Jul 2024: Wise Plc – Mr Market’s archenemy

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Wise Plc – Mr Market’s archenemy

July 2024 (756p)

 

Those wanting an introduction to what Wise plc does and Holland’s assessment of its operations line by line will be disappointed by this piece. We love finding new ideas, researching great businesses and thinking hard about the models they use. Our days of regurgitating much of what such companies spell out in their financial reporting is however behind us.

We are delighted that our research readers have become highly knowledgeable investors in their own right – they now know what we seek. As a result, this piece is for those already well versed in our approach/writings. We start with a word on the importance of pattern recognition. We then share a small businessman’s story of FX frustrations. Finally, we make some observations about Wise including a discussion of Mr Market’s archenemy… deferred gratification.

Pattern recognition

More and more we see this job as pattern recognition. Having studied hundreds of businesses, we now know what we are looking for pretty clearly. If we have to work too hard to polish the rock in front of us, chances are it is not a diamond. Precious stones tend to be obvious quite early on to the trained eye. That was our assessment when looking at Nubank earlier this year and we are delighted to report that we are coming to a similar conclusion on Wise plc.

Available on request are Wise’s last two R+A with our scribbles all over them. We could spend a week lifting many of the right messages out to craft a 30-page note recommending the share, but we will resist. Instead, we will shortcut the process and recommend readers look at these documents and listen to the company’s results call here themselves. Hopefully you will quickly read/hear many echoes of Holland past work on lowest cost producers. Also, on ‘Counter-positioning’ and ‘Scale-Economic-Shared’ business models. Much of what we have observed in our Netflix, Amazon and Nubank work we think is very relevant to any assessment of Wise. A few appropriate extracts from these pieces are shown below.

Counter-positioning

Sometimes it is hard to remember where you first heard something. We had read about counter-positioning before reading 7 Powers, but the book’s work on it we thought useful. We have certainly seen a great deal of real life counter-positioning via the challenger businesses we follow in Ryanair, JDW, Amazon, Schwab etc. 7 Powers articulates well the common traits that these businesses often display and how they impact incumbent players. Helmer brilliantly refers to the five stages of how incumbents react to counter-positioning. They are listed below:

      1. Denial
      2. Ridicule
      3. Fear
      4. Anger
      5. Capitulation (frequently too late) Source: 7 Powers, Hamilton Helmer

These are excellent and so true. Your author as an ex-airline analyst saw these close at hand when British Airways or Lufthansa was often asked about Ryanair in its early days. Denial and Ridicule were common. With Ryan’s intra-EU market share now at 16%, such companies are at the capitulation stage! Whilst we did not hear Blockbuster answer questions about early-stage Netflix, we can only imagine their replies were similar. Denial, Ridicule, then in their case bankruptcy.

Power Progression

The second area of Helmer’s work we think appropriate to highlight for Netflix is what he describes as ‘power progression’. This is his way of thinking how a Sustainable Competitive Advantage (SCA) is being developed. Holland’s approach has been to look for a SCA of some form and also the presence of owner managers. Helmer links the two. For many years now we have watched great owner managers innovate and pivot businesses. Helmer rightly describes “Innovation as the first step to gaining some sort of power.”

Whilst this is not rocket science it is a useful mental tool as we see the best owner manager’s change and adapt to new market positions. What they of course are looking for is a SCA in the future environment. We have now seen more than a few owner managers make such transitions. We have also seen Mr Market often terrified of the potential consequences during such a period of flux. (Next moving online, Facebook’s Meta/AI investment, Frasers stopping discounting++).

Source: Holland Advisors: Netflix – The Discovery Channel, April 2023

A Snowball…

An investors job in such a situation is not to re-invent the wheel. Instead, it is to assess whether the business in front of them is powerful and if so, to then think logically about what might happen next in its rollout. To be considered a “Snowball” in investment terms you need to possess a few traits that make the superiority of your business model over peers self-evident. Not exclusively these traits will likely include:

      • Lowest unit cost
      • Differentiated product
      • High customer centricity
      • A financial model that affords growth (i.e. good ROIC)
      • A visionary owner manager that knows what levers to pull

More succinctly put you need to be a horse (business model) of an exceptional standard who is being ridden by a great jockey (manager).

Source: Holland Advisors: Nu Holding – A snowball at the top of a long wet hill, June 2024

Imagine an amazing dinner party

Imagine an amazing dinner party. Seated around you are Peter Lynch, Jim Collins, Nick Sleep and Phil Fisher. Charlie Munger is of course at the head of the table. These are the giants on whose shoulders we stand and often we reference our learnings from them. As you join us researching Wise, imagine these five only discussing Wise Plc for an hour or two. Each, we think, would find a powerful trait to like about it…see if you can spot all five. Oh! and Hamilton Helmer popped by too!

A Story

Here is a story of frustration and opportunity.

“I am better businessman because I am an investor and better investor because I am a businessman” Warren Buffett

Your author started his own company many years ago now (c.2008). In doing so he became a sole trader in an industry where almost all his peers worked for large organisations. This (very) small company status allowed the true analytical independence he sought, but it came with a great many other frictions. Compliance, Companies House registrations, accounts, payroll and VAT are just a few. Business banking and FX are another. Holland Advisors is Sterling based but receives and makes payments in US dollars (e.g. Bloomberg only accept dollar payments from UK clients despite charging c.£30k pa!) Separately from his day job your author is lucky enough to have personal investments overseas and a house in France (with a Euro mortgage). This means he has lots of insights into currency transfers in the personal and small business banking areas.

Small business banking has many hidden fees and frictions around FX. What is particularly galling is that true FX spreads are tiny, and the cost of execution is virtually zero. As such bank charges in such areas are just them gouging their sticky customers for providing what is actually a risk-free service. All banks only really want your main small business account, and even your core bank will often not offer a deposit or a non-home currency account. (We asked ours a few years back for a dollar account. They just said ‘no’). If banks do offer extra accounts, these can come with sizeable charges. Companies like Caxton exist and can be used for better FX rates, but this means that transferred monies are either not coming from or being delivered to the small businesses/individual’s account. As a result, those (other banks) making or receiving payments will often not accept them from an intermediary (like Caxton) whom you are using to save on FX spreads. The result is that you are forced to accept and make payments from your local currency, thus incurring inflated spread and fees.

Interestingly the same restrictions exist more and more at the individual level also. Two years ago, your author sold some US$ based shares with a wealth manager. Planning to invest in something else in Dollars he asked the wealth manager to transfer these monies into a personal Dollar account (which had taken him quite a while to find and open!). The wealth manager refused – despite all investments and bank accounts being in the authors’ name. The reason given: “There is only one bank account nominated to these investments and that is the Sterling one”. The result was your author incurred two expensive Dollar/Sterling FX transactions to appease money laundering/wealth manager imposed rules.

The same money laundering rules were given when you author tried to repay part of a Euro mortgage. His domestic bank refused to disclose the rate (or spread) they would offer until he started the transfer. Additionally, the receiving bank insisted he prove (for money laundering purposes) where the funds had come from. They would then only accept delivery from that source, i.e. the Sterling account.

In short, your author is fee aware when investing or using banking services both in his business and personally. Particularly so when using services that he knows are zero risk and zero cost to the bank (FX vs say a personal loan).

Whilst he is lucky that the investment sums in his home and business life are larger than they were vs say 20 years ago the level of friction he incurs is enormous and far greater than the past. (e.g. 20y ago NatWest enabled him to have personal Euro and Dollar accounts for no charge. NatWest closed all of these in its post-2008 cutbacks).

We suggest personal/small business banking FX frictions are likely due to:

  • Tough money laundering regulations that make life logistically much more difficult for ordinary citizens and the banks
  • Banks/wealth managers, who have seen other profit pools disappear, being canny about protecting others (of which Treasury and FX are less visible to the client)
  • Domestic banks/wealth managers with sticky customers have not sought to help clients with the issues that arise from FX and money laundering. Clearly, they see such rules as a way to re-enforce the status quo to protect risk free profits made at the customers’ expense
  • Existing banks use old, slow, expensive systems and don’t specialise in FX thus have low volumes making them doubly inefficient
  • It is interesting that in a world of digital banking, FX functionality at big banks is worse than it was 15 years ago
  • Clearly into this void companies like Revolt, Monza and Wise have found easy pickings
Imagine

Part of this investing job is jumping forward a decade and imagining what life, businesses and customer experiences will be like. Then working your way back from that. (NB: It is crucial that any such future assessments are based on a logical extrapolation of today’s offerings rather than crystal ball gazing). Investor experience in the last decade in sectors like entertainment (Netflix) and online shopping (Amazon) are good examples of this need to ‘imagine’. Ten years ago, extrapolating the future of such industries and companies was not an easy task, but it was possible. It was this type of thinking and a little pattern recognition that led to our recent enthusiasm for Nubank.

Here is a business offering a Mexican deposit account with 15% interest rate vs competitor offerings at 4% (Base rate is 12%). Whilst in time Nu’s deposit rate will likely fall to 8-10% it will still dwarf what incumbent banks are offering. It is doing this using its scale and very low unit costs, sharing those with customers via generous deposit rates. Whilst many might see this as unproven Nubank won 80m Brazilian customers using this disruptor model. This suggests to us something new and powerful might be emerging. By their droves, and word of mouth customers are flocking to it.

Our enthusiasm for Nubank is that we can see a potential revolution in its customer offering vs sleepy, fat banking incumbents – who for years used customer stickiness to maximise profits.

Enter Wise Plc

Everything we have read about Wise as we have researched it, suggests something similar is happening here also. If Nubank is tackling the inflated branch cost structure that customers no longer wish to pay for, Wise is targeting the greedy risk-free, opaque FX pools of profit that banks quietly pocket at the expense of their loyal customers.

This company was founded by those who experienced the same unnecessary costs and friction we have in riskless home and work FX transactions. As a result, they set about trying to:

  1. Reduce the friction of such transactions by building their own (now hard to replicate) network
  2. Reduce the cost of such transactions, passing on their economies of scale where they can in ever lower fees charged to customers (see recent price cut)
  3. Embarrassing the main banks by highlighting the hidden spreads and charges they make. In contrast making their own fees super-transparent off middle market FX pricing

This is classic disruptor behaviour. Wise looks to be a classic ‘7 Powers’ counter-positioning disruptor, who is building a powerful a hard to copy scalable network. They look already to be one of the lowest cost providers of FX. Also, they are passionate and determined to use the economies of scale their model has created to share with customers lower prices and better services. This evolution of the business model is the power progression we wrote about in our Netflix piece. The company is moving from one Sustainable Competitive Advantage to another as it grows.

Disruptor > Network Economics > Scale Economics Shared

We have written much on all these traits and hope those reading up on Wise find them self-evident quite quickly.

Deferred gratification

Its obvious that deferred gratifiers do well over the long pull, versus those impulsive children who have to spend on Rolex watches, or other folly.

People are either born deferred gratifiers or they are not, and recent scientific work has been done to prove that. Charlie Munger: https://www.youtube.com/watch?v=-QobRyiXFl4

We will not discuss our views on deferred gratification once again. What we will say is how clearly it was on display in Wise’s recent results presentation. The company talks openly about the winners in the FX space being those with best and biggest end network.

“The market leader over time will be the provider of the cheapest, fastest, most convenient service with the broadest coverage. This will only be achieved by building the best global infrastructure, so we will continue to re-invest every year” Kristo Käärmann, Wise CEO and Founder, June 2024 analyst meeting

When asked about price elasticity the company are happy to accept that they do not know what it is like in the short term, but longer-term price reductions are the lever to drive future growth.

  • “We see the biggest driver of the business as new customers…
  • “The biggest driver of new customers is word of mouth/recommendations…
  • “and the biggest driver of recommendations is the fact that we are so much cheaper and more transparent than the banks or anything else that is available”

Kristo Käärmann, Wise CEO and Founder, June 2024 analyst meeting

The company is giving back to customers almost all the recent operational gearing its network has delivered. This is evident in:

  1. The price cuts it just announced for FX transactions
  2. The guidance it has reiterated with investors for 13-16% future underlying PBT margins, i.e. much lower than those just reported (c.40%)
  3. That its long-term revenue growth of 15-20% is net of price reductions, i.e. it expects volume to grow at a faster level, but ongoing price reductions will reduce reported revenue growth
  4. Its actions on current accounts to pass back to customers the bulk of interest Wise earns on their balances.

For a banking sector analyst all this giving away of profits might be hard to comprehend. Indeed, why on earth would a company give up jam today for an uncertain future level of growth. Especially when optically, there is no improvement expected in future growth as the company has not changed the forecasted growth rates it still expects….? We think we know the answer to that open-ended question. Such re-investment ensures future dominance and crucially a lack of fade in the growth rate. These two traits we see often in our best Scale Economy Shared businesses.

Lack of fade

“…the fact that a firm is quite large already does not necessarily tell you that its growth rate is set to slow. The widely held presumption that regression to the mean begins the moment the analyst picks up their pen, risks being wrong footed as a result” Nick Sleep, Nomad Partnership letters

The lack of fade in growth is the unseen powerful driver that never makes it onto any analyst forecast of a growing business, despite such company’s re-investment for that exact purpose.

This we think is at the forefront of Wise’s owner-manager minds when they chose to reduce profit margin forecasts to again further reduce customer prices. Mr Market clearly did not see things that way which its why the share price fell. Valuation aside, this suggests to us opportunity as the wider investing market clearly doesn’t understand the re-investment model the company is pursuing. Ergo, it also doesn’t understand the likely ongoing high levels of sustainable growth that such a course of action points toward.

Operational gearing

Markets love positive operational gearing (i.e. when more profits end up being made for the same level of sales). By contrast they hate investment periods that reduce profits, often marking the shares down as they did with Wise a few weeks back. Whilst some profit falls resulting from investment are genuinely bad news, others can be the opposite as today’s profits are being reinvested clearly to drive loyalty, a differentiated product/service and thus ultimately more growth in the future.

Those who feel inclined can overlay Amazon’s EBIT margin onto its share price chart. For all of investors detailed understanding of that company, its shares are still marked down every time an investment phase comes along (2013-2015 or 2021-2022). As Munger says ‘it is really hard’ to get the deferred gratification idea in your head; either you have it, or you don’t. Those that do think on different time frames often make outsized gains when the delayed end point finally arrives.

To listen to Wise recently explain why it is reducing prices and the analyst questions that followed was fascinating. As we stated above this is clearly a company that understands the outsized gains that will be made by the dominant future network in this sector. To have the greatest chance of Wise being that company, now is clearly a time to invest, thus ensuring a powerful cycle of more scale, lower unit costs, and more potential re-investment. Many investors and analysts seemingly just want jam today.

An important long-term understanding for Wise investors we think is to realise that it will probably not always be this way. Investment today and for the next 5-10 years is right if building an unrivalled FX network. But we suggest it will create positive operational gearing that will be too great one day to all be re-invested.

As a precedent for readers to consider we show Netflix’s historic EBIT margins below. After decades of investing to establish a dominant industry position, powerful operational gearing has now emerged. This is shown below and in the recent Q2 results that reported a 28% EBIT margin! This is occurring whilst delighted customers still feel they are getting great value. High gross margin network businesses that end up dominating their space with scale end up being high EBIT margin businesses we observe. But the best, most resilient ones are very, very, slow to get there. Wise gave us just a glimpse of this future operational gearing in March 2024 with 40% margins!

Fig.1: Netflix historic EBIT margins

A graph of orange bars Description automatically generated Source: Bloomberg

Network power

Whilst no two businesses are the same, Wise reminds us of Netflix a little. The network build is crab like, part owned, part third party. Third party functionality (Netflix bought in content?) is a way to give customers what they need today. A developed owned network, that has end-to-end connections as Wise has established in countries like UK, Australia and now Japan, is time consuming and hard to build. But it creates a more powerful long-term customer offer and a more powerful, scalable low unit cost network. One that is also resilient to outside challengers (analogous to Netflix In-House content?).

We think the fact that Wise now has many partner banks who are using its wholesale platform is a telling revelation. Clearly these banks know this industry well and have concluded that Wise is a better, cheaper alternative to the existing networks they used before. This platform arm of the group also gives it potential massive leaps in scale, thus lowering further unit-costs. This is a powerful scale driver that the likes of Monza or Revolt, if only retail customer facing, cannot match.

Why here?

As an aside we think it interesting that all these FX businesses have been built in Europe/UK. The USA is a wonderful market to expand a business in, but it does not have a money transfer problem. Europe does, especially with many overseas workers from inside or outside the EU/UK. As we observed in our story above, money laundering type regulations have been used to re-enforce many of the barriers to entry/innovation that were already in place. In short Europe needed a money transfer solution 10y ago, so a few emerged. Who dominates ten years from now however we think will be a function of:

  • Who achieves greatest scale to ensure the lowest unit-costs
  • Who re-invests the most offering best service and value
  • Who solves customer problems (like money laundering)
  • Also, who consumers end up trusting the most.

From our limited work on Wise and its competitors thus far, Wise score highly on these metrics.

In the many podcasts we have listened to with the founders of Wise being interviewed a few other points emerged. The first was customer trust.

Trust

Wise very early on stumbled across the importance of fee transparency, i.e. it was not about the absolute cost of an FX transfer for customers, it was that the banks were hiding these costs in fake FX rates. They still are! By disclosing spot rates and fees separately the company has built great customer trust. Its ongoing fee reductions clearly re-enforce that further. Its actions now to return c.80% of account interest income to consumers will add another level of trust we suggest.

Wise was founded by Estonians. It was a new country (post USSR break-up) with new digital banks and a well-functioning mobile telco network. Unlike established EU countries it did not have a long-in-place banking system that needed to be bypassed. As such the founders could see how the FX transfer system could and should work. This reminds us of the work we did on Spotify – how Scandinavia’s huge early investment in home computer and fibre networks laid the foundation for music streaming’s development and ultimately Spotify’s early mover advantage.

Jim Collins meets Phil Fisher

Attached to this note is our one page summary of Built to Last, by Jim Collins. The cultural traits he outlined are powerful and clearly visible when researching Wise. The company is mission led with a strong core ideology and clear staff buy in:

“Everyone who joins has to be aware that this is what they are getting involved with” Kristo Käärmann, Wise CEO and Founder

There is also some interesting product evolution happening at Wise. Some years ago, we studied Next through Phil Fisher’s eyes, noting the importance of internal innovation (Online, Label, Total Platform). “Can a business build new growth legs organically?” This was the question Phil Fisher asked of a growth company some 60 years ago. The same question is still very instructive today.

Wise’s expansion into accounts, cards and a wholesale platform are all new in the last few years. All look to be powerfully resonating with very different customer bases (individuals, small business and large banks) and doing so across many geographies. Each of these products and their potential reach is exciting to consider. What is more impressive still is the innovation culture that saw each emerge and grow. We think Phil Fisher would approve.

Fig.2: Wise Plc. A Truly global company

A graph of income by region Description automatically generatedSource: Wise Plc Investor Presentation, June2024

Such innovation and breadth of product offering by client and geography we think have some powerful impacts on the sustainability of growth. In turn this has implications when investors assess the price they might pay for such a company.

A ‘real’ Robin Hood account

The specifics of how Wise has approached the economics of its client accounts we think interesting and further revealing of its culture. This NIM investment line was not one the company foresaw at its flotation only c.3years ago as interest rates were so low. However, that changed post-global interest rates rising. Rather than pocketing the resulting interest income Wise earns on cash customers are happy to leave with Wise, it has found a targeted way of sharing these economics with customers. Wise will keep the first 1% earned on clients’ assets to cover costs. After that it will split the rest 80/20 in the customer’s favour. As a personal and business banking customer this is just remarkable to read. This company is trying to save me money in the annoying/expensive world of FX transfers (both large and small). They now also will share with me the economics they earn from my money held with them. The is Scale Economics 101.

Fig.3: Wise Plc 2024: Profit pools and re-investment – much more to come

A graph of a bar graph Description automatically generated with medium confidenceSource: Wise Plc Investor Presentation, June 2024

Our excitement for Nu Holdings comes from seeing them deploy the Scale Economy Shared model in Brazilian and Mexican banking markets and the long-term resulting in customer wins that we think will come from such actions. Wise is doing exactly the same thing in its FX fees and bank accounts. In time we think customers will love such actions and will reward the company handsomely with strong growth.

That the company had to think about its financial model in a whole new way to manage and reinvest these free profits that turned up when interest rates rose is impressive. It speaks to a nimble management team, that is hungry for innovation, but true to its customer centric core principles. That such changes make the company a little harder for analysts to model we welcome as we think that can create an investment opportunity.

Fig.4: New layout – same SES story!

A diagram of a company Description automatically generated Source: Wise Plc Investor Presentation, June 2024

We are pleased to see the company invest heavily in network development, product R+D, customer service and of course lower prices. Analyst questions seeking to model near term operational gearing miss this point – badly.

Evangelical customers & investment

Two thirds of the company’s new customers come to them by word of mouth. We have often repeated that we like companies who want to ‘delight customers’, creating ambassadors for themselves. Wise clearly already has that status.

Fig.5: Evangelical customers do all the selling

A graph of a customer Description automatically generated Source: Wise Plc Investor Presentation, June 2024

Evangelical customers are very different to those who get some sort of kick back from a referral. Wise has the former with word of mouth spreading about how cheap/good its service is. Often such word of mouth referrals happen in a single country. For Wise to be experiencing this globally points to how well its offering travels and resonates. With this and customer experience in mind the company is rightly focused on investing hard and clearly trying to make sure new customers that discover them are wowed and the word of mouth referral cycle keeps turning.

Truly global

Wise today now offers great value innovative products and is profitable on a global scale. These are powerful drivers when combined and we think extrapolatable (#ref Peter Lynch…). Investors will see many businesses with large TAM’s and small current market shares. Rarely are these market shares truly global in spread we observe. Wise is Proven, Profitable and Probably likely to keep growing with good returns from here. Some UK, US based investors, might not see the enormous friction that still exists in money transfers in almost all emerging economies. Wise could be a very powerful network for such economies poised for strong secular growth.

Wise Plc’s earnings power

Wise reported PBT of £481m (PAT of £355m) in the year to March 24. It also disclosed underlying revenue and PBT of £1,176m and £242m respectively for an implied 21% margin. With more price re-investment occurring post year end, this underlying PBT margin is guided to be 13-16% in future years. Underlying revenue is also guided to grow 15-20%.

These growth and margin measures having not changed since the IPO in 2021. The share price fall that followed was investor’s reaction to the company choosing to re-invest its huge operational gearing back into the business rather than pocket it. This, we think, is Mr Market vs a Deferred Gratification fight in real time! Indeed, the difference between a 41% PBT margin (£481m) and a 13-16% is a huge gap.

How we think about Wise’s long-term earning power

Wise could easily carry on with the high profit (41% margin) model and still be successful. The investment it is making is thus highly discretionary, but clearly being undertaken to ensure strong future growth. It is also being made by highly aligned long-term focused owner-managers. They clearly see such investment as accretive to the business’ intrinsic value. That said they are not dreaming up faster volume/new customer growth rates to justify such spending even if they think them possible. The periods of higher margins Amazon made in its past (c.5% in retail) and of depressed margins during heavy investment are instructive. The higher margins can be a useful look through benchmark of what such businesses can earn in a more steady-state environment, nearer end games of scale.

We showed earlier what is now happening to margins at another network asset that has found a true scale advantage (Netflix). We would also note that Wise, as a high gross margin digital only business in time will very likely see high operating margins also. The year end March 24 was just a taste of that before the investment spigots were turned back on. Indeed, the company openly admit to the business having significant operational gearing when at scale.

Wise’s account policy of returning 80% of interest income over 1% we think a brilliant innovation and could be very powerful in driving future growth. We also think it will provide a constant boost to the group’s reported profits over and above the underlying profit they are targeting. We will discuss this issue with the company, but for now think the 6% (£73m) lift in PBT margin in March 24 that came from its 20% share of interest income a useful guide. If an investor thinks interest rates are now at/near new normal levels (as we do) then this additional earning will be a constant feature for the company.

Some numbers – Earnings power 1

Simplistically therefore we will pick the following metrics on which to assess Wise:

  • 25% pa revenue growth as we think volume growth will be stronger than forecast
  • 15% underlying PBT margin (company range of 13-16%)
  • +5% boost from ongoing excess interest income
  • = Look through PBT margin of 20%

Using these metrics and looking out to March 26 and March 27 after a 25% tax rate, results in net income of £275m and £345m respectively. (£1.17bn x 1.25 x 1.25 x 20%/0.75 = £275m).

In turn resulting in PE’s of 24x and 19x (if we knock off £1bn of excess cash from the £7.7bn M.Cap). Arguably this is a reasonable proxy for the sort of profit numbers the group might actually report on these dates, albeit we have picked a faster growth rate to try for a little more realism we think.

Some numbers: Earnings power 2

But like a Netflix, or Nubank, should we not make some adjustment for our belief that one day, end game margins will be higher. It is clear the group is investing very heavily. Price cuts and 24% of staff (£100m) working in product development are clear evidence of that.

As such we observe:

  • Considered vs the £481m profit just reported the company is valued at 18x PE ex-cash
  • If in March 26 and March 27 we used a 30% look though PBT margin, rather than our 20% one the resulting PE’s would be 19x and 13x respectively

Another way to consider the company is through our ‘Put up more to make more’ model (PUMTMM) or Supernatural Compounder lens. The company just reported a Return on Equity of 42%. The year before it had an ROE of 22%, when its reported pre-tax margin was at 17%, i.e. closer to its longer-term underlying target. This suggests its likely earnings power in ROE terms, in the coming years could be somewhere between these two levels. As such the group might earn an ROE of 20-30% and compound at that rate.

Crucially the company has both the products, customer trust, geographic reach and management team to keep deploying more capital at equivalent rates. I.e. it has very very long runway of potential growth ahead. Indeed, when the company was recently asked about capital allocation and dividends by an analyst, they responded that they saw ample opportunity to reinvest all cashflows back into the business for a long time. We agree with both this course of action and welcome the mindset that drives it.

Valuation – Art not science

Price is what you pay – value is what you get” Buffett

Our thinking following all this is as follows: Wise shares look to be trading somewhere between 15-25x the best guess we can make of the group’s look through earning power c.2years from now. That is the price we are being asked to pay.

Whilst no bargain we don’t think this price is outrageous vs the value we get in return. We will own a part share in a powerful disruptor business model that exhibits almost all the traits we seek. Multiple sustainable competitive advantages, aligned owner managers with a drive for growth and passion for innovation and powerful re-investment opportunities. All this with a starting ROE of 20-30%. As such c.20-25% pa growth in annual intrinsic value look very plausible, rather than rose-tinted.

We remind readers of the observations we made in our super-natural compounder piece. If look though multiples hold for ten years and a 20% grower can keep deploying capital at that rate, your investment is worth 6x what you paid for it today in 2034. At 30% its worth 14x today’s value.

For the chance to be part owner in such a compounding machine we are very happy to pay today’s starting prices. This is our first assessment of Wise plc having only looked at the company for a few weeks. We have much more to learn, we are sure. However, like Nubank we might decide to keep learning whilst being an owner, rather than just an observer…

With kind regards

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.

Disclaimer

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.

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Welcome to Holland Advisors

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Terms and Conditions
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Please confirm the following Please confirm that you have read and understood the following terms of use of this website. THIS PORTION OF THE WEBSITE IS ONLY MADE AVAILABLE TO NON-US INVESTORS AND PROFESSIONAL CLIENTS OR ELIGIBLE COUNTERPARTIES. The content of this website has been prepared by Holland Advisors (London) Ltd on the basis of information and sources believed to be reliable. Under no circumstances should any part of this website be construed as an offering or solicitation of an offer for any investment in the products on this site Holland Advisors (London) Limited is authorised and regulated by the Financial Conduct Authority (FRN 538932). 1. Not for U.S. Persons The provision of the information in this website does not constitute an offer of securities to any person in the United States or to any U.S. Person as such term is defined under the Securities Act of 1933, as amended. The information contained in this site about Holland Advisors (London) Ltd is not directed to any person in the United States. Funds referred to herein are neither registered under the Securities Act 1933 of the USA, nor are they registered under the Investment Company Act of 1940. Consequently, they cannot be offered for sale or be sold in the USA, its territories, possessions or protectorates under its jurisdiction, nor to nationals, citizens or residents in any of those areas. No investments or services mentioned on this website are directed at US Persons who are not Eligible Counterparties as defined by the UK Financial Conduct Authority (FCA) Handbook or Qualified Purchasers as defined under the Investment Company Act of 1940. The information contained herein does not constitute a distribution, an offer to sell or the solicitation of an offer to buy any securities in any jurisdiction in which such distribution or offer is not authorised. 2. Terms and Conditions of Use IMPORTANT LEGAL NOTICE THE FOLLOWING TERMS AND CONDITIONS OF USE (“TERMS OF USE”) APPLY TO YOUR ACCESS TO AND USE OF THE HOLLAND ADVISORS (LONDON) LTD WEBSITE (THE “WEBSITE”). EACH TIME YOU ACCESS OR USE THIS WEBSITE, YOU AGREE TO COMPLY WITH, AND BE BOUND BY, THE TERMS OF USE AND ACKNOWLEDGE THAT WE MAY RELY UPON YOUR AGREEMENT. PLEASE READ THE FOLLOWING TERMS OF USE CAREFULLY AND IF YOU DO NOT ACCEPT ANY TERMS OR CONDITIONS, PLEASE DO NOT ACCESS OR USE THIS WEBSITE. 3. Information on the Website Except where stated otherwise, the information, content and services on this Website (the “Information”) are provided by Holland Advisors (London) Ltd (referred to as “we” and “us”) as at the date indicated on the relevant material. The Information is provided for personal use and information purposes only. The Information does not take account of the investment objectives, financial situation and particular needs of any particular person and is not general advice to any class of persons. Therefore, you should not rely on the Information and should obtain relevant and specific professional advice in making any investment decision. Furthermore, nothing on this Website constitutes or should be construed to constitute: (i) an offer, advice, invitation or solicitation from us or our affiliates to buy or sell any investments or securities, futures, options or other financial instruments; (ii) an invitation or inducement to engage in investment activity or a financial promotion of any kind; or (iii) investment advice or recommendation. 4. Stock exchange prices and exchange rates The prices/values shown on this Website in relation to different underlying securities are based on the prices notified to Holland Advisors (London) Ltd as the last sale price of the relevant securities on the stock exchange on which they are traded as at the time and date shown. Those figures may vary throughout the course of, and between, stock exchange trading days, market trading times and business days in general. Holland Advisors (London) Ltd has not verified the figures with the relevant stock exchange and you should verify the accuracy of those figures separately before relying on them. 5. Permitted users of the Website The laws and regulations of the country from which you access this Website may include restrictions on the distribution of the Information. This Website is not directed at or intended for distribution to or use by any person or entity in any jurisdiction where (by reason of that jurisdiction’s applicable securities laws, person’s nationality, residence or otherwise) such distribution, publication, availability or use of this Website or any part of its contents would be contrary to applicable law or regulation or would subject Holland Advisors (London) Ltd to any registration or licensing requirement within such jurisdiction. If you are such a person or entity, you are not authorised to enter the Website. It is your responsibility to ensure that your use of this Website complies with any restrictions or any applicable local laws regarding use of the Information on this Website. Persons or entities in respect of whom such restrictions apply must not access the relevant pages on this Website. The Information displayed on this Website contains material that may be interpreted by the relevant authorities in the country where you are viewing this Website as a financial promotion or an offer to purchase securities. Accordingly, if you reside in any such country or fall within the scope of any law that seeks to regulate financial promotions in the country of your residence or in the country in which you are viewing this Website, please cease accessing or using this Website immediately. If you are uncertain about your position under the laws of the country in which you are viewing this Website, then you should seek clarification by obtaining legal advice from a lawyer practicing in the country of your residence or in the country in which you are viewing this Website before accessing this Website. You may not use any part of the material or Information on this Website to establish, maintain or provide or assist in establishing, maintaining or providing a stock market for trading in securities. 6. Investment Performance and Accuracy of Information The Site contains material about the past performance of our Funds. The value of an investment in a Fund may go up as well down so that an investor’s investment in a Fund, when redeemed, may be more or less than the original investment amount. By its nature, investment in a Fund managed by Holland Advisors (London) Ltd is only suitable for sophisticated investors who do not require immediate liquidity for their investment, for whom an investment in a Fund does not constitute a complete investment programme and who fully understand and are willing to assume the high risk involved in the investment programme of a Fund. THE PAST PERFORMANCE OF ANY INVESTMENT, INVESTMENT STRATEGY OR INVESTMENT STYLE IS NOT INDICATIVE OF FUTURE PERFORMANCE. Whilst the information contained on the Website has been given in good faith and every effort has been made to ensure its accuracy, the Information may not be complete or accurate for your purposes. This Website and the Information is provided on an “as is” basis and Holland Advisors (London) Ltd may not, and has no obligation to, update the Information or correct any inaccuracy which subsequently becomes apparent. The Information and/or opinions and estimates comprised in the Information may be changed or withdrawn without notice and may become outdated. You, therefore, should verify any information or other material obtained from this Website before you use it. HOLLAND ADVISORS (LONDON) LTD, ITS DIRECTORS OR OFFICERS DISCLAIM ALL REPRESENTATIONS AND WARRANTIES, WHETHER EXPRESS OR IMPLIED, INCLUDING BY WAY OF EXAMPLE BUT NOT LIMITATION AS TO RELIABILITY, COMPLETENESS, FITNESS FOR PURPOSE OR ACCURACY OF THE INFORMATION ON THIS WEBSITE OR ON ANY THIRD PARTY WEBSITE LINKED TO THIS WEBSITE. IN ADDITION, WE DO NOT REPRESENT OR WARRANT THAT THIS WEBSITE OR THE SERVERS THAT MAKE THE WEBSITE AVAILABLE WILL BE UNINTERRUPTED, ERROR FREE, OR FREE FROM INFECTION, VIRUSES, WORMS OR ANY OTHER HARMFUL CODE WHICH MAY HAVE CONTAMINATING OR DESTRUCTIVE PROPERTIES. YOU ARE FULLY RESPONSIBLE FOR ENSURING PROTECTIVE STEPS TO BE TAKEN SUCH AS VIRUS CHECKING. The Information is assembled from material prepared by Holland Advisors (London Ltd) or its agents but may not include Information made known to Holland Advisors (London) Ltd officers (or agents) subsequent to the date of publication of the Information indicated on the Website. If you use the Information, you do so at your own risk. Please recognise that the previous performance of securities or other instruments does not guarantee or predict future performance. 7. Exclusion of liability TO THE FULLEST EXTENT PERMITTED BY LAW, HOLLAND ADVISORS (LONDON) LTD ACCEPT NO LIABILITY TO YOU OR ANY THIRD PARTY FOR ANY LOSSES OR DAMAGES, INCLUDING, WITHOUT LIMITATION, DIRECT OR INDIRECT DAMAGES, CONSEQUENTIAL OR SPECIAL DAMAGES, LOSS OF USE, DATA OR PROFITS, COSTS OR EXPENSES INCURRED OR SUFFERED BY YOU OR THIRD PARTY, WHETHER IN CONTRACT OR DUE TO NEGLIGENCE OR OTHER TORTIOUS ACTION, ARISING OUT OF OR IN CONNECTION WITH THE ACCESS TO, USE OF, RELIANCE ON, OR PERFORMANCE OF THIS WEBSITE OR ANY INFORMATION CONTAINED ON THIS WEBSITE, WHETHER DUE TO INACCURACY, ERROR, OMISSION OR ANY OTHER CAUSE AND WHETHER ON THE PART OF US, OUR SERVANTS, AGENTS OR ANY OTHER PERSON. NOTHING IN THE TERMS OF USE EXCLUDES, RESTRICTS OR MODIFIES ANY CONDITION, WARRANTY OR LIABILITY WHICH MAY AT ANY TIME BE IMPLIED BY STATUTE OR ANY OTHER APPLICABLE LAW WHERE TO DO SO IS ILLEGAL OR WOULD RENDER ANY PROVISION OF AN AGREEMENT VOID. 8. Third Party Websites We may provide, on our Website, links to websites operated by third parties as a convenience to you. If you use these other sites, you will leave this Website. If you decide to visit any linked site, you do so at your own risk and it is your responsibility to take all protective measures to guard against viruses or other destructive elements. Holland Advisors (London) Ltd makes no representations, warranties or guarantees of any kind about any of the content of any other website which you may access by hypertext link through this Website. When you access any other website by means of a link from this Website, you should understand that your access to that other website is independent of Holland Advisors (London) Ltd and Holland Advisors (London) Ltd has no control over the content of the website, nor does Holland Advisors (London) Ltd in any way endorse or approve the content of that website. In no event will Holland Advisors (London) Ltd in any way be liable to you or any other person(s) or organisation(s) for loss or damage (whether direct, indirect, consequential, special or other) for any use of any site linked to it by means of hypertext or otherwise. 9. Indemnity You agree to indemnify Holland Advisors (London) Ltd and its officers from and against any claim brought by third parties against Holland Advisors (London) Ltd and its officers as a consequence of your breach of the Terms of Use. Furthermore, if your use of this Website results in the need for servicing, repair or correction of equipment, software or data, you assume all costs thereof. 10. Intellectual Property Rights and Licence The copyright, trade mark or any other intellectual property rights in the Website and the Information are owned by or licensed to Holland Advisors (London) Ltd. You may download or print out a hard copy of individual pages and/or sections of this Website provided you do not remove any copyright or other proprietary notices. Any downloading or other copying from this Website will not transfer title to any software or material to you. You may not reproduce (in whole or in part), transmit (by electronic means or otherwise), modify, link to or use for any public or commercial purpose this Website without the prior written permission of Holland Advisors (London) Ltd. Any rights not expressly granted in the Terms of Use are reserved. 11. Operation of the Website You should be aware that the internet, being an open network, is not secure. If you choose to send any electronic communications by means of this Website, you do so at your own risk. Holland Advisors (London) Ltd cannot guarantee that such communications will not be intercepted or changed or that they will reach the intended recipient safely. 12. Privacy Any personal data relating to you will be collected, used and recorded by us in accordance with current data protection legislation, the Terms of Use and our Privacy Policy. You must read our Privacy Policy as it forms part of the Terms of Use. 13. Governing law The Terms of Use are governed by the laws of England and Wales and the courts of England and Wales will have exclusive jurisdiction over any disputes arising under them. 14. Waiver If you breach the Terms of Use and we take no action, we will still be entitled to use our rights and remedies in any other situation where you breach the Terms of Use. 15. Our details This website is owned and operated by Holland Advisors London Ltd. You can contact us at: Holland Advisors London Ltd, The Granary, 1 Waverley Lane, Farnham, Surrey, GU9 8BB. Updated and effective as of  31st March 2024
Disclaimer
Please read the following conditions of use of this website. This website is directed at high net worth experienced investors and institutional investors who understand the risks involved with the investments being promoted and it should not be relied upon by retail clients (as defined by Financial Conduct Authority). The information on this website is issued by Holland Advisors (London) Limited (hereafter referred to as “Holland Advisors”), a limited liability company (7431314) incorporated in England and Wales, which is authorised and regulated by the Financial Conduct Authority (FRN: 538932). This website is for information purposes only and does not constitute an offer or solicitation to buy or sell securities, funds or any other financial instrument. The information is directed inside the United Kingdom and is not directed at any persons in jurisdictions where it would be against local law or regulation.  In particular, information on this site is not directed at any person, partnership or corporation being resident in the United States of America. Holland Advisors disclaims all responsibility if you access or download any information in breach of any law or regulation of the country in which you reside. Information on this site The information provided does not constitute advice. Holland Advisors believes that the sources of the information in this website are reliable. However it cannot and does not guarantee, either expressly or implicitly, and accepts no liability for, the accuracy, validity, timeliness or completeness of any information or data (whether prepared by it or by any third party) for any particular purpose or use or that the information or data will be free from error. Holland Advisors does not undertake any responsibility for any reliance which is placed by any person on any statements or opinions which are expressed herein. Neither Holland Advisors nor any of its directors, officers or employees will be liable or have any responsibility of any kind for any loss or damage that any person may incur resulting from the use of this information. This does not exclude or restrict any duty of liability that Holland Advisors has to its customers under the regulatory system in the United Kingdom. All Information may be changed or amended without prior notice although Holland Advisors does not undertake to update this site regularly. Marketing Communications Documents on this site do not constitute investment research as they have not been prepared in accordance with UK legal requirements designed to promote the independence of investment research. Therefore, even if they contain research recommendations they should be treated as marketing communications and as such will be fair, clear and not misleading in line with Financial Conduct Authority rules. These communications are not personal recommendations to you and any opinions cited are subject to change without notice. Holland Advisors takes all reasonable care to ensure that the information on this site is accurate and complete; however no warranty, representation, or undertaking is given that it is free from inaccuracies or omissions. Documents on this site are based on, and contain, current public information, data, opinions, estimates and projections obtained from sources we believe to be reliable. Past performance is not necessarily a guide to future performance. The content of these documents may have been disclosed to the issuer(s) prior to dissemination in order to verify their factual accuracy. Investments in general involve some degree of risk, therefore Prospective Investors should be aware that the value of any investment may rise and fall and you may get back less than you invested. Value and income may be adversely affected by exchange rates, interest rates and other factors. The investments discussed on this website may not be eligible for sale in some states or countries and may not be suitable for all investors. If you are unsure about the suitability of an investment given your financial objectives, resources and risk appetite, please contact your financial advisor before taking any further action. Holland Advisors and/or its officers, directors and employees may have or take positions in securities, funds or derivatives mentioned on this site (or in any related investment) and may from time to time dispose of any such securities (or instrument). Holland Advisors manages these potential conflicts of interest internally via its compliance procedures. Fund Information Parts of this site may refer to Funds managed or advised by Holland Advisors. These are not solicitations to invest and any potential investors should refer to the “Our Funds” section of the website in order to learn more about these Funds and find out how and where to obtain the relevant full legal documentation. Linked Websites This site may be linked to third party websites or contain information provided by third parties. Holland Advisors does not make any representation as to the accuracy or completeness of such websites or information, has not and will not review or update such websites or information, and cautions browsers that any use made of such websites or information is at their own risk. Holland Advisors does not accept any liability arising out of the information contained on any linked website or Information provided by a third party and the use of such sites and information is at your own risk. This does not exclude or restrict any duty or liability that Holland Advisors has to its customers under the regulatory system in the United Kingdom. Indemnity You agree to indemnify and defend Holland Advisors, its affiliates and licensors, and the officers, directors, employees, and agents of Holland Advisors and its affiliates and licensors, from and against any and all claims, liabilities, damages, losses, or expenses, including legal fees and costs, arising out of or in any way connected with your access to or use of this website and the Information. Use of Cookies If you agree to these terms and conditions a “cookie” might be placed on your computer. A cookie is a packet of information that does not identify individual users of a website, but allows the collection of website activity (such as the number of users who visit our website, the date and time of visits, the number of pages viewed, navigation patterns, what country and what systems users have used to access the site). We can use this information for statistical purposes, which allows us to analyse and improve our website. The cookie will expire automatically after 6 months or you can manually remove cookies in your browser settings. Copyright, Trademarks and Other Rights Copyright, trademarks, database rights, patents and all similar rights in this site and the information contained in it are owned by Holland Advisors or relevant third party providers. You may use the Information and reproduce it in hard copy for your personal reference only. The information contained herein and any supplemental documentation provided is confidential and should not be copied, reproduced or redistributed without the prior consent of Holland Advisors. Governing Law You agree that your use of this site and any dispute arising from this use is subject to English law and you submit to the jurisdiction of the Courts of England & Wales.
Privacy Notice
This is the privacy notice of Holland Advisors London Ltd our company number is 07431314. Our registered office is at 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.