13
Nov

Nov 2020: Ryanair/EasyJet – A matter of trust

November 13, 2020

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Ryanair/EasyJet – A Matter of Trust

Nov 2020 (€15.5/775p)

 

“The test of a first-rate intelligence is the ability to hold two opposed ideas in mind at the same time and still retain the ability to function” – F Scott Fitzgerald

That the low-cost airlines of Europe are ultimate beneficiaries of a post-Covid world is something we have believed all through 2020. The recent share price performance of Ryanair and Wizz suggest that Mr Market now agrees with this view. Both are in a strong position to reduce their unit cost bases further while bloated competitors accept state aid and the handcuff conditions that accompany them. Hopefully we expressed these views clearly during the year.

Now we would like to add a new idea; this being that ‘trust’ as much as low costs will play an important role in the recovery of the airline and holiday sector.

Unprecedented pent up demand

We will not write at length on this issue only to state again that we think the scale of pent up demand for leisure travel post a Covid recovery we believe will be simply enormous. In a recent piece on Ryanair we noted that this could lead to a ‘feast’ following the recent ‘famine’, i.e. Travel and airline companies could potentially make supernormal profits were a portion of this massive demand to accompany maybe a slight shortage of supply. The latter possibly occurring due to company bankruptcies or lack of available pilot flying hours or ATOL licenses etc. In the summer when writing about the Spanish airport operator AENA we talked about ‘the time to buy a road toll was when no one was on it’. Today we ask:

“when travel demand does recover which companies will it benefit most?”

A Matter of Trust….

The reason we have used the F Scott Fitzgerald quote above is that we think there are two types of attractive travel companies right now and they are not mutually exclusive. The first being the lowest cost producers that we always seek out in our work across sectors. This leads us to Ryan (and we accept also Wizz). All of our recent work shows their cost leadership position only being strengthened further. However, those that have followed our work on this sector will know that our work on EasyJet was subsequent and adjacent to our Ryan work. We noted there was room for both companies to operate in this low-cost market. The second type of company that we see as attractive right now are those that are trusted by their stakeholders (customers, suppliers and regulators).

A story of travel past…

In 2018 your author took a number of flights. He is a frugal individual, so keen to save money where he can. A family holiday to Majorca was booked with friends “the cheapest flights are coming up with a company called Air Europa, Andrew, what do you think?” I checked them out for a whole five minutes and we booked them. Later that year I had to go to New York for business. Something I dread, due to its expense. I flew with Norwegian from Gatwick. Were in 2021, I to be making either of those trips again am I likely to pick either of those airlines? No, I will pick a more reputable alternative.

… and future

And what about all our travel plans for 2021-2023. We will all be looking forward to our holidays. The first thing we will do is book with a company that we know has not gone bust (so that rules out STA and Thomas Cook). We are likely to want to avoid those that have been in the news as rumoured to be ‘in trouble’ or ‘needing help’ (Virgin and Norwegian). Next, we are likely to use brands that we know and trust where maybe we have already had a good relationship before. As much as our friend Michael O’Leary might squeal at the next point that does not put him at the front of the queue! We will also want to use a company that if something goes wrong, will look after our family. This all points to incremental demand for trusted brands like BA/EasyJet and Jet2 in the UK.

Fig.1: References to Customer trust in Annual Reports

EasyJet Ryanair Jet2
References to “Customer Trust” 5 0 13
Mentioned in Risk Factor Section? Yes No Yes
“We believe that in times of uncertainty

customers look to brands they can trust and which offer them the best value”.

 “we relish the trust our customers place in us to give them a fantastic holiday experience”

Source: Company Annual Reports

Trust and Travel

Much of travel is sold on romance. The wonderful time you and your family will have on that beach in Spain, or the luxurious relaxation you and your wife will enjoy on that city break.
After that comes the cost. But underlying it all is trust. Will it all work out OK? Web photos of apartments and reliable low-cost flights have meant we have taken that trust component for granted in recent years. This was what we used to pay package holiday companies for and indeed what some people still do pay them for: to ensure a lack of hassle or fixing of the cost. Covid we think has thrown the trust cards up in the air as far as travellers are concerned. At least for a while. The desire to travel/get out of the house and live will be an enormous driver of demand post-Covid. However, the best low risk way to do it will be unclear. With that in mind we ask a few rhetorical questions about your leisure travel plans in the next few years:

  • Will you trust a new company, say one you have not used much before?
  • Will you trust a company that has had bad press about insolvency of treatment of customers over the Covid period?
  • Will you trust to fly from new airports or the one you know?
  • Will you trust paying for a villa and flight separately or might you want them all packaged in case something goes wrong?

Clearly, we do not know exactly in what scale and where leisure/holiday demand is going to resurface when it recovers. What we do know is that it will not be in the same place as it was before as some of those suppliers no longer exist. What interests us is that Mr Market’s interpretation of this recovery is that it is skewed heavily towards Wizz and Ryanair holding all the aces. Our work on these lowest cost providers agrees that they have some of the aces but not all of them. In terms of share of customer mind and trust, companies like EasyJet, BA (IAG) and Jet2 we think, look very well positioned in the customers’ eyes. Arguably better positioned than Ryanair on the Trust issue for holidays.

A study of cash (and voucher) refunds

Like other investors this year we have been closely focused on the free-cashflow burn of the airlines that we look at. Perhaps we have been a little too focused…?

That Ryanair has shown itself to be a brilliant low-cost base business that has managed not to produce sizable losses or significant cash outflows during this Covid period we have been impressed by. Are its customers as impressed…? The influential Which? magazine thinks possibly not[1]. Clients will find attached a study we have done ourselves of Ryan, Jet2 and EasyJet cashflows over the last 6-month period. Whilst there are many moving parts for each, a couple of small points and one very large one stand out. First the smaller ones:

  • EasyJet takes it aircraft depreciation on a straight line basis (Ryan takes it on a usage basis). EasyJet also undertook a little kitchen-sink provisioning in H2. As such EasyJet’s P/L losses look worse in the period, all other thing being equal.
  • Jet2 (as it always does) separates cash between customer cash and its company owned cash.

Now the elephant in the room – cash refunds or Ryanair’s lack of them

“In July, we analysed 12,000 complaints about airline refunds and found customers were owed £5.6 million in refunds. That is just the tip of the iceberg. It was also clear that while some airlines, such as Jet2, had done a good job on refunds, several were clearly delaying or refusing refunds. In total, Ryanair customers were responsible for 44% of all the complaints received. EasyJet was the second-most complained about airline, with 14% of all complaints coming from its customers.” – Which? Statement[2], July 2020

We are fans of Michael O’Leary, but he is prone to conflict and hyperbole. Recently he gave an analyst a very hard time when she said Ryan were not giving cash refunds. A recent BBC interviewer suffered a similar fate[3]. We will just present the facts as we see them from the accounts. The first obvious fact we point out is that ‘paying’ out a voucher refund is not the same as paying out cash refund. Ryan looks to have given many refunds of flights to customers but done so in the form of providing these customers with Ryanair vouchers as opposed to hard cash. Ryanair had circa €1.5bn of such vouchers on its balance sheet as of March 2020. Our work suggests, customer vouchers still amount to an accrued liability of c.€1.3bn today. In that context, the following excerpt from Ryanair’s Risk Statement is revealing.

“There is also a risk that some authorities may find Ryanair’s decision to encourage passengers to accept travel voucher in lieu of a refund to amount to a breach of the information obligations contained in the Regulation and/or a misleading commercial practice.” – Ryanair FY20 annual report Risk Statement p.73 (emphasis ours)

By sharp contrast in the last 6 months EasyJet and Jet2, we estimate, have given hard CASH customer refunds of £863m and £409m respectively.

Follow the cash

We have not got to these conclusions by reading company press releases or the like but by studying the cash in/out flow of each group’s cashflow statement. Needless to say, the greater the cash refunds paid-out, the worse said company’s cashflow statements look. In turn the greater financial peril a company it might be judged to be in by analysts (ourselves included) were they too fixated on just that cash burn number for an uncertain period.

Conversely how might such a company’s customers feel and importantly how would we know (answer – they would feel fairly treated, but we would only know when/if they came back to the company in the future with their business). The corollary to this cashflow issue is that when these happy customers re-book such monies will return boosting cashflows for Jet2 and EasyJet. In Ryanair’s case upon the eventual use of vouchers for flights will not result in a cash inflow.

Our point here is not to criticise Ryan for conserving cash in a crisis at the expense of its customers. Its ultra-low-cost model suggest it was likely to do nothing other. Instead it is to illustrate that customer trust might surely flow back more freely to those brands they feel better looked after by who they can maybe trust more? Partially so in the family holiday market where so much is at stake if something goes wrong as opposed to just on point to point flights

Regulator and supplier trust

We have known Jet2 (formerly Dart Group) for many years. We learned a great deal from it as the requirements made by both regulators (CAA) and credit providers (merchant acquirers) on travel companies like Jet2. Simply put a credit card company and the bank that sit behind it needs to be sure that the travel company is going to be able to deliver the £2,000 holiday before it is prepared to release the client funds for the transaction. Said travel company needs to show a balance sheet strength commensurate with that commitment. That may sound easy enough. In fact, it is anything but, especially if you are wanting to grow at a fast rate as Jet2 has done and many might like to in this recovery environment. This is the main reason Dart Group sat on such a prudently financed balance sheet during its strong growth years.

Now consider the role of the regulator. Travel companies have ATOL protection meaning the CAA gets everyone home if you are stranded (as I was when Monarch went bust in 2017). The CAA keeps a close eye on who has what capital and who is selling what holidays knowing they are one who picks up the pieces. Investors should be thinking of the CAA today as they would the banking regulator post 2008/9 “no, you can’t do that,” “no you can’t sell that holiday,” “no you can’t have an ATOL license”. They went into Covid a bit like the banking regulator went into the Credit Crunch, thinking their systems were fail-safe. Now they are far less sure. They will want to make sure the operators that carry the ATOL badge in 2021 and beyond are well capitalised enough to do so. Another point for investors to be aware of is that the CAA look at Company capital and past expertise and effectively decide how many holidays you can sell in a coming year.

All of this is, in addition to suppliers that want to get paid by an operator that will not fail, points in the same direction. That direction is huge consolidation, but not by deals or M&A, but just by suppliers, regulators and customers all wanting holidays and flights via the same few big Trusted companies.

A few other points re ATOL and regulators
  • ATOL is mainly a package holiday financial protection scheme. It is not intended and doesn’t really apply to flight-only bookings i.e. it’s relevant for Jet2, and EasyJet Holidays but far less relevant for Ryanair’s or EasyJet’s main flight only business.
  • ATOL Licenses are awarded for specific passenger capacities by the CAA.
    • CAA confirmed that of the 1,261 ATOL licensees that expired in Sept 2020, only 995 were renewed.
  • As of May 2020, here is the top ATOL licenses by passengers in the UK for 2020 travel:
    • TUI UK – 5.55m,
    • Jet2Holidays – 4.8m,
    • On the Beach Travel – 1.2m,
    • We Love Holidays – 1.09m,
    • British Airways Holidays – 1.01m,
    • Expedia Group – 874,208,
    • EasyJet Airline Company – 793,874, EasyJet Holidays 726,000,
    • BravoNext (lastminute.com) – 640,555,
    • Travel Republic – 555,060
  • We note that Jet2holiday’s ATOL licenses of 4.8m passengers should be considered in the context of 3.7m Jet2 package holiday customers in 2019. That was a c.27% growth projection.
Trust = Flight to Quality

What the future of business travel looks like we are unsure of. The future of leisure travel we think may normalise much quicker than many of us today imagine. Whilst it might feel odd to want to cram into a plane or airport today, there will be millions of people writing bucket lists and planning to live for today rather than work so hard. That there will be plenty of plane capacity we accept, for the world is awash with them, a bit like it is awash with video content. But as is the case in other industries only a few network operators of scale in each industry win most of the spoils. Ryan’s and Wizz’ places are secure as the super low-cost point to point travel providers. But others have a role to play too. Jet2 is trusted by many in the UK to provide the whole package holiday for a low hassle and good price. Many more will now come to it for this service as other competitors have failed.

EasyJet arguably sits between these three players. It provides the point to point network also, but does so in far more sought-after (rare + central) locations. The result of which is that it has a catchment area and thus client base in northern Europe (London/France/Switzerland). It also has ‘trust’ with large number of the wealthy populations that live near these airports and are its customers. We suspect that when these people travel again, they will do with EasyJet for it has not broken that customer trust, nor have competitors displaced it.

The other interesting part of EasyJet’s future is its holiday business. This was a smaller but interesting development for the group last year, but one we think with significant potential for growth in its margins.

The fact that this was an extension of the airline that Ryanair was not able to make in any scale suggests it is hard to do. Again, we think the role of trust was and will be critical here[4]. In 2020 the damage inflicted on other tour operators means that many hotels in Europe are keener than ever to have good new partners who can sell rooms for them. Other than Booking.com. When hotels are looking for a new partner who has massive scale (100m passengers) but also access to wealthy customers (rather than just bargain-basement hunters) Easyjet looks the perfect Pan European candidate.

Roughly right, or exactly wrong

We have long term models for both EasyJet and Ryanair which we are happy to share with clients that request them. They are not attached for the reasons expressed in the sub-heading above. Trying for forecast these businesses in a period such as this is tantamount to doing a jigsaw puzzle in a hurricane. We have focused on these businesses ability to survive in cash terms in recent months. Prior to Covid and now into the future we are focusing again on their compounding ability to growth as low (or lowest) cost providers of much valued travel services.

We would remind readers of a crucial point that differentiated our work on these companies from other analysts in the months and years up to Covid which remain valid today. Unlike the USA we believe strongly that the starting yields for short haul (fares) in Europe are artificially depressed. This is due to the aggressive discounting that Ryan has done up to this point to win market share. Longer term yields will be a little higher than 2019’s, but that ‘little’ will have a big effect on profits of the teams that are still on the field at the time the final whistle blows! The greatest driver of our long term firmer yield environment was industry consolidation and Covid has brought that about at breath-taking speed.

There may have been a bump in the road, but we stick by the thesis of our end game. Fewer bigger players, and a win-win for all. Cheap fares. Lower than ever unit costs and great return on capital for the few companies that offer super low fares or the right balance of cost and trust

We see significant upside in both shares.

Buy EasyJet + Ryanair

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 managers 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. https://www.which.co.uk/news/2020/11/ryanair-claim-that-all-requests-for-cash-refunds-have-been-paid-is-untrue/ ↑
  2. https://www.which.co.uk/news/2020/07/civil-aviation-authority-fails-to-take-action-over-airline-refunds/ ↑
  3. Michael O’Leary on The BBC https://www.bbc.com/news/business-54776678 ↑
  4. https://www.easyjet.com/en/holidays/info/protection-promise ↑

 

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

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