Apr 2020: Aena – Toll roads for 50 cents

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Aena – Toll roads for 50 cents

Apr 2020 (€112)

 

“The time to buy a road toll is when there is no one using it”

We feel no need to explain the toll-road business model or its attraction as an investment. Collecting money, as a monopolist with very little daily effort, is as close to a ‘money tree’ as we are ever likely to find. The attraction of this model means that many such companies are almost always highly valued due to their predictable growth and prodigious cash generation…almost always. One of your authors was analysing airports, and their road toll characteristics, a mere 25years ago; We conclude in this piece that in the last two and half decades there has never been a better time to buy shares in an airport operator than in 2020. You can put us down as buyers of them all, but our focus and preferred picks are Spain’s Aena and China’s Beijing Capital International Airport (BCIA).

What did you do yesterday?

Last week we took a break from balance sheet stress testing and daily Government briefings to read the annual report of Aena (monopoly owner of all airports in Spain and the Balearics). After that we poured ourselves a strong coffee and read DORA. For those of you stuck at home with young children this is not a story about an adventurous 7-year-old with a backpack, but the regulatory accounts/regime of Aena for the period 2017-2021. As with all regulated companies this is an area critical to understand. We will not yet claim to be Aena regulatory experts, but we like much of what we found and see the shares as very cheap. In addition, we have been looking again at Beijing Capital International Airport (BCIA) adding to the knowledge we started building in a piece published in May 2018 (re-attached). Those of you that look for super cheap, hard assets will love Beijing Airport.

Aena – Reach for bucket not a thimble

For these that know what they seek, this is, to paraphrase Buffett ‘a time for buckets not thimbles’. It is also a time to focus on the analysis needed to assess a company rather than the long-hand write ups. As such we have studied a number of documents related to Aena airports. These we have marked up, highlighting the most relevant areas we think investors should be focused on (see attached). We highlight below the impressive combination of factors that we are pleased to have found in Aena. We then expand a little on regulation.

In Summary, Aena:

  • owns all the airports in Spain and on the Balearic islands, so it and its regulator can have a sensible joined up way to think about future planning for capital and expansion on a national scale
  • carries c.275m passengers annually
  • makes high EBITDA Margins (c.65%)
  • has high Free Cash generation
  • has low leverage (2.3 x EBITDA) vs. airport peers – many of which have 5x leverage
  • has the lowest landing fees in Europe (by a wide margin)
  • and the lowest operating costs per passenger (also by a wide margin)
  • unlike many other airports in Europe, Aena is not overly reliant on one airline group such as say Swiss or Lufthansa
    • It also has a high exposure to those airlines that are likely to emerge intact and will be strong growers post the Covid-19 crisis (Ryanair, IAG and EasyJet)
    • 158m of its passengers are from low cost carriers (LCC’s)
  • is also well positioned in two regards:
    • Spain is a country that attracts the second highest number of visitors globally
    • Spain is also positioned in a geographically advantageous location – i.e. it is a natural westerly transit point for travellers to either North or South America.
  • has a sensible and favourable regulatory framework under which it operates
  • …and in 2018/9 had an 80% dividend pay-out ratio (current dividend yield = 6.8%)

Prior to Covid-19, Aena shares (when changing hands for €170) traded on an undemanding 11x EV/EBITDA and a PE of 17x. Today at €112 these multiples are 8x and 11x respectively.

Traffic and economic growth

In addition to this note is a variety of documents that will aide readers understanding of this company and the airport industry.

Separately from these there is significant data on this industry (i.e. airlines and airport travel) made available by IATA. If we chose to super-simplify the main findings of almost all IATA studies for the last 30 years, the consistent conclusions would be:

  1. That any major set-back that has ever occurred which has significantly reduced global air travel (recessions, 9/11 attacks, Icelandic ash cloud) have all been recovered from and in most cases quite quickly.
    1. See appendix chart showing US Airline travel pre and post September 11th attacks and 1990 gulf war
    2. Also reference our argument in our recent Perfect Storm research piece – today’s crisis is importantly not about the safeness of flying per se.

Fig.1: GDP vs. Traffic

  Source: DORA

2. That including these periods of severe disruption global airline travel has increased at a rate close to 2x GBP on average globally pa. This correlation is higher in developing countries and lower in developed ones, as the chart above shows. That said the overall correlation with a GDP Plus growth rate is very very well established over multiple decades that includes severe shocks to short term travel

Normalisation or traffic – In reality

In each of our (normal) daily lives we are able to see the truth of this data with us travelling more as our disposable incomes have risen and the cost of air transport has fallen. We can all accept that the world will experience an occasional crisis. But just as inevitable are the seasons that the world continues to enjoy and each of our own (and our children and grandchildren’s) desires to travel to sunnier climes or to enjoy better weather and wider experiences.

Whilst individual airlines and travel companies may fail there will (and has always been) others that take their place. The secular growth of air travel that the IATA data lays out over multiple decades does not occur because of one or two airlines or travel companies promote this growth. It occurs because the global population is growing and is becoming a little wealthier each year and has a little more disposal income. As such this is an industry where there is a constant and secular growth in demand for air travel. The airline suppliers of which may come and go according to the fortunes their operationally geared business models bring. But the airports, i.e. the toll roads these travellers pass through as this secular growth unfolds, remain the same. The only change is that the airports get busier, thus need to invest more in capacity. Also, this greater number of people spend more money whilst passing through these airports. Geographically well-located airports are thus beneficiaries of the secular growth in populations and the secular growth in consumer spending power.

The importance of ‘Dual Till’ regulation

Fully understanding the regulatory regime is crucial to investing in any regulated utility. Each utilities regulation varies slightly, and airports are no different. Simply put airports have aeronautical revenues (landing fees etc.) and retail revenues (Duty Free, bars and parking etc).

Airport Regulation can be ‘single till’ or ‘dual till.’ The former means that the profits the airport makes in its retail operations can be considered as a cross subsidy of the regulated activities of the company. The latter, ‘dual till’, means the two areas of income are looked at separately.

Fig.2: AENA is subject to a ‘Dual Till’ regulatory regime

Source: DORA

The above quote from Aena regulatory regime makes it very clear that Aena’s regulated revenues are designed to compensate the company for providing only its regulated activities. This is an important distinction as Aena earns profitable retail revenues that are thus kept by shareholders.

Our annotated copy of the DORA document is attached. In short, we would highlight:

  • Aena has regulatory asset base of c.€10.5bn
  • During the 2017-2022 period it is allowed to make a ROCE of 7% (pre-tax) on that RAB
  • This equates to €700m-€770m pa expected regulatory profits in the 2017-2022 period

However, two key point we would highlight further:

  1. This return is allowed after a deduction of c.€600m of depreciation/amortisation (non-cash)
  2. The group is required to spend c.€450m pa in capex over this period
  3. The regulatory outlook in 2017 used RAB/costs of capital growth and other projections to throw out the reduction in revenue per passenger Aena had to pass on during this 5-year period. In 2017-22 this was a reduction of 2.22% pa
Regulation summary

The simple way to look at the regulation of this group is that they are being allowed to make a 7% return on a €10.5bn capital base, i.e. €700-€750m. The pre-tax cash they would generate from this is: €730m + €600m – €450m = €880m (i.e. adding back depreciation and taking off capex).

There are adjustments due to future actual passenger growth which can mean the group exceeds such earnings, but for now we will leave our regulatory outline there.

The most important thing about Aena regulation is that it: a) gives the group complete certainty in the returns it will make on these regulated activates and b) under the ‘dual till’ method it leaves the balance of the business profits that are derived from its retail activities untouched. When the non-regulated part of your business generates €1.3bn of revenue and an 85% EBITDA margins that is quite an important assurance.

The blend

The result of these two activities assessed together produces the following:

  • Aena group EBITDA margin of 65%
  • Aena ROE in 2015-2019 of 22-23%

What is actually occurring here is the blend of two of Buffett’s favourite business models:

  • The Compounder: i.e. the utility part of the business that will in time spend more than depreciation, hence growing it RAB, but in doing so will receive a guaranteed return on that capital:
    • Whilst that return is only a 7% pre-tax level it should be remembered that this is at the capital employed level
    • The regulator does not stipulate the leverage that the company can chose to take or sustain, (currently it is 2.3x EBITDA and way below peer levels). Hence any ROE would result in a higher return than that reported at the ROCE/RAB line.
  • The Dream: The retail/duty free business is a growing asset-light business that is using the assets of the airport to operate. But the high demand for its services, whether conducted in house or outsourced, ensure that they are very profitable. Particularly in Aena’s case when a captive/spend hungry 275m people pass by their services on a 24/7 basis. We will not try to calculate a RoE for such a segment, but with low assets and EBITDA margins of 85% we feel pretty comfortable stating that it is likely =/>100%

But one could not exist without the other, hence as investors we are presented with the offer to invest in the blended business. Most simply put today you are being offered that blend of two businesses with secular growth and a guaranteed regulatory return earned from world class well-invested assets. But one with a dream, high growth high return business attached. The RoE that Aena reports at a group level is thus instructive of what is on offer (5-year average of 23%).

That investors in December were happy to pay 11x EBITDA and a PE of 17x for such a business we do not find surprising. But todays investors if they are prepared to buy the same business while it has almost no one passing through the toll road get it for a mere 11x PE.

A word on Covid-19 and ‘Time Arbitrage’

We have spent little of this report trying to quantify the effects of Covid-19. The attraction of assets of this nature during a crisis is their longevity and thus only limited damage will likely be done to the equity value of the business during even a protracted period of shut down.

This stems from two factors. The first is a prudent capital structure meaning that even if sizable losses were to amount these are affordable without any new equity being required. The second is the fact that the asset heavy and high margin nature of the business means that it is quite hard for it to be loss making for long. Aena’s pre-deprecation costs are only 18% of commercial revenues and only 44% of Aeronautical revenue. In addition, we know that c.25% of total costs are staff (many of which currently qualify for the Government furlough type schemes). A second significant cost will be utilities which can to an extent be managed with passenger throughput. Such a business would seem highly unlikely to make losses during a full financial year we suggest, even one as unusual as 2020. As such the capital structure, regulation and assets controlled by the group will be largely unchanged ahead of a 2021 traffic recovery.

If this 2020 vs. 2021 dichotomy represents a ‘Time-Arbitrage’, Aena arguably also has a longer- term time arbitrage opportunity too. Analysts keen to see it maximise its equity value occasionally ask management about the uses of the group’s balance sheet, i.e. can you lever up, as other airports have done to improve your equity return vs. your regulated one? Management’s answer to this is instructive. They realise (and admit) that they are not efficiently structured, but also highlight that due to the Spanish Government’s stake in the company there is no desire to make a re-levering move. The analyst’s response seems to be a shrug and a “move along – nothing to see here”. However, management then speaks to its ability to invest in a country like Brazil using its balance sheet to do so. This is allowed under its regulatory regime and in effect is the company using its under-leverage to grow a further revenue stream. Clearly it is important that this capital is invested wisely but so far; we are comforted by the focused approach they have taken to this expansion.

Beijing Capital Airport (694 HK): Find an even bigger bucket..?

Those wanting to understand our view on Beijing airport and a little background as to what is taking place in the airport capacity of this global city should first read our short piece published in May 2018. It is re-attached.

This airport is partly owned by the Chinese state but has been listed since 1999. Until this year it was the world’s second largest airport by passenger numbers with 100m passing through it each year (only Atlanta is bigger). Its share price has been falling for a number of years due to the 2019 opening of a new airport built in Beijing (Daxing airport) that is taking some of BCIA’s traffic away. This was all known and underway well before Coronavirus hit.

Before stating our view that this could be a significantly undervalued asset, we acknowledge the points of risk:

  • That the regulatory framework surrounding this company is much less clear than say for Aena
  • That central planning for future required infrastructure will be considered by the Chinese state far more important than BCIA’s shorter term profitability we will take as given
The ‘bull’ case on BCIA

We have done a lot of reading on and around this company but will just give the bare bones of why this might be an outstanding investment. Those that want to know more can discuss it with us:

  • Today BCIA has almost no gearing, a very unusual state for a global airport company
  • Even without gearing it equity only valuation is super cheap
    • It trades at an EV/BITDA of 4.2x the profits it made in December 2018
    • It trades at an PE of 7.5x the profits it made in December 2018

In December 2018 BCIA had 100m passengers. As 2020 evolves some 30-40% of those passengers are being moved to the new Daxing airport thus reducing BCIA’s profits. However, as we observed in our original note a few interesting more favourable trends will then start to occur:

  • BCIA is closer to the city centre than the new airport. It will thus most likely remain the main hub for international and business traffic (and crucially, Air China the flag carrier is remaining and expanding its base at BCIA)
  • The capacity of both airports in now such that Beijing’s wider travel market can now grow again as both airports have capacity
    • Indeed, late last year Beijing doubled its it traffic capacity with immediate effect. This was logical and always likely to us, but it came as a relief to some who were worried (illogically we suggest) that the two airports would compete for existing slots
  • BCIA will then be in the enviable position of having a capacity of >100m but throughput of maybe only 60m
    • As a result, many years of coming organic growth will come at minimal incremental capital cost
    • With airports having significant deprecation charges this creates a period where the groups cashflow will be way in excess of reported profits
  • Additionally, the retail spending opportunity at BCIA is huge:
    • In the past the airport has been underdeveloped in its retail offering
    • But development in recent years have seen it make much greater investment
    • This has resulted in far more favourable contracts (announced in 2018) with Duty Free providers
Strong GDP growth – the perfect hill for an airport snowball

Fig.1 earlier showed IATA traffic growth correlated with country GDP growth. Unsurprisingly this suggests that air transport growth in China will grow at a high rate for many years into the future. Just a ratio of 2x GDP might yield a 10% pa growth rate. At such a prevailing rate an airport that in 2020 carried say 65m passengers would in 4-5 years once again be transporting 100m passengers. However, at the same time as this nominal passenger number growth each of those passengers will have far greater spending power. Unsurprisingly the airport is now aggressively developing its retail offering to take advantage of this coming demand. This comes on top of the starting fact that Chinese travellers are already the biggest global spenders when it comes to travel and duty-free purchasing. All this has not been lost on the Chinese state as it has resulted in them looking at ways to bring more of that spending back to China rather than it occurring elsewhere in the world.

Our work on Aena and other airports is interesting to use as a yardstick. Aena has a blended (i.e. regulated and retail) EBITDA margin of 65%. In the December 2018 figures for Beijing Airport we used above BCIA made an EBITDA margin of c.48%.

Roughly right will do: A 3-5x bagger?

For now, we will make do with a guesstimate as to the future earnings power of this businesses. That guess is for a future when 100m passengers (maybe in the year 2025 or 2026) will once again pass through Beijing Capital Airport. They will generate more revenue (say 30%) than they did in 2018. Also, that such activities will be more profitable producing a margin of say 60% rather than the past 48%.

If so, such an assumption would result in an EBITDA of c.$1,325m. We remind readers that today’s EV of BCIA (all equity) is US$3,512m at a price of HKD5.4 per share.

For those that want to salivate on the sort of upside such a starting point could result in we attach in the appendix a summary valuation sheet showing the multiples that many airports operators globally trade at, both today and pre-Covid-19. Most peers are way above the starting price of 11x we observed for AENA in December 2019.

What to do with all that money?

BCIA controls a huge airport asset that likely has a replacement cost of >3x its current market cap. It is poised for profitable cash generative growth and will need little investment to facilitate that growth. Oh! and it has no debt. So, what to do with that abundance of riches if we are right and the cash starts to pour in. Some will ask for a dividend bonanza. We note that for the last 20 years this company has paid out 40% of its profits in dividends. Those with a more cynical/defeatist bent will assume the Chinese state will just steal it all.

We would bring to the attention of investors an RNS released by the company on June 28th 2018. It stated that BCIA has a long-term option to purchase Daxing Airport (price unknown). At this point we should point out that Daxing was built and is operated by the parent state-controlled company that owns the 45% stake in BCIA. Also, this parent company has in the past sold assets down to BCIA, some we believe at cost.

Depending on your point of view this is either state control to a point you cannot tolerate or a clever way to use public money and planning to build (in only 5 years) an asset that a country needed. Then ensuring that such an asset is run by the right entity long term. The role model for this is clearly the Three Gorges Dam project that was government planned and built but then bought (at a fair price most seem to agree) by China Yangtze Power. With recovered traffic and profitability BCIA would be in a strong enough position to make a purchase of Daxing a decade from now.

When considering BCIA’s intrinsic value it is worth knowing the news that Daxing airport with a current capacity of c.45m passengers is said to have cost $15-25bn. We repeat the sign off from our 2018 assessment of BCIA (Current EV $3.5bn): “Sam Zell – where are you?”

The future of capital allocation at BCIA might not be clear, but crucially it might not be anything like as bad as today depressed equity valuation discounts.

Rarity values + Toll Roads

The world loves predictable cash flows. As such franchises, utilities and REITs that are seen as secure longer term are priced keenly off of ever lower bond yields. Airports offer much of these predictable traits also. As such they are often priced keenly too, but not all airports, all the time. Maybe this is due to the fact that this is not a well-known subsector in the US, or maybe it is due to the differing approaches to RAB regulation meaning that great local/regulatory knowledge is required to invest.

Whatever the reason, we know a toll bridge when we see one. 11x EV/BITDA and 17x PE is either a fair price to pay for such a stream of regulated but growing cashflows or a cheap one depending on your interest rate outlook and the price you will pay for stable cash flows. What this level of valuation is not is excessive or overly optimistic. This however was the starting value for Aena when priced at €170 a share last Christmas. With scope to grow its long-term airport capacity with guaranteed regulator returns, but then supplement these with 85% EBITDA margin retail activities we think the company had (indeed, has) room to grow such a valuation, especially as it is able to use its balance sheet to do so.

BCIA value is illustrative that occasionally significant anomalies can get thrown up in global markets. That there are greater uncertainties we will not dispute, and we would very much like spend time with the company to better understand a number of these. However even allowing for heighted risk its unlevered $3.5bn valuation is very unusual and very low against a long list of global benchmarks. (NB The Regulatory asset value of just Heathrow is c.$21bn).

you make most of your money in a bear market- it just does not feel like it at the time!” Warren Buffett

With best wishes

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

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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

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

 

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.