Dec 2022: TSMC – What does Warren see?

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TSMC – What does Warren see?

Dec 2022 (Tw$470/$80)


In our recent research report on Amazon, we observed the following.

In sharing its efficiency with customers by reducing prices AWS has brought the Scale Economy Shared business model that has proven so powerful with consumers into the world of corporate buying. With perhaps TSMC as the only exception we cannot think of another company globally that is doing this. The implications of this could be very significant. Source: Holland Macro Views/Amazon – Raining Gold + Unpeeling Amazon, Sept 22

Like other investors we had noted TSMC’s semiconductor manufacturing supremacy. As the above quote observes we further spotted them doing an unusual thing amongst B2B suppliers and sharing some of their scale efficiencies with customers. We also knew a couple of investment managers we respected owned the shares. Up until now this was the extent of our TSMC knowledge. Berkshire’s recent purchase of $4bn worth of stock piqued our interest however. We have learnt a great deal from reverse engineering many of Berkshire’s past purchases. As such we thought we would take a look to try to answer the question as to what Warren/his team saw in TSMC? What follows is less of a research piece and more of a call to action/reference piece. Summarising such a company’s operations is not our game. Seeing how its operating, business and financial model fits against our investing approach is.

Semi-complexity or value in plain sight

In the last 10 days we have looked closer at TSMC including reading its annual report – all 200+ pages of it. Our annotated copy of it can be provided on request. We highly recommend looking at it. Also available is an annotated copy of the analyst conference call that accompanied those 2021-year end results. We think both are revealing as to the attraction of this company. We have read no stock market research on it at all, but have listened to quite a few podcasts that recount the story of the company’s history and its founder. Please look at these annotated documents. We also recommend a few books later on.

Summarising TSMC skills, market position/power and technological leadership in a note like this would be trite. There are thousands of people worldwide that can assess such technologies better than us. What we seek is proven business models with the outputs and inputs that suggest with high a high level of certainty that their current industry dominance will remain. We stopped being sector analysts many years ago. Instead, we have tried hard to be mental and business model finders. If we can ever have an edge in company like TSMC (or Meta/Apple/Amazon etc.) it will not be through sector specific knowledge or granular detail. Instead, it will be from spotting a familiar mental model that we have seen powerfully used in another sector or geography before.

Readers need to assure themselves of TSMC’s franchise strength and of its current and future position. The more we have read the more this outcome seems almost an inevitability, but we’re not semiconductor/FAB experts. Warren’s actions however made us wonder if maybe there was something for us in TSMC hidden in plain sight. We conclude from this work, we think there is. We find ourselves excited.

What we think Warren sees

What follows is the framework we found ourselves using as we read more about this company.

Process Power

Earlier in the year we recommended Hamilton Helmer’s book, 7 Powers. It highlighted the different business models that readers would know as giving some form of moat. Easily recognisable ones are Brands, Switching Costs and of course Scale Economics. One that gets less attention is: Process Power. We and the book can easily identify Toyota as a past success story using process power. Indeed, Toyota process system (TPS) is now a widely copied manufacturing efficiency process used by many successful organisations. The only company we have cited in this area in our research thus far has been Amazon (#ref the Amazonian approach).

However, if you have this mental model in your head when reading TSMC’s accounts it is impossible not to conclude that they possess process power in very powerful industry dominating scale. Years ago, we heard Munger talk about manufacturing at scale and the small incremental advantages that huge production volumes bring to such an operator over time (e.g. Ford early last century). This is the perfect model of what TSMC is, albeit with a little complexity! We conclude that numerous levers come together inside TSMC to re-enforce what have become now huge advantages. This includes patents, sunk assets and control of its suppliers. Also, a high level of customer trust and massive ‘share of mind’ in this sector. It controls the assets and IP required to produce cutting edge chips at scale. It also has an irreplaceable workforce and deep enough pockets to make the required massive investments that drive future scale efficiencies. Lollapalooza comes to mind.

Our limited discussion in this area should not undermine its crucial importance. Deciding or not that TSMC has, and will retain, franchise strength due to its excellence of Process Power is the most important conclusion readers/we need to make. The more we read on this company and the role it plays in its industry the clearer we see this conclusion. Others will need to make their own decisions as to their conviction on this point post their own research.

Culture and ethos

What you can’t measure often matters more Munger

This is another area of intangible assessment that potential investors must also make. We think the TSMC Report and Accounts and a study of this company’s history give a wonderful insight into this important area. We would encourage readers to start by looking at the company’s Core Values and Business Philosophy

Extracts below give an essence of what you will find:

“Innovation is the wellspring of TSMC’s growth”

“At TSMC customers come first, their success is our success”

“Since the company was founded, we have treated our customers as partners and we have never competed against them”

Source: TSMC website Values and Philosophy

RONTA, ROE and reinvestment

For years now we have outlined our thinking on the above headings. Return on Net tangible Assets (Taxed EBIT/ PPE +/-WK) is our favourite measure of assessing a company*. Why? For four reasons:

  1. Firstly, it is the purist measure of what cash is being produced for each dollar of required physical capital in the business today
  2. Over years of study, it is the measure we know Buffett uses in assessing companies. We believe he does so because of point 1.
  3. Companies that make high returns on this measure for long periods must be doing something right, that others cannot copy
  4. Understanding this level of return also helps us to understand the true cost of future growth

In some companies the ROE calculation may be different to the RONTA calculation, but in more than a few, ROE acts as a good proxy for RONTA. TSMC’s historic ROEs are shown below. It’s RONTA as we calculate it was 24% for 2021 by comparison. As we highlight in the notated Annual report, TSMC’s high ROE’s are nearly all derived from strong ROA/RONTA. This is a company with no leverage (it is net cash) and has pretty much zero intangible assets. This high rate of sustained RONTA/ROE is a sign of a wonderful business. It is also evidence of the success of this business in the customers eyes. This company is in a super competitive, fast moving volume production field yet makes a gross margin of 53% and a net margin of 37%. Customers are clearly delighted with what TSMC provide to them, its profits are thus not a sign of any sort of customer gouging or branding. Instead, they are purely down to the scale efficiency its processes deliver to it.

Fig.1: Return on Equity









Source: Bloomberg

*NB: We do make other adjustments when necessary, such as maint. capex vs depreciation

Just a little theory

Read any good investment letter from a high-quality portfolio manager and they will use a phrase like. “We look to find companies that make high returns on capital, who can then allocate more future sums at that high ROIC rate.” We agree with that statement 100%. However, the reality of many businesses that make high returns (say Moodys or Visa) is that they have a limited ability to deploy more capital at these same rates. Hence good allocators running these businesses buy back their shares. The companies that can deploy more capital (our ‘Put up more to make more’ companies as we call them) often make returns that are a step lower than TSMC’s. Additionally, they may rely on some leverage to make their c.20-25% ROE, or experience some volatility in returns. (Examples might include Ashtead, Jet2 and Ryanair). We favour such companies not because they are better than Moodys or Visa. Instead, it is because they can sometimes offer us both future compounding and value at the point of purchase. This being due to uncertain outlooks or a lack of clear investor understanding as to how valuable future capital redeployment might be. By now readers will be bored of our Venn diagram, so instead we will let Buffett aptly express our approach:

“The best thing that happens to us is when a great company gets into temporary trouble – we want to buy them when they are on the operating table.” Warren Buffett

The reality is that the Visa/Moody’s of the world are rarely on the operating table.

Enter TSMC

Against these yardsticks of high returns and the potential to re-invest TSMC looks compelling. We hope the following quotes will be almost self-explanatory:

“We believe TSMC is entering a period of higher structural growth.”

“Looking ahead, as the world’s largest, reliable and effective capacity provider with our technology leadership, manufacturing excellence and customer trust, we are well positioned to capture the group from the favourable industry megatrend with our differentiated technologies. We expect our long-term revenue to be between 15% to 20% CAGR over the next several years in U.S dollar terms.

“We will also work diligently in our own fab operation and with our suppliers to deliver on cost improvement. By taking such actions, we believe a long-term gross margin of 53% and higher is achievable, and we can earn a sustainable and proper return of greater than 25% ROE through the cycle. Thus, even as we shoulder a greater burden of CapEx investment for the industry, we can continue to invest to support our customers’ growth and deliver long-term profitable growth for our shareholders.”

“Every year, our CapEx is spent in anticipation of the growth that will follow in the future years. We are witnessing a structural increase in underlying semiconductor demand underpinned by the industry megatrends of 5G-related and HPC applications.

“At the same time, we are committed to achieve a sustainable and proper return that enables us to invest to support our customers’ growth and deliver long-term profitable growth for our shareholders.”

Sources: TSMC annual report or Year-end Analyst call 2021

Price is what you pay – Value is what you get

The three legs of any great investment are high returns, good growth and a low starting valuation.

Exactly what has driven the valuation of TSMC lower in during 2022 any investor can never be sure of (see Fig.4). Of course, China/US relations have become more strained and unpredictable, particularly in reference to Taiwan. Equally the company is now set on a course of significantly increasing investment as the above quotes clearly show. This suggests short term investor sugar rushes of higher dividends may slow for a while (see pay-out ratio in Fig.3). With a clear history of excellent returns on capital being achieved we welcome this coming growth opportunity, but do all investors? Also do some investors see such expansions as risky offering chances of failure or low returns?


We include a couple of charts below just to show the differing periods of growth TSMC has experienced in its past. This clearly shows that in its history there have been periods of time where revenues have grown at a very fast rate and periods when they were growing more slowly. With steady margins and capital intensity (turn/assets) both profit and asset growth has mirrored this growth seen in revenues.

What is also notable is the how the groups dividend pay-out ratio has inversely corelated with such growth. This is great to see. A company with high returns on tangible capital/ROE’s has two choices for future capital deployment. It can allocate annual profits to further reinvestment if it thinks it will make a good return on such capital. Absent such opportunities it can distribute excess capital to shareholders. The charts below and our wider study of the company suggests TSMC has been highly astute and nimble is this decision making in the past. This is highly unusual is such high growth industries. Often growth is far more linear. TSMC past investment can thus been seen as both selective and also broadly successful it its timing of deployment. The crucial test is that even as more and more capital is committed by the group over time returns on total capital are maintained at high levels. This is highly unusual (see Fig.1).

The quotes in the earlier section we hope outline what we have read with regard to how TSMC is only planning strong asset growth because it sees high demand from its customers in the coming years. That it spells out such growth but also makes clear this will still come will at high (i.e. current) margins and high (i.e. current) returns on equity is insightful and impressive. Very few companies ever do this. They will lay out a growth plan, but the likely returns from which are found out after the event!

Fig.2: TSMC revenue – Strong, but NOT LINEAR growth









Source: Bloomberg

Fig.3: Dividend payout ratio mirrors slower growth periods = TICK









Source: Bloomberg


Price is what you pay, Value….

Fig.4: TSMC EV/ EBIT ratio







Source: Bloomberg


A week or two studying TSMC’s business models’ inputs and the outputs it has produced, suggests past higher valuation multiples given by Mr Market were largely justified. This being due to the huge moat this business has and the rare combination of growth with sustained high returns it can produce consistently. Today’s lower valuation occurring just as strong re-investment opportunities are actively being developed by the company thus looks compelling to us. (Maybe to Warren too..?) The starting ROE (c.30%) gives credence to the companies 15 -20% growth outlook. Indeed, a look at the company’s recent growth in assets seems to suggest a growth rate closer to 20% is more likely than 15%. As such some very compelling compounding may lie in front of investors today. The company having been an astute deployer of capital for organic growth at high rates AND a disciplined payer of dividends when such opportunities were scarcer is a powerful combination. It gives us an outcome we best describe as “Heads we win loads & tails we still win quite a lot”. Some scenarios:

  • At a 20% growth rate (sales + assets), investors expecting no change in share rating can reasonably expect Intrinsic Value Per Share (IVPS) to grow 22% (the extra 2% derived off of a 33% pay-out ratio and a current PE of 13x)
  • At a 15% growth rate they can expect IVPS growth of 18-19% (50% pay-out ratio on PE 13x)
  • Were post this period of strong growth revenues then slow to say an 8% pa rate of growth (implying a 75% pay-out ratio) IVPS would still grow by 13% pa

To some these might seem projections that can be met or missed. In fact, they are little more than mathematical extrapolations. Any assessment as to both the strength of TSMCs franchise and the competitive/political risks that may surround the company must not just be looked at in isolation, but against these probable outcomes.

Were any investor per-chance to decide todays 13x Multiple of both EV/EBIT and PE were too low, well then, they can add the chosen scale of the re-rating they expect to any returns assumed above!

The cost of growth

Whilst growth is regularly discussed and modelled, the true cost of growth is often not thought about hard enough. Whilst clearly for TSMC there is a high capital cost of growth which is understood. Are there others?

Yes. The company’s commentary of R+D makes it clear that the vast majority of today’s expensed spend is focused on specific future growth initiatives. R+D we note is c.8% of sales and therefore c.20% of EBIT. We make no suggestion that R+D levels should ever be cut thus revealing higher profitability. Instead, we assert that investors need to consider their degree of certainty that future profitable growth will be delivered upon due in part to today’s P+L expensed investment. When assessing the above three growth scenarios above did you take into account the scale of R+D expense already made on these growth initiates? The scale of the group and its leadership position means its R+D dollar absolute spend of course dwarfs any would be competitor. It is also growing very fast. In 2012 TSMC R+D expense was $1.3bn, by 2017 it had doubled to $2.6bn. It has now doubled again to $5.2bn. All these figures were c.8% Turnover

What about other costs of growth? A glance at TSMC’s high gross and EBIT margins suggests they must be maximising price. We think not. There is much focus on cost efficiencies and sharing those with customers. Customers in turn seem delighted with the service vs price offering that TSMC provides. There is zero claim of gouging. Yes, the company makes good margins and returns, but it only does so at points of massive scale. This is process power advantages. All of this implies TSMC is a serial scale economy re-investor in lower price/innovation. Again we make no claim that the company should ever change that strategy to produce higher margins in the future. Instead, we see this constant investment in customer pricing and relationships as a reason why future growth at good/great returns on capital has a higher probability of being achieved.

Were we to contrast TSMC with A.N other large manufacturer that did not invest similarly in R+D, customer relationships or pricing, surely we would conclude it to be less certain of its future dominance, even were its market share today strong. To think such a way is logical. As such we must also think logically in reverse. TSMC is making many investments for profitable growth that combine to imply a far greater probability of it occurring than Mr Market might realise.

Not all aspects of TSMC strengths we have discussed. We hope investors will find more of them in the R+A and other links we provide. One that talks to its process power and moat is that a high proportion of its COGS are either from the depreciation of assets (likely elevated as todays spend is for tomorrow’s production) or labour. Access to these hard and soft assets are crucial to TSMC’s continued dominance in this field. Reading about the scale of its highly specialised workforce and the supply contracts it has with the likes of ASML shed more light onto the size of its moat.

Just a word on politics

Clearly there is much that can be written on the political risks that exist for Taiwan and its incumbent companies. Most of it is idle and pointless speculation. We will observe only the following:

The China/US/Taiwan issue has existed for many decades. That a sort of war of words has recently occurred does not mean conflict is inevitable. Cleary risk is priced most highly when the noise is the greatest (ref hurricane insurance costs post storms).

A table on page 141 of the Annual Report shows TSMC’s importance to the US economy. 64% of its chips are sold to US end company users. This fact, the 2021 semi shortage (and the damaging effect it had on supply lines) and now significant political intervention in this sector leads to a simple conclusion. Microchips and their supply are today a crucial and critical infrastructure provider to the US and whole global economy Whilst this suggests risk/implies it could be leveraged if controlled, its pivotal importance might also result in politicians of any persuasion stepping back when the true knock-on economic consequences are explained to them of any hostile action…?

Despite trade wars and tariffs in recent years, global commerce is still hugely inter-linked, particularly so in the technology sector. We look for win-win outcomes in companies we like to own. By contrast aggressively interfering with TSMC and/or Taiwan looks like a lose-lose outcome for both China and the US. We suggest/hope that TSMC’s pivotal importance might make all think twice about their political actions.

On supplier politics we note the US is putting pressure on the main Dutch and Japanese companies that supply TSMC to stop supplying machines to China. Whilst we need to be careful that such actions don’t have a knock-on trade war type consequences it is notable that these actions make life far far harder for any TSMC would be competitor based in China to establish any sort of foothold. That TSMC tries so hard to retain its China/US neutrality is notable. That it benefits from any US/ASML export ban without being in any way connected to them is interesting. This we note is an industry where getting behind for a year or too almost risks extinction. Even were US advanced microchip sanctions to one day be reversed the damage to any possible TSMC competitor would already be done.

Chip Wars by Chris Miller gives great insight into this area. We thank client X for recommending it to us. The author has also discussed the book and the topics it covers in a few podcasts

Turning pages

When I started looking at TSMC a few weeks ago I was reminded that a Far East investment manager I respected a great deal owned the shares. I listened to Richard Lawrence present at a conference a few years ago and thought his thinking exceptional. When I heard he had a book out I made sure to order it. It arrived in the summer and I made a start. For whatever reason I put it down a third of the way though intending to return. Knowing he has been a long time TSMC fan I thought I should pick it up again. I did last week and found my reward in the last chapter. Not only did he lay out his view on TSMC. He also shows a letter he wrote to Buffett in 2007 outlining why he thought Buffett should invest in TSMC! If Warren has heeded this 15y year old advice we do hope he has written back. Sometimes as Warren says you just have to keep turning the pages and see what you find. The Model by Richard Lawrence is an excellent book which we highly recommend.

In short

It is not our intention to reduce one of the world’s most technologically advanced companies into a Ladybird guide. Accepting the complexity of what TSMC does is part and parcel of seeing just how strong their market position is. The two are inter-linked. That said whatever a company’s product or service complexity its financial model outputs are the same the world over: cashflow. Understanding how future cash will flow, be re-invested and with what confidence is the great skill Buffett has used across geographies, sectors and owned businesses or investments. That is all our job is too. We conclude from our work on TSMC so far that its future cashflows will be far stronger for far longer than Mr Market is today assessing. We gave estimates of potential intrinsic value growth rates earlier. If any of these are accompanied by a thawing of US/China/Taiwan relations Mr Market might change his view of this remarkable company by quite a jump.

Kind regards

Andrew Hollingworth


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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.

You agree to indemnify and defend Holland Advisors, its affiliates and licensors, and the officers, directors, employees, and agents of Holland Advisors and its affiliates and licensors, from and against any and all claims, liabilities, damages, losses, or expenses, including legal fees and costs, arising out of or in any way connected with your access to or use of this website and the Information.

Use of Cookies
If you agree to these terms and conditions a “cookie” might be placed on your computer. A cookie is a packet of information that does not identify individual users of a website, but allows the collection of website activity (such as the number of users who visit our website, the date and time of visits, the number of pages viewed, navigation patterns, what country and what systems users have used to access the site). We can use this information for statistical purposes, which allows us to analyse and improve our website. The cookie will expire automatically after 6 months or you can manually remove cookies in your browser settings.

Copyright, Trademarks and Other Rights
Copyright, trademarks, database rights, patents and all similar rights in this site and the information contained in it are owned by Holland Advisors or relevant third party providers. You may use the Information and reproduce it in hard copy for your personal reference only. The information contained herein and any supplemental documentation provided is confidential and should not be copied, reproduced or redistributed without the prior consent of Holland Advisors.

Governing Law
You agree that your use of this site and any dispute arising from this use is subject to English law and you submit to the jurisdiction of the Courts of England & Wales.

Privacy Notice

This is the privacy notice of Holland Advisors London Ltd our company number is 07431314. Our registered office is at 7 York Road, Woking, Surrey, GU22 7XH.



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

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


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

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

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.