. You may download or print out a hard copy of individual pages and/or sections of this Website provided you do not remove any copyright or other proprietary notices. Any downloading or other copying from this Website will not transfer title to any software or material to you. You may not reproduce (in whole or in part), transmit (by electronic means or otherwise), modify, link to or use for any public or commercial purpose this Website without the prior written permission of Holland Advisors (London) Ltd. Any rights not expressly granted in the Terms of Use are reserved.

11. Operation of the Website
You should be aware that the internet, being an open network, is not secure. If you choose to send any electronic communications by means of this Website, you do so at your own risk. Holland Advisors (London) Ltd cannot guarantee that such communications will not be intercepted or changed or that they will reach the intended recipient safely.

12. Privacy
Any personal data relating to you will be collected, used and recorded by us in accordance with current data protection legislation, the Terms of Use and our Privacy Policy. You must read our Privacy Policy as it forms part of the Terms of Use.

13. Governing law
The Terms of Use are governed by the laws of England and Wales and the courts of England and Wales will have exclusive jurisdiction over any disputes arising under them.

14. Waiver
If you breach the Terms of Use and we take no action, we will still be entitled to use our rights and remedies in any other situation where you breach the Terms of Use.

15. Our details
This website is owned and operated by Holland Advisors London Ltd. You can contact us at: Holland Advisors London Ltd, The Granary, 1 Waverley Lane, Farnham, Surrey, GU9 8BB.

Updated and effective as of  31st March 2021


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.

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 7 York Road, Woking, Surrey, GU22 7XH.



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

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


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

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

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.