Nov 2020: Mo Farah’s recovery portfolio + Be bullish

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Mo Farah’s recovery portfolio + Be Bullish

Nov 2020

 

“Where did all my competitors go?”

The market has had its first sniff of recovery. We are interested in the best businesses that have the greatest and most lasting recovery potential. Mr Market we note is a long long way from working that out yet. We are very bullish on 2021, but sadly only have two pairs of hands!

A little reflection to start

2020 has been a brutally busy year for us here at Holland. Like you all we have gone from the normal work of assessing weak vs. stronger business models and operational gearing to cash survival analysis, doing so in some cases with sales not -20% but at zero. Mark and I are proud of the experience we have picked up along our analytical journeys over the past combined 50 years of market watching. Dramatic cycle changes we are ready for, but stress testing capital structures for zero revenues, let’s face it, was a real challenge.

During the summer period we tried to do what we thought would help you as investors. I.e., come up with new ideas of companies we thought had become mispriced in the selloff. In truth doing so with an analytical staff of two is extremely hard. We are proud of our ability to move across sectors and geographies, taking what we learn from one to another. That said jumping into Ashtead, Aena, Brembo or Hiscox in the middle of pandemic is not easy. Especially so when our readership is of a really high standard (we would have it no other way). If in 2020 we were working in a different role that gave us greater access to resources (say as a Head of Research) we would have been encouraging others to look at a broader range of ideas. These would mostly fall under a heading we will call – “where did all my competitors go”. We still think there is time to do this work now.

Mo Farah’s recovery portfolio

Imagine you are Mo Farah. You train like hell, year after year. Each year to turn up to the World Championships and there is 1/100th of second between you and your nearest four competitors. You do the same each and every year. You try and try and you are almost winning but the gaps between you in the silver medal spot and gold in front and bronze behind is still a tiny fraction of a second.

Then in 2020 you turn up for DIVOC 91 Olympics. It is the semi-final of the 5,000 meters. On the back straight a slightly odd-looking chap you have never seen before seems to trip one of your main rivals. Your rival falls and does not make the final. The next day is the final, you are very focused on your race and are out in front. Normally your nemeses will be right on your shoulder on the final bend for his ‘kick’ finish to beat you to the line. On the back straight you hear a scuffle behind you but daren’t look back. You just keep running. When the final bend comes, you glance at your shoulder to find no one there. You look again to see no one is within 10 yards of you. Across the track your second rival lies injured, studs down his calf, a second victim of this strange DIVOC 91 Olympics…You think to yourself: “where have all my competitors gone?”

Where did my (big) competitors go?

The best recovery ideas coming out of this crisis we think will fall under this heading. In some cases, the failures are obvious (Norwegian fails so Wizz and Ryan have outperformed) but it is often far more nuanced than that. Indeed, the airline sector is one that has seen huge bailouts. Many see this as bad news for the sector, we see it as long-term good news as it has just made the high cost/low cost gap even bigger and the customer in time will notice. Arguably the biggest beneficiary of Norwegian’s failure is IAG. After all, long haul was Norwegian’s dream and their challenge to BA on a number of routes brought lower prices to routes that BA (IAG) held a monopoly on. That monopoly will return one day soon. The difficulty of a three-person operation like ours is that it is hard to be able to get into the detail enough of each and every idea to give the conviction we would want on such a share; especially when they are a) cyclical ideas and b) there have been capital structure changes of late. That said with our Head of Research hats on we would be telling others around us to spend much time on IAG right now. (Or companies like it that fit this remit of having failed competitors).

Another company that looks strongly positioned in that in regard is Whitbread. We briefly wrote about it in the summer, but again we were time limited. Whitbread recently spoke of having increased its Premier Inn market share over the summer months in the UK by c.30%. This is a remarkable statistic (from 8% to 10% of rooms sold). They also spoke of some freehold owners of Travelodge hotels re-bannering themselves as Premier Inn during too. Going back to the Mo Farah story when we think of how hard it is to get a market share position of say 8%. A period that enables you to jump 2% share points just in a few months can make a massive difference to the scale of your footprint and brand in the longer term.

As is the case with IAG, post a rights issue Whitbread looks equity heavy and customer demand light right now. As such it is hardly an attractive investment for the asset light groupies of 2015-2020. For those of us prepared to think differently maybe these businesses are more interesting. Sometimes to build a moat takes times yes, but also capital (when others do not have it) and an ability to endure pain for a while. These could be very interesting opportunities. Those of you with deep analytical resources at your finger-tips should be getting them to work hard in these areas. We would love to hear of others you think are similar.

Where did my (small) competitors go?

The failures of Norwegian and Travelodge are visible for us as investors to see. What is less visible is the failure of many smaller businesses (gyms, hotels, restaurants) and yet these will play an equally strong role in future market share movements too. Many of us have seen the generic Investor Relations pie chart that shows market leader share, number 2 share, number 3 share and ‘independents’. The independents are too small to name and don’t have listings. They don’t put out RNS releases. Some will have had help from their banks, some will have benefited from furloughs, but many will have suffered in a less than fair way.

Indeed, that the UK bailout system helped the small self-employed, but by excluded all those who are Directors has in fact hurt many businesses who might have been quite strong otherwise. Arguably those perhaps who were gaining strength to challenge bigger players in time..? An example I could write at length about is my local gym which was the best of six in my town. It was loved. People left David Lloyd to work there and train there. ALL the classes had wait lists. It was THE place to work-out locally run by a great husband and wife team. But it went bankrupt when Gym Group, David Lloyd and the work at home personal trainers survived. Why? They had the right kit, the right brand, classes, website +++.

They just had the wrong lease with the wrong landlord at the wrong time. That does not matter when you are either big OR successful OR if sales are down 20-30%. It matters a great deal if they are down 100%. It was a tragic personal local story because the business was so strong before.

Pubs, sarnies and gyms

The implication of these sorts of trends are harder to see for stock market investors but still important. Companies like Gym Group and David Lloyd suddenly look a lot lot better placed locally than they did post the closure of my local gym, without them doing very much right. Is that the case nationally? Is that happening also to sandwich shops and coffee shops where there is a strong independent sector too? In reference to Whitbread above we note that the hotel sector has a huge independent component. In the summer we singled out Greggs as a benefactor of this trend. In its case, that its peers were mostly London-centric in their base and the damage done to these businesses in the first lockdown (Pret/Leon etc.) as well as that to the independents must surely help Greggs win shares in the normalisation when it comes.

Another affected sector is pubs. Listening to the Young’s call yesterday the group has been doing extensive works on its pubs to extend gardens and upgraded its app faster than planned. JDW has been doing the same. Being a visitor to pubs it always fascinates us the difference between those (big and small) that really make the experience better for the customer and those that don’t. Listening to Greggs, Young’s and JDW talk about how fast they were able to roll out their app upgrades and home delivery (Greggs) vs. other local eating out experiences in the summer (good and bad) tells us that the strong will only get stronger post this crisis

Might these be the crisis Tim Martin needed?

Readers know that we are admirers of the JDW pricing policy. Also, that we think one day a little operational gearing will show up in this business when they just cannot find any more staff to pay and any more beer to give away at silly low prices! A few years ago, we managed to get a few minutes with Tim at the back of the Crosse Keys. We asked about this point. I.e. when might the long awaited operational gearing arrive, and it be good to be a JDW shareholder rather than just an employee or customer? Tim answered by describing the competitive situation in the pub sector in the 1990/2000’s and the restaurant sector today. He pointed out that during past over-investments in the UK pub estate (via companies like Punch and Enterprise) JDW sales and profits were depressed. When that bubble burst, he noted JDW did really well. He went on to say that there had then been a huge over investment of capital in the restaurant sector (we were talking in c.2018). He cited new branches of Jamie’s and Carrluccio’s across London-all half empty. He observed that when that capacity left the restaurant sector, like it left the pub sector, JDW would do well.

At the time this was not the answer I wanted (rarely are they!) The Sam Walton in him knew that he just had to keep charging the low prices, build the brand and… wait. As Covid has decimated the restaurant sector this year Tim’s reflection on that day in 2018 has often returned to me. With the company in technical breach of its covenants, losing £14m a month and the pubs shut it feels a strange time to talk about their competitive strength. We will see.

VAT, pricing importance + Tim’s Rants

The other interesting aspect of these consumer areas like eating out and pubs currently is pricing. The change in VAT has brought about either help to operator profits or bigger gaps in pricing depending on who passed on the VAT cut and who did not. Again, from yesterday’s Young’s call we learnt that they had originally passed the VAT cut on to customers in the summer, but quietly they have now pocketed it, meaning they will have put prices up.

JDW by contrast have kept prices low (indeed did you grab those 99p pints the day before lock down – My sons did). These differences matter little when pubs are shut (!) or when trading is light, but when pricing gaps are already big and trading normalises next year the customer will notice. Not directly between say Youngs and JDW for they are serving different market, but vs local peers who acted differently. Another example is Greggs. It has passed the VAT cut on in the summer, but my local sandwich shop did not (again scale advantages in evidence).

We will be honest and state that do not always agree with Tim Martin’s use of JDW investor releases for some of his personal views. Sometimes would like him to tell us a little more on his thoughts about the business. However, we do hugely admire the tenacity he has for a cause. Indeed, that the Chancellor cut the VAT on pubs during this pandemic is interesting as this has been a permanent policy Tim has been campaigning on for years now. Tim has (rightly) sought tax equality between pubs and supermarkets, a policy that most other EU countries now have. Having noticed this issue and made this change in the summer we wonder if it is likely that the Chancellor might make it permanent in the spring. He clearly will be looking to balance the books so taxes will be going up on capital gains and the like, but populist tax cuts are always well – popular. It would help the man on the street and a sector that desperately needs it. If the Chancellor does so it will be solely Tim’s doing, as for some inexplicable reason the sector has never backed his call on this issue.

Your ideas

We would love to hear your stock ideas that fit this ‘lost competitor’ thesis. We are particularly attracted to sectors that were already seeing supply side discipline on capacity. We think the equipment rental sector interesting. Here in the UK and US there are plenty of independents who will have found it very very hard to compete with the services offered by United and Ashtead in this period. We are interest to hear of others…?

“Be Bullish”

Working as analysts with sceptical eyes at Merrill Lynch, in the years leading up to the 2000 boom/bust under the motto of “Be Bullish” always somewhat irked us both. It seemed to fly in the face of the cautious, risk averse investing path we believed right to follow. (Your authors both left in 2004). However, in our long investing careers we have rarely felt this phase is more apt that today. It must be remembered this is not from investor writing based in Wall Street, but from one sitting in London- seemingly the most hated investing market in the world

Almost exactly one year ago we were predicting the outcome of the UK general election. We were right, right and then very wrong. We thought that the Conservatives would win by a strong majority (right). We thought that a Brexit deal of sorts would get agreed (right). As a result, we thought the UK was poised for strong period of economic recovery (wrong – in fact, very wrong thanks to Covid). So what about today:

  • The Pfizer news is universally bullish on scale that we think many investors and the wider population are struggling to adjust to. It having a number of knock-on positive consequences such as the likelihood of other vaccines being more likely to work
  • It seems almost likely now that a second vaccine (Astra Zeneca – mentioned by Matt Hancock on Question Time last night?) might have good efficacy as well as it uses the same approach. We will find out in next few weeks.
  • Some form of Brexit resolution is likely. For all sides the logic in finding a form of compromise would seem logical. This again will come in short order.
  • Political stability is arriving in the form of centrist Democrat President’s but still a strong republican representation in Congress and Senate
  • A new phase of UK government may start with the new year – with the quiet departure of Dominic Cummings (ref. Spitting Image – ‘you cannot fire me’)
  • The scale of pent up demand for consumption and feel good factor in Western economies in Spring/Summer 2021 we feel is simply enormous. This will likely more clearly emerge in early Spring as the virus naturally fades (due to its seasonality) and the vaccine will have been rolled out in some scale
  • The only analogy to such a period is maybe the post-war boom years, but this time people have greater access to credit. For some also there was no loss of earnings at all, just a loss of the ability to spend. We should remind ourselves too that the drivers of wealth for the lucky in society are unchanged – neither property values nor equity markets have fallen
  • This will all come with uber low interest rates and central banks that are so delighted to see growth resume they will not want to be party poopers.
  • ….and with with western politicians who have committed to a scale of fiscal spending rarely before seen.
  • This has all the makings of a multi-faceted multiyear boom…for now
Roaring Tigers

The sceptics will shout ‘bubble’ and ‘inflation’ as we might have done 20 years ago at the first sign of any good news! But it is hard to have an inflation when GDP is still down 10% on its peak that was only last year. Every day since last April every economic doomster has been too bearish on the economy – all the way up they have failed to understand global workers and consumers resilience. The ‘Caged Tiger’ we spoke of last May has bounced back in some sectors, but boy oh boy how she wants to get out of the house, go on holiday etc. The recovery in the demand for these sectors could be unprecedented not just in terms of demand, but soon after that in pricing also. (Ref our Ryanair piece ‘Feast to follow famine’). If capacity is down and demand goes crazy, pricing will spike and margins will snap back ‘real fast’ as our North American friends like to say.

Our work over the summer has been focused on this normalisation and trying to profit not just from its snap back but by being well positioned in companies that end up being lasting beneficiaries of this crisis that were overlooked at the time. Being early to call recovery ideas feels pretty much the same as being wrong until…. maybe you are right. All you need is the sun to come up, spring to arrive or a Pfizer’s silver bullet! Maybe even an Astra golden one to follow it.

This week’s share price recoveries have seen many hated shares boom and many commentators who were happy to find reasons to recommend the sale of such shares on the way down, now find reasons to encourage the layman to hold on a little longer or buy: ‘I am now hearing the summer 2021 cruise booking season is looking stronger, so I would hold on’ Such is the way of markets, the cycles they move in and those that earn a living commentating on their every whim.

We too earn a living from them, but our role is to try and help clients profit from taking the contrarian approach to Mr Market’s mood swings by buying good businesses when they are offered for sale. This for us was the state of play for much of the leisure and tourism (it should be noted, normally growth) sectors in 2020. Thus, once we felt the market lows had passed us in the Spring, we set about trying to identify contrarian value.

In occasional cases our notes were published close to share price lows (Aena and Ashtead). In others we went to print far too early (Greggs). Such crude score keeping misses the point. The time to start looking for those contrarian ideas was as the market fell, the time to stop looking for them, is not yet.

Where we have done enough work on a company to understand its capital structure, competitive position and compounding abilities in the long term we write pieces outlining its attraction to you. As you will have gleaned from our thoughts in recent months, we think this a target rich environment. There are likely many more attractive stocks in the market today than we can do the required work on in the time left, but we will share our ideas in all forms. We would be delighted to look at other companies you think might make a Mo Farah portfolio. Happy recovery hurting

As the Thundering Herd used repeat ad-nauseum – “Be Bullish.”

Andrew Hollingworth

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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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.