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Mar 2020: Ryanair – The ‘Perfect Storm’ + Peak fear

March 15, 2020

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Ryanair, EasyJet, Ashtead, JDW, Booking[1]– The ‘Perfect’ Storm + Peak Fear

Mar 2020

“you make most of your money in a bear market, you just don’t realise it at the time” – anon

This research piece is in part to help our clients think about what stocks to buy and when, it is also intended to reflect on our bullish stance on the EU low cost carriers (Ryanair and EasyJet). It does however contain many other ideas on other stocks and sectors, so please don’t stop reading yet!

Imagine sitting down with Michael O’Leary for a drink at Christmas 2019. As the conversation rolled on you found yourself discussing the pivotal moment in Ryanair’s history when Ryanair put in the mega order for deeply discounted Boeing planes post 9/11. It seemed obvious segue to ask “Michael, if you could imagine another scenario where things got really tough for the sector but ultimately – again – worked massively in your advantage what might that look like?” O’Leary we surmise might have said something along the following lines[2]:

  • “Well we would need a black swan, a really monumental shock to demand that would expose and wash out all those poorly capitalised competitors of ours
  • The shock would be global so that the demand hit is global and thus impede the usual geographic capacity arbitrage
  • And it would be preferable if something happened that was severe enough to not only cause some short term disruption, but also to linger in the memory so that anyone following in competitor footsteps would think twice before setting up a new airline
  • It needs to be something that is not about airline safety, so that when the event passes all will want to travel fully again
  • And in a perfect world it would be great if all those guys we buy these new more efficient aircraft from get squeezed so we can get some really great capacity deals
  • Oh, and while you are at it. Let’s have a collapse in our largest single cost item – fuel”
O’Leary’s Perfect Storm

So, this is where we find ourselves today – in what we imagine might be Michael O’Leary’s perfect storm. Indulge us here a little more – maybe we could extend the analogy from the film of the same name. Imagine that you are part of a fishing group of 20 trawlers based in an isolated fishing area. You have the best, biggest, safest boat and one day a truly enormous, once in 50 year storm comes through. One that is big enough to wreck all of your competitor boats and leave just you and one or two others with sea-strong vessels intact. For months and years after this period the fishing will be easy and plentiful due to less competition. However, as you tossed and turned in a force 9 gale for a week how did it feel at that time? The honest answer would have to be “truly awful”.

We surmise that today’s confluence of events (Covid-19 + oil price collapse + poor policy response) are the airline industries (and indeed more than a few others’) perfect storm.

When we are assessing the opportunities in front of us today, we can say that it is ‘most likely’ that surviving industry players who were positioned appropriately to survive such an event will make some super normal profits once it is over. However, that does not mean things do not feel truly awful now and that day by day the news coming out of such companies and industries is not going to get worse.

Are we at peak fear? – Sentiment reflections

There is an old saying that if your neighbour loses his job that is a ‘recession’, if you lose yours it is a ‘depression’. This mentality we think has been prevalent as this crisis has spread. Simply put, too few have taken it seriously enough until it is outside their door. As we have been studying this virus for >6 weeks (see Twitter link at end of note) now we have noticed a few common traits that we think it fair to observe:

  • Western stock markets were slow (really slow) to pay enough attention to this virus even when it had clearly made its way to countries like Italy. (NB: That Monday evening of 24th February, Carnival shares closed in New York at $36. Today they are $22). Now, we accept, markets are trying hard to catch up.
  • There has been the recession vs. depression mentality visible in Western populations. Too many young Italians were still socialising a week ago and too many Brits believe that a ‘stiff upper lip’ might solve the problem. Additionally, far too many Americans (one in particular) were totally under estimating the real threat of the whole situation and thus have not prepared suitably for it.
  • Those countries that have stopped the virus spreading best are those that were the most draconian in the measures they enacted (huge testing/use of red/green apps/city lockdowns). Western countries had a chance to learn from these experiences but rather than do so some have instead presented these as the acts of totalitarian regimes with an alternative agenda!

Maybe SARS and MERS viruses and the fact they did not spread so widely play a part here. In the West’s eyes they were the boy that cried wolf twice? Now we open our door and Mr Wolf is standing right there.

The tide is turning

We would suggest some Western politicians were very much like Mr Market, slow to take the issue seriously enough and now trying to catch up fast.

As country by country in Europe the penny drops a new mentality kicks in. i.e. those that were telling all a few weeks ago this will not be a big deal will soon shout from the roof tops about how it is affecting them, without any irony. (See CNBC anchors for this full 180-degree view change in only 3 weeks).

Sadly, it is exactly this too relaxed Western mentality that has perhaps helped this virus spread. Time and time again the WHO team who visited China and South Korea have praised the response they saw. Seemingly too many in the West are too busy criticising to take the important lessons they could from such early responder experiences. Even as we type the US President is making unplanned actions designed to point blame at other countries rather than focusing on the real threat and preparing, as the US should have done weeks ago.

Peak fear?

In almost all scenarios we come across as investors, we should focus on the intrinsic value offered to us in a share and act to buy it if we think we are being offered a bargain price against that value. However as is the case in a prolonged bear market, investors only get so many cash bullets to fire so they do not want to waste them. This bear market/correction might not end up being prolonged but it is starting to offer us once in a generation pricing of some shares that normally only long downturns come with. So, whilst timing is clearly difficult it is worth us pausing before buying the first cheap stock we see.

Maybe in the UK we sit in an advantageous position as investors as we have been able to look both East and West. Whilst it was hard to envisage the extent of what scale of impact the virus might bring from Asia to Europe, we can now more clearly experience the pain closer to home and see that:

  1. The now high likelihood of further closures of many EU national economies as we have seen in Italy
  2. The real change of attitudes all around us in the wider population as views change from cynical of the virus’ importance to panic about how it will affect daily lives

In the same way that the US is behind Europe in the spread of virus cases it is perhaps also behind in both the policy response (UK having gone first, courtesy of the budget). Also, in the changing sentiment of its population which is perhaps still lagging behind that currently being experienced in Italy and soon likely wider Europe.

Looking for the whites of the eyes

For analysts that mostly look to find undervalued great companies this is all very crystal ball gazing stuff. When trying to decide when you buy the businesses you have identified as already mispriced vs. longer term intrinsic values a great time is likely to be when the markets, they operate in have just been engulfed in a tidal wave. ‘Peak Fear’ if you like.

Earlier this week we wrote on the value being offered in Jardine Strategic. In doing so we suggested its value was in a relatively steady state as the tidal wave of Hong Kong protests and Covid-19 was at least past its peak. Events in Europe and US are progressing at speed suggesting that the moment of peak fear is perhaps near. However, whilst poor leadership and inadequate policy responses (to the virus and its threat) in some countries may have consequences, Mr Market is reacting to these too.

Additionally, each of us as investor’s will seemingly quite soon be forced to confront fear in our daily lives that comes from worrying about our parents/grandparents or even our own health. As such it is highly likely that we will bring some of that fear into our work decisions. That will be as true in New York as it is in Milan or London and we should be mindful of this tendency as it can lead us to make poor decisions.

What we are looking to buy

Each portfolio manager amongst us will have a list of pet shares they are looking to buy. Our list is getting longer by the day but for now we will include Ryanair, EasyJet, JD Weatherspoon, Booking.com and Ashtead. Some of these we have written on extensively, others we have not had the chance to do so yet, nor might we get chance before the optimum moment for purchase arrives. However, each of these companies:

  • We feel we know either well or very well
  • We have spent a good amount of time studying their past compounding and modelling their most likely future
  • We think each most likely offers investor’s excellent long-term IRRs (c.20% or more) if purchased near today’s share prices
First and Second order thinking

This is not really a time for naval gazing but we think it is right to remind ourselves of why some business outcomes might be more powerful than others.

Fig.1: A banquet of consequences!

 Source: Farnam St Blog

Returning to our thinking on airlines, the damage currently being inflicted on the global airline sector is consistent with that of a first order negative effects. For those airlines that have the resilience to survive they are surely examples of exactly what we outline above, i.e. where a negative first order effect is then followed by a positive second or third order one. Ryanair, SouthWest and most likely EasyJet, IAG and Delta will be surviving entities in this (soon to be consolidated) sector.

We think the travel, leisure and related sectors have within it some wonderful investment franchises that we expect will compound their intrinsic value per share at high rates for many years into the future. This is in part due to growth that will one day (hopefully soon) return, but also due to the likely strengthened market positions these businesses will then have. Investor IRR’s on the equity of those companies purchased around this time we think will be excellent (>20%pa). Our best compounding ideas in this area would be Ryanair and Booking.com. But we also have great enthusiasm for the other airlines mentioned. Whether yesterday, today or tomorrow represents the peak fear of these companies we cannot tell, but we feel we are much closer to it today than we were only a week ago.

Modelling Ryanair for some amazing prospective IRRs

For Ryanair watchers we attach a copy of our long-standing model for it. When we started using it we took the shortcut to look at what 2022 or 2024 profitability might look like without realising how helpful it might be to not try to forecast the periods in between! During the three years we have used this model fares have generally trended lower as new capacity additions were filled and fuel costs have been volatile.

Today we assess the likelihood of the stronger fare period in 2022 or 2024 as just as likely (if not more so) than in all our previous studies. The tabs in the model show two scenarios, both have oil assumed to cost $50 a barrel as a constant (our past work always assumed it at $80). The first tab assumes fares in 2022 average €40 (up from €37 currently). The second assumes fares at €45.

We remind readers that these figures are way, way, below what our discussion with Michael O’Leary suggested to us as the likely end pricing environment for a consolidated industry. The prospective IRRs that these modest assumptions throw out are pretty startling (30-40%pa) when the starting share price is €10-€11.

Missed second order thinking

For all the degree of caution we entered recent weeks with in relation to how the virus might affect sectors like travel and leisure we were completely blindsided by another second order effect. That being the knock-on effect that has occurred to the banking and financial industry valuations as a result of the equity market discounting lower for longer interest rates. Our past positivity in this sector has focused around the very strongest franchises that we think have been undervalued by Mr Market. If you have not listened to us on this sector up to now, then ‘well done’ for today RBS, Lloyds and Wells Fargo trade in most cases at significant discounts to their tangible book values. To state that we think they are cheap is obvious, but also suggests we do not see how hard making money in this sector at such low interest rates will be. We do concede this seemingly new fact of life and realise that a future that looks somewhat Japanese in interest rates and banking profitability is indeed possible.

That said maybe the policy responses we are seeing in countries like the UK will lead bond markets to change their thinking. Also, we think those either invested here or tempted to be should start to ask themselves other questions about these company’s business models. Today a great deal of us bank for free. Might that need to change if the largest banks in our country are discounting making ROTE of c.5-7% even from c.30% market share positions? Similarly, the share price of Charles Schwab discounts a similar scenario. With so few credible competitors left (we note the multiple Robin Hood system crashes this week) might it not be credible to bring in slightly greater custody fees charged to clients? Are these ideas clutching at straws? Short term it feels that way. Longer term if huge numbers of people (current account holders or investors) are getting truly wonderful deals from these super scale businesses maybe they could be charged just a little for the privilege.

Arbitrage opportunities + spokes in the flywheel

In a recent piece on Berkshire highlighting its value we noted the arbitrage opportunity that is presented to some companies in a world of super low interest rates. (See link below to Berkshire raising 5 year money at 0%!). These need to be businesses with end markets that are largely stable in their cash flow generation and/or have strong asset backing, with a strong market positions also. This is where the availability of credit and its prudent use can make the difference between low-ish ROICs (7-12%) and higher ROTE (15-30%) returns. A company we feel strongly is in a great position to benefit from this is J D Wetherspoons. Right now, Mr Market is digesting the fact that very very few people will be going to its pubs in the next few weeks but the long-term dominance of its industry position that we have written about many times remains intact and deeply attractive we suggest (model available on request).

https://www.sec.gov/Archives/edgar/data/1067983/000119312520064645/d853116d424b5.htm

Another company we have been looking at in detail in 2020 is Ashtead. We found a very similar compounding model in its business also, where it is using a number of levers to both consolidate its industry and profit from its continuing growth using its scale cleverly to do so. What Ashtead also does like Wetherspoon is use debt prudently to enable a faster rate of growth in compounding to be achieved. With the shares down c.30% since January they look attractive to us also.

The new ‘New Deal’

When deciding to buy into such companies however we need to be mindful of not just short-term trading hits, but also how their business models are affected by changing events. Indeed, our whole attraction to flywheel businesses goes slightly into reverse when an event like this occurs. E.g. Why does JDW make a good return on Tangible Equity selling beer at a fraction of the price that others do? The answer is because it attracts high volumes of people. Why does Ashtead have an advantage over its peers? Largely due to the scale of its depot and fleet network offering the good throughput these depots get. For a period of time we are likely to see such operational gearing in such companies work in reverse. Additional to which whilst these companies do not have levels of debts that we would assess as high in almost all outcomes, they do still have leverage. That in JDW’s case its debt has a longer-term maturity and has now been fixed at low rates we find very reassuring. Other investors may see it differently however, when the warnings on customer throughput surely come. We need to be ready to act to buy such wonderful companies at wonderful prices assuming we have judged them fit for survivable in all market scenarios.

NB. As we write today the UK market enjoys another rout but one small cap is resilient, VP Plc, one of Ashtead’s UK peers. Likely it is responding to yesterday’s enormous new infrastructure spending announced by Government. We remain of the view that these types of polices were always coming from this UK Government, but maybe they just got bigger and more urgent. As for the US policy response, well we would expect something similarly large that takes advantage of such uber low interest rates to boost infrastructure spending. With companies like Ashtead marketed down so aggressively it could soon be a wonderful opportunity to buy them.

The good thing about these arbitrage ideas rather than the banking type ones is that they just need a return to some semblance of order, they do not need higher interest rates or changes in business models. In closing we will share with you a comment an older investment strategist shared with us years ago in a similar moment of market turmoil.

“markets stop panicking when policy makers start panicking”. Anon

Were that adage to be true it would suggest there is hope that at least in investment circles things might be reaching a nadir.

Good luck – keep well.

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.

Disclaimer

This document does not consist of investment research as it has not been prepared in accordance with UK legal requirements designed to promote the independence of investment research. Therefore even if it contains a research recommendation it should be treated as a marketing communication and as such will be fair, clear and not misleading in line with Financial Conduct Authority rules. Holland Advisors is authorised and regulated by the Financial Conduct Authority. This presentation is intended for institutional investors and high net worth experienced investors who understand the risks involved with the investment being promoted within this document. This communication should not be distributed to anyone other than the intended recipients and should not be relied upon by retail clients (as defined by Financial Conduct Authority). This communication is being supplied to you solely for your information and may not be reproduced, re-distributed or passed to any other person or published in whole or in part for any purpose. This communication is provided for information purposes only and should not be regarded as an offer or solicitation to buy or sell any security or other financial instrument. Any opinions cited in this communication are subject to change without notice. This communication is not a personal recommendation to you. Holland Advisors takes all reasonable care to ensure that the information is accurate and complete; however no warranty, representation, or undertaking is given that it is free from inaccuracies or omissions. This communication is based on and contains 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 this communication may have been disclosed to the issuer(s) prior to dissemination in order to verify its 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 investment discussed in this communication 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 this investment given your financial objectives, resources and risk appetite, please contact your financial advisor before taking any further action. This document is for informational purposes only and should not be regarded as an offer or solicitation to buy the securities or other instruments mentioned in it. Holland Advisors and/or its officers, directors and employees may have or take positions in securities or derivatives mentioned in this document (or in any related investment) and may from time to time dispose of any such securities (or instrument). Holland Advisors manage conflicts of interest in regard to this communication internally via their compliance procedures.

  1. Share Prices (respectively) €10.70, 872p, 1751p, 1062p, US$1442 ↑
  2. This is obviously a fictional account from our imaginations and do not want to diminish, belittle or ignore the awful human suffering and tragedy ongoing with this virus globally. That said, our job is economic forecasters and business valuers and such exercises help frame events for us and readers. ↑

 

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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.

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