Jun 2020: Formula 1 – A simpler Formula

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Formula 1 (FWON) – A simpler Formula

Jun 2020 ($34)

 

The Covid crisis has resulted in much change to some company capital structures. Formula 1 (FWON[1]) is notable as a company that has greatly reduced its debt and simplified its capital structure considerably – without issuing new shares: This is our third in-depth look at FWON since 2017[2]. As we first said then, we think F1 is a ‘rare bird’ investment. Today its shares offer value to longer term investors seeking great franchises and importantly now come with far less debt.

What attracted us to Formula 1?

“Content, you know, content is where the money is…and content will always be where the money is…but content distribution magnifies the value of content – Warren Buffett

  • FWON shareholders own a share in an entire Sports League, an extremely rare asset
  • F1 is a unique, globally recognised brand with 390m million unique global viewers
  • With pricing power (i.e. contractual rate increases in promotion and sponsorship deals)
  • F1 was under-managed/under-monetised under Eccelstone and now has top-class management with a long-term outlook. We see lots of opportunity to accelerate growth.
  • This is an extremely asset light business and thus very high return on capital

…in short, F1 is a dream business

And what has changed in the last three months?

Fig.1: Never waste a crisis: FWON is now a simpler and more resilient entry

Source: Holland Advisors

  • A much simplified capital structure as per Fig.1
    • Equity stakes monetised (reduced from c.50% of MCap to c.10%)
    • Consequently, Net debt reduced from $5bn to $1.6bn
  • FWON shares -25% YTD. Before any re-leveraging in coming years (i.e. sizeable buybacks of stock), this is a business that offers investors a 13% IRR’s (our best guess) from today’s starting price.
  • A purer equity play on F1 (no Live Nation exposure any more)
  • Team ‘cost caps’ now agreed with the teams. Covid could prove the catalyst to “create a financial structure for the sport that allows smaller teams to compete” A renewal of the Concorde agreement has been deferred until 2021 but a sensible outcome that promotes growth is now very likely?
In this note we discuss:
  1. Debt reduction and a simplified capital structure
  2. A recap on the F1 machine – A cash cow and a growth engine
  3. A word on the near-term uncertainty
  4. And an updated look at valuation
Debt reduction is welcome

Much as we love John Malone and his track record, we were never totally relaxed by his willingness to embrace debt (and, frankly, financial engineering) to juice equity returns. Even if his businesses are always cash generative and the tax benefits good (F1 enjoys a 7.5% cash tax rate in the UK!). Our work on Marriott and Ashtead’s clever use of affordable through the cycle leverage has helped our understanding on this issue, but Malone and team do like to push it a little!

But we always liked the idea of being long term shareholders in Formula 1. So, it is with some relief that we see Greg Maffei (Malone’s right-hand man and head of Liberty Media) de-lever FWON in April. His hand we suspect forced by lenders and the huge uncertainty about 2020 F1 race calendar. The group needed to reduce its significant interest costs and thus divested its 30% stake in Live Nation leaving a far less leveraged owner (FWON) of the Formula 1 racing business.

To remind you, the FWON tracking stock included a significant equity holding in Live Nation (worth c.$5bn as recently as February). That stake had halved in value by the time the asset was transferred to Liberty Media sister company Sirius XM along with $1.3bn of other FWON holding company debt liabilities in exchange for a $1.4bn cash injection. FWON shareholders also obtained ‘call-spread option’ allowing it to participate in any upside to Live Nation shares over the next 12 months (to $47).

Long story short, this action greatly simplifies FWON’s capital structure and also means that debt leverage will likely fall further and quickly in the coming years. Assuming that 2021 reverts to a ‘normality of sorts’ in terms of F1 season schedule, the cash generation potential of this business could mean that Net Debt/EBITDA could fall below 1.5x as soon as 2023 (see Fig.2). We elaborate on this cash generation later and our model is available on request.

Fig.2: A “simpler” capital structure

Source: Holland Advisors

The F1 cash machine + growth engine

Formula is a sports league, like say MLB, FIFA, Premier League or the Olympics. It owns the preeminent global motorsport racing brand (F1) and has almost no capital requirements as it does not host the race events itself. These being bid for by outside providers.

At its basic level, its primary costs are just its (admittedly very well paid[3]) employees. These employees negotiate rules and contracts with the regulator (FIA), track owners (‘Promoters’), media buyers (TV execs), advertisers and the racing teams. In the past, we have compared F1 to businesses such as Manchester United and WWE as per Fig.3. We strongly recommend a re-reading of our last in-depth report on FWON (Holland Views – Formula One, Economies of scale – $31, Dec 2018) from which Fig.3 originated. That note looks in detail at “the economics of content” and “Why F1 is a premium sports asset”. As F1 increases its fan engagement and racing becomes more of a spectacle we expect broadcasting and advertising revenues to increase leading to faster growth in profitability.

Fig.3: Thinking about scaling the business and operating leverage

 Source: Holland Views – FWON, Economies of Scale, $31, Dec 2018

Last year, F1 generated about $2bn in revenues, paying away about half of that to the teams (this share being determined by the Concorde Agreement). After this and its own staff costs FWON generated an EBITDA margin of 22-24%. The 33% suggestion we made of likely 2021 margin has not been achieved, but it should act as an indication as to how marginally profitable we think future growth at F1 might be.

For further insight into future potential profitability we highlight the percentage of revenue companies like Manchester United and WWE derive from scalable sources, (i.e. adverting or broadcast fees). These have risen in each case from 40-50% to c.80% in 8-10 years. Not only does F1 feel under monetised when you get near the sport, but this is also evidential in the figures above. Today’s margins seem too low to us given a) the rarity of this asset in a global context, b) a comparison to how other sports media businesses monetise their content and c) the asset light nature of the FWON business model. Restructuring the Concorde agreement will likely help but FWON grow its margins but in truth it is the revenue growth of the entire sport that will really bring strong operational gearing.

Fig.3b: Live sport and why “the network will never cancel it”

Source: James Montague, The Billionaires Club

In James Montague’s, the Billionaire Club, he illustrates why the Major League owners in the US are so attracted to the UK’s Premiership football teams. Montagu reminds readers that Sports Teams are ultimately entertainment businesses with a never-ending, engrossing scripts and thus highly sought-after by TV networks! We think that logic applies to F1 too albeit that we think the script has become a little predictable in recent seasons.

The indisputable economics of content

We will add a little math to this thinking. When doing our work on Manchester United in our economies of scale piece (December 2018) we calculated something that surprised us as outsiders to this industry. Fig.4 shows that a content distributor (say cable channel) that has:

  • Revenue growth of 6% pa and who wishes to maintain very aggregable, 20% margins
  • Will happily pay a content producer 11% more for their content each year

This we think an important conclusion. Without it is easy to attach a too simplistic commentary to sport rights that is convenient, but untrue. i.e. that they are vanity assets with unaffordable player salaries and rights costs that have been bid up by media companies to uneconomic levels. Fig.4 we suggest is the evidence to justify why sports rights are extremely valuable and why a doubling of content costs every 6-7 years is actually reasonable (equates to 11% pa). This work we feel is equally (if not more) important in an OTT world as it was in a cable/broadcast one. Readers with long memories will know that the lack of need to play famous player salaries was one of the reasons we liked WWE. Formula 1 is one more step up again as they do not own the teams, but the very league itself.

Fig.4: The economics of content

Source: Holland Advisors

A recap on the F1 growth potential

The exciting part for equity investors in F1 is not the racing, but the untapped opportunity to add significant value via more races, festivals around races, online media streaming + far more sponsorship/co-branding all for a very limited incremental capital cost. These growth opportunities excited Malone and team at the time of their purchase and they still excited us today. All future growth will be capital likely have very high marginal returns.

We wrote before (Holland Views – Formula One, Lollapallooza…at speed, $38, Nov 2017), of the key improvements that could drive revenue growth:

  • Improving the racing spectacle for fans, night races, city races, weekend festivals
  • More races
  • Better penetration of US market, where Ecclestone was not trusted
  • Better commercial terms with teams
    • Lowering team costs with car spec standardisation and budget caps
    • Aligning team and F1 interests to promote growth
  • Better commercialisation (broadcasting and sponsorship deals)

We acknowledge those changes have been harder and taken longer to implement than Liberty and we ourselves envisaged back in 2017, but there is clear progress. This quote from Greg Maffei from last November’s capital markets day gives useful context on the company’s progress since 2017.

We made the investments over the last few years in marketing and sponsorship and research and they’re going to start paying off. Importantly, we did our deal with the FIA, improved the car specs and the cost-cap. We’re working on the team agreements, which I believe will proceed favourably and they’re going to set us up for improved fan engagement continuing growth in sponsorship broadcast and promoter value, allow us to fund more growth initiatives, allow us to increase dollars for the teams and then continue the economic sustainability of the business. I think we’re at the beginning of a virtuous cycle, you’re seeing some of that kick off in ’19, but we’re super excited about what’s going to happen in the next several years. Source: Greg Maffei, Nov 2019

When spending time inside Formula 1 we find two things. One is a great passion for the sport at a global level. The other is the focus on the details. Crucially it was the details that needed to be worked out first before any real change in commercialisation of the sport could take place. The detail we refer to is around car specification, track changes to permit more overtaking, team budgets, DRS system ++. Think of a sport you love (say football) and the controversy over every change that has ever taken place (back passes, goal line technology). Each is designed to make the sport more of a spectacle, but they take time to enact. Formula 1 is no different, except that these changes had to be agreed by all and were important to make the sport more of a spectator spectacle. Few of them have yet to benefit the racing we see each week.

Cash Generation

We outline our simple P&L/EBITDA model below but first reference a slide from the Liberty Media’s analyst day last November. Our clients will remember our recent work on American Tower, Ashtead and Marriott – all highly cash generative businesses which judiciously use constant debt leverage to provide cheap funding for growth and an efficient capital structure. Arguably, John Malone was the pioneer of this approach four decades ago. Thus, it should not be a surprise to see a Malone company a) being highly cash generative and b) using debt to enhance equity returns. Fig.5 shows this mindset clearly.

In 2020 arguably the bankers had the upper hand (for once) over Malone, insisting on a recap as F1 high leverage met zero revenues. The result, as we showed in Fig.1, is a business that might find itself under levered in say 2023. Investors should not expect it to stay that way. Once post-Covid resilience is proven and growth restarts it would be very very surprising were Formula 1 not to be a significant purchaser of its own shares.

Fig.5: A reminder of the cash generation on offer (pre-Covid)

...Fl and FWON Expanding Free Cash Flow FWON Cumulative Free Cash Flow (2020 through 2023) in millions Free Cash Flow(l) OPCO Leverage Capacity 5_0-5 5x Estimated Restricted Paynrnts Fl Free Cash Flow FWON Monetizeable Corporate Assets BATR, private assets) Live Nation Margin I_oan Capacity (less) Estimated Corporate Expense FWON Free Cash Flow $1,600 $800 $250 $2,650 $300 $600 ($450) $3,100  Source: Liberty Media, November 2019

Near-term uncertainty

Greg Maffei and Chase Carey have done a good job of restructuring and simplifying FWON’s debt and capital structure. They have boosted liquidity and continue to work with teams and tracks to keep the F1 ecosystem as intact as possible for fans, teams and promoters through the lockdown. Obviously, this year is a ‘write-off’ from a profit perspective and both we and the company are working on the assumption that the 2021 season can revert to some sort or ‘managed normality’ in terms of event safety and attendance (NB the 2021 season does not start until March 21). We might add that an F1 event is a large-scale social event, but what might be in its favour from a Covid restriction perspective is that it is an outdoor event.

A cursory look at 2020 is relevant just to assess the cash burn. Fig.6 gives a stab at how it might play out. It is still in planning stages but F1 is hoping to host 15-18 races this year through to Dec 2020..? The number of races and attendance (especially of later races) will obviously have a bearing on cash generation. Revenues are most at risk from Track Promoter revenues. Though these are typically a flat fee, F1 is being flexible with the track owners. Our finger in the air estimate is that group revenues could more than halve this year to c.$900m.

  • We should note the recent development that Sky has secured significant refunds from The Premiership and is seeking similar concessions from other leagues including Formula 1.
  • We should also note that F1 has addressed recent press speculation that it may need to support lower-tier F1 teams financially saying “those are discussions we’ve not had to date”.
  • The good news is that most of F1’s cost base is variable. It is essentially Team Payments and Employee labour costs. ‘Other cost of sales’ essentially are pass-throughs of paddock and freight forwarding costs.
    • Team payments are actually determined as a percentage of ‘pre-Team payment EBITDA’ but roughly approximates to 50% of revenues. There are contractual minimum payments which could kick in if more races get cancelled.
  • Long story short, assuming that F1 realises its 15-18 race ambition this year, it is plausible that the F1 opco should cover its (now much lower) group interest costs of c.$100m.
  • The reality of F1 racing is that much of the financial pain will be borne by those that have the large Opex budgets related to it (i.e. the teams and the race promoters).
    • As an asset light business FWON will be exposed to its share of revenues, but sizable losses should be unlikely. Importantly this means a further deterioration of the balance sheet is unlikely also.

Fig.6: Team payment % and revenue growth are key to profit growth

 Source: Holland Advisors

Valuation and conclusion

We guestimate that FWON could generate $533m of true Free Cash Flow by 2023. This assumes a 5% revenue cagr from a $2.1bn starting revenue figure. (NB this level of growth is maybe modest when most race promotion contracts had 5%pa escalators in them, i.e. it assumes little LT growth form any innovation or more races). Some operational gearing is assumed with EBITDA margins rising to 30% by 2023. That suggests a 13x P/FCF multiple in 2023. This is far too low for what will then be a global leader in sports rights. Moving that multiple to 25x would give shareholders 76% upside in 3-4years(13%pa). Crucially however this assumption takes no account of the use of cashflow for its most likely accretive purpose, buy backs. A re-levering of the business to only 3x 2023 EBITDA (low by Malone standards) would enable a sizable buy backs accelerating shareholder returns.

Fig.7: Cash generation to drive de-levering and low free cash multiple

Source: Holland Advisors

In our December 2018 piece this was our conclusion on Formula 1:

Source: Holland Views – FWON, Economies of Scale, $31, Dec 2018

What is interesting in 2020 is that Covid-19 and the destruction it has brought to the leisure businesses has resulted in the removal of our greatest past reservation for FWON, i.e. leverage. All the benefits of a future rationalisation and commercialisation of F1 still remain and the longer-term multiple we are paying for the shares is co-incidentally similar to that when we looked at the opportunity in 2017+2018. But at those points we were faced with a company needing to de-lever itself. Not only is the risk of leverage, and the accidents it can cause, greatly reduced, but its prudent re-use one day could see returns for equity shareholder enhanced long after Covid is a distant memory.

Buy Formula 1

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.

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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. We remind you that Formula 1 is publicly traded via a ‘tracking stock’ and is legally a part of John Malone’s Liberty Media conglomerate. In this note, ‘FWON’ is the tracking stock/holding company, ‘F1’ is the operating company.
  2. Holland Views – FWON, Lollapalooza at speed, Nov 2017, $38 Holland Views – FWON, Economies of scale, Dec 2018, $31
  3. Pre-Liberty ownership, F1’s then 360 staff received $54m cash salaries and $98m worth of equity!

 

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