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Oct 2024: Wise Plc – The more we look, the more we like

October 1, 2024
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Wise Plc – The more we look, the more we like

October 2024 (670p)

 

This summer we researched and published our work on Wise plc. Post which we have now spent some time with the company’s IR/finance team. What follows are a few further reflections.

Lessons on customer obsession from the sage

As we have stated in recent pieces, we think a core tenant of this job as we get older (and wiser we hope) is pattern recognition. Indeed, this was how we framed/described Wise in our first piece.

Sometimes there is also a juxtaposition of events that occur prompting a researcher to think more clearly. The day after we spoke to Wise and were writing up our notes on the company, this interview by Buffett popped into one of our media feeds. Whilst we have seen most Buffett interviews before it is easy to forget things. This one we think particularly interesting for those assessing companies from a qualitative angle. In many ways it is more Nick Sleep in its messaging than traditional Buffett. Using Rose Blumkin (Nebraska Furniture Mart) and the founder of Enterprise rental cars as examples Buffett explains the importance of a highly customer-centric approach.

These examples are interesting because both are commodity industries (Car rental + furniture sales) so the only way to get any sort of lasting competitive edge was through a highly customer centric business model. We strongly suggest readers listen to this speech. The relevant section starts at the two-minute mark. Buffett summarises the power of those models by saying:

“You need a genuine desire day in day out to delight the customer. I’ve seen a lot of businesses, but I’ve never seen one that focused on delighting the customer that didn’t succeed.” Warren Buffett, emphasis ours

Wise reflections

We think this a nice preamble for what we are learning on our journey to better understand Wise.

The competitive environment

The biggest risk we see to Wise plc is that there may be others building similar networks with similar efficiencies being created as we write. With few competitors quoted and thus imperfect information available this is a hard area to get disclosure, and thus clarity, on. Our learnings in this area post discussions with Wise/our own further reflections are as follows:

  • Revolut’s focus is seemingly on expanding its banking product reach and on growing ARPU. It is not driven by a desire to build its own FX network, nor by any efficiency drive for lower unit economics that can be passed on.
  • Revolut’s pricing (i.e. FX charges) is at a similar level to Wise, but promotional, not EDLP in nature as Wise is. I.e. they are currently undercutting Wise by a few basis points ($/€ at 0.275% vs Wise’s new rate at 0.28%). But Wise do not think Revolut’s unit-cost base supports this, so assumes it is cross subsidising.
  • Revolut uses Currency Cloud for its outsourced FX. It was established in 2012 and is now owned by Visa. It handles roughly a third of the volume Wise does.
  • JPM/Citigroup have good, efficient global FX networks that their large corporate clients benefit from. Almost all other banks (HSBC included) have patchwork networks of old-fashioned connected banking relationships. These are inefficient and might mean an FX trade take a few days to be credited to the target account.
  • Businesses like Remity are more expensive than Wise and largely about cash delivery rather than Digital FX transfers.
Holland reflections on this

If we are extrapolating the success of the Wise Network, hoping for decades of c.20% compound growth then the greatest threat to that assumption is the Wise Network’s future lack of dominance.

  • The wholesale usage of Wise’s Network (i.e. by a great many other banks) we think

a) Gives it greater absolute scale therefore lower unit-costs

b) Also acts as a reference point for investors to its efficiency and network scale I.e. Monza, N26 and NU bank + large banks in Japan, Korea and Indonesia have decided to use the Wise Network. They have clearly concluded that this route is both better than their existing networks and something they cannot easily/want to build themselves

  • We learnt from our work on Grenke that having a network that can process credit transactions is one thing, but having one that can be profitable processing smaller transactions is a very very different proposition. Being able to be profitable with money laundering requirements on transactions at a value of c.£2,000 is very different to one that can claim to be efficient when handling £200k transaction sizes. Wise is profitable with these low FX transaction sizes
  • We suspect this is where any difference between a Citi or JPM and Wise Networks might lie in the future. Crucially a network that is efficient and profitable at small transaction sizes can be scaled for larger sums. It does not work the other way round
  • Separately, when larger global banks look to use networks outside of their own for better FX execution and cost whose are they going to use. We suspect HSBC, Barclays, Bank America et al would rather use Wise or Currency Cloud, not JPM or Citi, even if such networks were one day offered wholesale
  • As most banks take a 5-6% spread out of FX (2.5%-3% either side) we assume this to be a silent profit pool for many banks. But maybe it is not. Partly because the banks only have old systems and processes that require manual inputs and checks to follow up on any delivery delays. Also, because they are not specialists is this area so likely have low volume throughputs vs the staff/systems required to process them. This might explain why despite the high spreads taken, many banks have been happy to outsource FX using the Wise Network instead.
  • Wise’s Network position looks to be a classic niche market position. Solving a small problem with a high quality, low-cost solution offered to customers (banks and businesses) with far bigger issues.
  • The reason the Wise platform take up is faster at neo-banks is

a) Their newer tech stacks make it easier for them to add new software/services

b) They are more proactive towards giving customers better products and services, i.e. want to be innovative

Wise’s customer obsession

The discussion above and our wider view of the banking sector shows that Wise’s customer obsession is very rare inside banking. Clearly this is true when compared to long-standing banking incumbents that control most market share. There are new banking alternative offerings and many of them are based on product innovation and doing a better job than incumbents. Wise’s product offering we think stands out, even against them, due to an unusual combination of factors.

  • Its offering is both retail and wholesale, thus building more scale than just a retail only offering
  • It is truly global
  • Is niche in its focus, and the product innovation it develops are all related to that niche
  • Is very focused on finding genuine units cost efficiencies and then passing these on to the customer. I.e. is following a Scale-economy-shared model

With our 2024 enthusiasm for Wise and Nubank we are now very interested in alternative finance offerings worldwide. Simply put we need to understand their competitors and any threats to their growth. Our work thus far suggests to us that these two companies are special, however. The gap between their cultures (highly customer centric, efficiency and innovation driven) and todays banking incumbents is frankly enormous.

We see this combination of factors as a powerful driver of each company’s longer-term future. We are now actively seeking evidence to disprove/challenge this theory mostly via the presence future competitors. As of today, we see alternative banks (like Monza and Revolut). We are not however finding companies with the cost, innovation and customer centricity of Wise/Nu. Buffett’s observation above that customer centric companies rarely fail to be successful we think an interesting observation.

Wise Innovation

Innovation is seemingly a centre of gravity for Wise plc. They are very focused on “what do our customers want”. Crucially, unlike Revolut, Wise is not expanding into adjacent areas that is does not feel are close to its core. The main driver of product innovations that are brought to market by Wise is “what will drive greater cross border volumes for the company”. Whilst all successful product innovation is often admired by investors, we are pleased to hear of this focus.

Wise has clearly articulated the end game of the network scale it seeks, articulating how the power will accrue to the operator with the greatest end market share. As such it is making sure all its innovation help it achieve that goal. I.e. a Flywheel of more scale, lower units costs, cheaper prices, more/happier customers. Jeff Bezos and his napkin drawing would approve we suspect:

Fig 1. Jeff Bezos Amazon flywheel sketch

A diagram of growth and sales Description automatically generated  Source: Working backwards by Colin Bryar/Bill Carr

We think it is important for investors to realise the importance of Wise’s past innovations and just how recently such products were launched. The Wise Account and the Wise Network offered to other banks were both innovations only released in the last three years. Wise’s multi-currency invoicing is more recent even than that. The potential benefits such products offer to their target markets we think are enormous. Just these three innovations alone could become huge profit sources for the company in their own right, without any further innovations.

Wise: The SME’s friend

We have spent a little time of late thinking through how Wise benefits SME companies, doing so through the eyes of our own company, Holland Advisors. The appendix of this note shows a recent payment we made and how it was treated by our bank (Big Red Bank Plc!). Comparing it with how it would have been treated by Wise were we to be set up with them. We named this study/example “Dirty Rotten Scoundrels” in honour of the big banks and the FX fees companies like us are forced to pay. This shows that we would have saved £181 on our £3,000 payment had we used Wise. We estimate that we make, or receive, 16 such Euro or Dollar payment per year, implying a potential c.£2,500 annual saving.

Running a prudently financed company as we do, we keep quite a lot of spare cash in our bank account (which earns no interest). Our bank does not offer an easy sweep facility, nor a simple ability to buy gilts or other money market funds. Wise does! Were our current balance to earn Wise type money market rates annually we would earn c.£5,000 of interest that we do not receive today. These combined £7,500 savings are a huge sum for a small business and can be achieved with minimal effort. (NB: FCA rules do not permit Wise to pay ‘interest’ to their UK current account holders currently. However, a simple button allows even UK Wise account holders to put cash into a daily liquidity fund, BlackRock’s UK money market fund. This currently pays 4.46% in Sterling after Wise has taken a 0.46% fee and BlackRock 0.1%).

Multi-currency invoicing

Wise’ recent innovation of multi-currency invoicing is a product/service we think quite brilliant. Our Dirty Rotten Scoundrels section shows what happens when we as a GBP based company receives a supplier invoice in US dollars. We have to deliver dollars to our supplier, but because these funds come from our Sterling account its costs us c.2.5% more than the invoiced amount. A Wise account helps to circumvent this.

Wise multi-currency invoicing is the next step. It allows us to bill our clients in their domestic currency (using the mid-market or agreed exchange rate) then receive these monies in that currency. We can then convert such funds at the full exchange rate inside our Wise account, saving ourselves c.2% of the invoiced amount in the process. Holland Advisors has some receipts and payments in Dollars/Euros, but not many. We estimate a total value of £120,000 hence a 2.5% saving of c.£2,500. Most other companies will save far more. Today this is a real frictional cost being incurred by almost all SMEs worldwide. Multinational companies have the banking relationships to avoid such payment costs, but up until now SMEs did not.

  • We ask readers to consider a £1m turnover business that has 50% of sales outside its home currency and buys 50% of cogs outside as well
  • Let’s assume it makes 30% Gross margins and 10% PBT margins
  • This means its sells £500k abroad, but also sources £350k of its COGS abroad too
  • A 2% saving on £850k of transactions is £17,000!
  • For a company that expects to make £100k in PBT pa, this is an enormous saving
  • It is also illustrative of how draining on SME finances large banking FX spreads are
  • Clearly drawing up invoices in numerous currencies is not a hard function to create, but having a single multicurrency account that such funds can be remitted to is.
  • The power and importance of this function is far less visible to US based SMEs, and investors we suggest. Versus those in Europe and Asia. This is why Europe is where such innovation is coming from.
An owner manager with Plenty of SCA’s

We have written to Kristo and would very much like to sit down with him. From what we have heard/read he is our archetypal owner manager. The business he has built is working its way through many of the SCA’s we admire in a similar fashion to Netflix. Wise as a disrupter has gained network scale and now is using this to drive scale economies for customers benefit. Such a starting point combined with a constant drive for innovation and a customer obsession looks set to take the company a long way. We are fans.

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.

Appendix: Dirty rotten Scoundrels

Below we highlight what life is like for a small business and the banking cost incurred.

Holland received an invoice from Bloomberg for $9,000

  • Holland instructed Big Red Bank X to pay this invoice from our Sterling account
  • We were told it will cost £25 to make this transfer and were then given a £ amount that this would cost us. This was £7,180 with a £25 fee added on top.
  • NB. Nowhere on the Big Red Bank account (paper statement or live) does it show the rate this equates to. Indeed the $9,000 dollar amount is not shown on statement either, only the £7,180
  • Our accounting system Xero (and our 30y old calculator!) however can work this out for us.
  • $9,000/£7,180 = 1.25348.

The below chart shows how this compares with the spot rate on that day.

A screen shot of a graph Description automatically generated Source: Bloomberg

What is notable is:

  1. The bank rate we are offered/given does not disclose the spread it is from spot rate. In this case it was fairly typical 2.5% (Average spot rate for day of 1.2855/1.25348)
  2. Not only is this trade low risk but it is also arguably zero risk as the majority of Big Red bank FX undertaken in any day will be matched against another on the other side
  3. The way banks report these trades suggest the fee for the transaction is £25 (reasonable on first glace). In fact, the all in cost is £204(spread + fee). Far less acceptable!

How would this transaction look with Wise

Firstly the company is transparent about giving you the spot rate, and also on the fee it is then charging on top.

  • Wise average take rate for FX is 0.58% now. When we checked this out on a few transactions this is broadly what we found for Indian Rupee to Sterling (i.e. 0.6%). For Euro or Dollar to Sterling the fee was 0.33%
  • If we had instructed Wise to deliver $9,000 to Bloomberg on 25th July this would have been the result:
    • $9,000/1.2855 = £7,001 is what our account would be debited by. With Wise disclosing to us what the spot rate was. Wise would then have charged us 0.33% for making this transaction… or £23

Total cost of delivering $9,000 on 25th July 2024 =

= £7,205 (£7,180 +£25) with Big Red bank Plc

= £7,024 (£7,001+£23)

Difference = £181 or 2.6% of the transaction value. It must be remembered that such % spreads are charged on both side of the FX spot rate. The result being that Holland has paid 2.6% more than it needed to, to deliver dollars. At exactly the same moment, ABC Engineering will have also paid 2.6% to receive dollars… our dollars most likely.

We were debited £7,205 for the privilege. They likely only received $9,000/1.3176 = £6,805 (after £25 fee). The difference is £400 (c.5.7% of $9,000). This level of frictional cost is being incurred by SME business all over the world, every single day.

The future will be different

Holland is lucky in the sense that it need not make that may payment of receipts in single year. That said we probably make c.14-16 with quarterly Bloomberg bills and some receipts. £181 x15= £2,715!

Today we all think this lack of transparency by the banks as the norm. But in an age of digital money and low-cost execution this is gouging. Pure and simple. Consumers with the help of companies like Wise will gradually see this and react…. with their feet. Regulators too will one day have these opaque profit pools in their sights. The puck today might be at the feet of Lloyds, NatWest and Santander and the like today. We think we can clearly see where the puck is going.

Wise looks to be the champion that can save consumers and businesses real money that they should not be paying in a digital money world. Like the others deflationary consumer champions that came before it (Amazon, Spotify and Netflix) we think it will be well rewarded.

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

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