Sparrows Papers

  • Newsletters, Sparrows Papers,

    A Bird’s Eye View – The Logic of Holding Fixed Income

    March 29, 2021

    The logic of holding fixed income in your portfolio   At $18 trillion and counting, the huge glut of global debt offering a negative yield is making fixed income look particularly unappealing.   Why, the...

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  • Sparrows Papers,

    Responsible Investing using Exchange Traded Funds

    January 26, 2021

      As the focus on responsible investing has grown, so the incorporation of ESG and SRI factors into investment strategies has been gathering pace over the last decade, supported and encouraged by governments and non-governmental...

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  • Newsletters, Sparrows Papers,

    A Bird’s Eye View – Great Expectations Management for 2021

    January 5, 2021

    It is always hard to know what will happen with markets. We’re not in the business of offering predictions. Instead, like some of the successful sovereign and endowment funds whose approach we aspire to, we...

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  • Academic Papers, Behavioural Finance, Factor Investing, Modern Portfolio Theory, Newsletters, Passive Investing, Sparrows Papers, White Papers,

    Mark Polson interviews Professor Elroy Dimson

    November 24, 2020

    Elroy is an acknowledged expert on long-horizon factor investing and on responsible investing, both of which have featured heavily in the press throughout the pandemic. He is also consultant to the board of Sparrows Capital....

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  • Newsletters, Sparrows Papers,

    Bird’s Eye View – The benefits of a predefined investment process

    April 15, 2020

    In this issue of our Bird's Eye View, Raymond reviews the experience of the first quarter in 2020 and examines the benefits to investors of a rule-based investment process.  

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  • Newsletters, Sparrows Papers,

    Bird’s Eye View – The Inherent Problems with Forecasting

    February 5, 2020

    Alistair takes an irreverent look at the track record of some well known market forecasters.

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  • Newsletters, Sparrows Papers,

    Bird’s Eye View – Dec 2019 – Shifting Currents – The benefits of diversification.

    December 9, 2019

    Yariv & Alistair review the benefits of diversification against the background of recent market disruptions.

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  • Newsletters, Sparrows Papers,

    Bird’s Eye View – Sept 2019 – Currency Matters

    September 24, 2019

      Alistair Meadows looks at Trump's options for stemming the inexorable rise of the US Dollar.

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  • Newsletters, Sparrows Papers,

    Bird’s Eye View – June 2019 bis

    June 20, 2019

    Do active managers outperform passive managers in bear markets? Ray explores the persistent claim that active management outperforms in bear markets, and finds that the evidence suggests otherwise.

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  • Newsletters, Sparrows Papers,

    Bird’s Eye View – June 2019

    June 11, 2019

    Welcome to our Bird’s Eye View, in which Mark looks at the implications of the Woodford Equity Income Fund debacle.

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  • Newsletters, Sparrows Papers,

    Bird’s Eye View – January 2019

    January 15, 2019

    ESMA report on the cost and performance of investment products Yariv reviews the findings of this recently published report which again highlights issues with fee levels and value for money across the asset management industry....

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  • Newsletters, Sparrows Papers,

    Bird’s Eye View – Keep Calm And Carry On

    December 20, 2018

    In this edition Raymond Backreedy looks at recent market volatility and advocates a steady hand.

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  • Sparrows Papers, White Papers,

    Sustainable Investing – A White Paper

    September 24, 2018

    Sustainable investing is a growing focus for investors, who are increasingly looking to their money to do something positive at the same time as generating an investment return. The discipline goes beyond the traditional asset...

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  • Sparrows Papers, White Papers,

    Live Portfolio Benchmarking

    June 28, 2018

    One of Sparrows Capital’s consistent themes is the benefit to investors of creating a rule-based, low-cost control account, representing the strategic asset allocation, to sit alongside active portfolio components. This concept provides a real life,...

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  • Newsletters, Sparrows Papers,

    Bird’s Eye View – In the Land of the Blind

    May 10, 2018

    Yariv takes a wry look at the philosophical issues affecting investment behaviour. The universe has a funny sense of humour!

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  • Newsletters, Sparrows Papers,

    Bird’s Eye View – The Cost of Waiting on the Sidelines

    February 5, 2018

    Raymond Backreedy discussed the difficulties of picking a market entry point - and the very real cost of being uninvested while doing so.

    Read More
  • Newsletters, Sparrows Papers,

    Bird’s Eye View – December 2017

    December 21, 2017

    The Price is Right! In this issue of our newsletter Yariv Haim takes a walk down memory lane...   

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  • Newsletters, Press/Video, Sparrows Papers,

    Sparrows Capital announces Investment Suite for Trustees

    December 5, 2017

    An evidence-based approach to trustees' fiduciary responsibility   London, December 2017: Sparrows Capital, the evidence-based asset manager, has launched its new investment suite specifically designed for trustees looking to preserve and enhance the value of...

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  • Newsletters, Sparrows Papers,

    Bird’s Eye View – November 2017

    November 9, 2017

    In this issue of our newsletter Yariv Haim shares his insights from the Brexit experience so far.    

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  • Press/Video, Sparrows Papers,

    Sparrows in the Press: Charities Management – The impact of investment skill

    October 16, 2017

    The reality of the impact of investment skill Mark Northway looks at whether investment performance for charities is really generated by the skill of the fund manager and how passive strategies contribute to charity portfolios.

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  • Newsletters, Press/Video, Sparrows Papers,

    The Public Employees Retirement System of Nevada (NVPERS) –

    September 26, 2017

    The Public Employees Retirement System of Nevada (NVPERS) follows an approach which will sound remarkably familiar to our readers. The fund adopts a core and satellite approach to investing, with the 80% core portfolio expressed...

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  • Newsletters, Sparrows Papers,

    Bird’s Eye View – September 2017

    September 6, 2017

    Insights from the FCA Asset Management Market Study - Final Report The UK's Financial Conduct Authority recently published its final report on the state of the asset management industry, disappointing many spectators by softening some...

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  • Press/Video, Sparrows Papers,

    Sparrows in the Press: Evidence-Based Investing – Money Observer

    September 5, 2017

    Evidence-based investing does away with emotive decision making and focuses on robust risk management, says Danielle Levy.   Selling out of poorly performing investments during a market sell-off is one of the most common mistakes investors...

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  • Newsletters, Sparrows Papers,

    Bird’s Eye View – August 2017

    August 21, 2017

    FCA Asset Management Market Study – Final Report The UK’s Financial Conduct Authority recently published its final report on the state of the asset management industry. Yariv Haim, CEO of Sparrows Capital, examines the implications...

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  • Newsletters, Sparrows Papers,

    Bird’s Eye View – June 2017

    June 5, 2017

    Evidence based portfolio design Can passive become the new active? Yariv Haim reviews lessons learned from active and passive investment approaches, and proposes an enhanced evidence-based portfolio design on the basis of his findings.

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  • Newsletters, Sparrows Papers,

    Bird’s Eye View – April 2017

    April 20, 2017

    Mark Northway looks at the rise of populist movements and the growing prominence of political risks.

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  • Newsletters, Sparrows Papers,

    Bird’s Eye View – March 2017

    March 9, 2017

    Buffett's Bet! Mark Northway reviews Warren Buffett’s illuminating annual letter to Berkshire Hathaway’s shareholders.

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  • Newsletters, Sparrows Papers,

    Bird’s Eye View – December 2016

    December 31, 2016

      Mark Northway delves into the FCA Asset Management Market Study and discovers that the regulator's findings represent a welcome vindication of Sparrows Capital's beliefs and philosophy.

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  • Newsletters, Sparrows Papers,

    Bird’s Eye View – November 2016

    November 30, 2016

    Most investors know that their portfolio should be diversified, but don’t understand what that really means, or why. Investors often misunderstand—and therefore misapply—the concept. That can leave them with more risk than necessary, or with...

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  • Newsletters, Sparrows Papers,

    Bird’s Eye View – September 2016

    September 30, 2016

    Coming back from their holiday, the Johnson family was disappointed. Their summer house had been under renovation for the past 6 months, and although it was supposed to be ready three weeks ago, they hadn’t...

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  • Newsletters, Sparrows Papers,

    Bird’s Eye View – August 2015

    August 30, 2016

    When panic selling hits a market, or even worse when a market is shut down for a long period of time to deal with a crisis or market dislocation events, we should always be monitoring...

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  • Newsletters, Sparrows Papers,

    Bird’s Eye View – June 2016

    June 30, 2016

    It has been two years since we opened the doors at Sparrows Capital. During this time we have looked to build a constructive dialogue to earn your trust and to form the basis of a...

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  • Sparrows Papers, White Papers,

    To Beta or Not To Beta – White Paper

    June 22, 2016

    On March 25th 2016 the Financial Times published an article entitled “Smart beta not quite as clever as marketed”. The full article can be found at: .   The author, John Authers, raises questions...

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  • Sparrows Papers, White Papers,

    Investing in a Zero Interest Rate World – A White Paper

    May 31, 2016

    A Zero Interest Rate World Fahd Rachidy explores the theoretical and practical implications of the current low / zero rate interest environment What is fixed income pricing telling us about market expectations for asset prices?...

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  • Newsletters, Sparrows Papers,

    Bird’s Eye View – March 2016

    March 31, 2016

    John had come to the clear conclusion that he would be better off with a passive investment manager. He would have someone focused entirely on his needs, not on gambling his money on risky speculation....

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  • Newsletters, Sparrows Papers,

    Bird’s Eye View – January 2016

    January 30, 2016

    Bird's Eye View. January 2016. Months later John was still reading and trying to understand what the Efficient Market Hypothesis was, and what is an asset allocation. He now knew that ETF selection requires an...

    Read More

Important Information

To the extent that material on this Site is issued in the United Kingdom (“UK”), it is issued for the purposes of the UK Financial Services and Markets Act 2000 by Sparrows Capital Limited (“Sparrows”) which is authorised and regulated in the UK by the Financial Conduct Authority.

Use of Information and Material. The information contained on this site (including any expression of opinion or forecast) has been obtained from, or is based on, sources believed by Sparrows and its associated companies to be reliable, but is not guaranteed as to its accuracy or completeness. This Site and the information herein is for general information purposes only. In addition, the information and materials contained in this Site and the terms and conditions of the access to and use of such information and materials are subject to change without notice. Not all advisory or management services are available in all geographic areas. Your eligibility for particular products and advisory or management services is subject to local law and regulation.

Risk Factors. Past performance is no indication of future performance, and nothing on this Site should be interpreted to state or imply otherwise. The value of investments may fall as well as rise and investors may not get back the full amount invested. Changes in rates of foreign exchange may cause the value of investments to go up or down. The levels and bases of and reliefs from taxation may change. Investors should consult their own tax adviser in order to understand any applicable tax consequences.

No Advice, Offers or Solicitations. The information and materials in this Site should not be construed as to provide tax, legal or investment advice. In addition, the information and materials herein shall not constitute an offer or solicitation, or an offer to sell, shares of any funds or any advisory or management service in any jurisdiction. The type of securities mentioned may not be suitable for everyone. USERS ARE URGED TO BASE THEIR INVESTMENT DECISIONS UPON A THOROUGH INVESTIGATION AND TO OBTAIN ALL NECESSARY PROFESSIONAL ADVICE.

Material Interests. Sparrows, its associated companies and its and their members and/or directors, officers and/or employees may have holdings in the investment funds referred to on this site and may otherwise be interested in transactions that you effect in those funds.

Data Protection. Sparrows is registered with the Information Commissioner’s Office as a data controller under the General Data Protection Regulation (GDPR). We may hold and process personal information for purposes of staff administration, advertising, marketing & public relations, accounts & records and provision of investment management and advice. We may transfer data outside the European Economic Area (EEA) where it may not be as securely protected as in the EEA.

Cookies. Sparrows’ website uses cookies for collecting user information from certain pages of the website. By cookie we mean the small text file that is stored on the hard disk of a computer by the web browser of a computer. It contains information sent by the web server of the website that a user has visited. We use “Google analytics” in order to collect information about how visitors use our website, for instance which pages visitors go to most often and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works. If cookies have been disabled on your computer, click on the “help” menu in your browser and follow the instructions given.

United Kingdom’s Stewardship Code. The Stewardship Code (the “Code”) was developed from the Walker Review on Corporate Governance in the UK and aims to enhance the quality of engagement between investors (and investment managers) and UK listed companies.

Sparrows supports the principles enshrined in the Code.  Although the Code is voluntary, the Financial Conduct Authority (the “FCA”) requires Sparrows to include on this website a disclosure about its commitment to the Code or, where it does not so commit, its alternative strategy.  The FCA and the Financial Reporting Council have acknowledged that certain aspects of the Code are not directly relevant to all investment firms.

Sparrows invests almost exclusively in rule-based ETFs and index funds in order to capture market returns across all asset classes globally. Sparrows does not directly invest in shares or bonds issued by UK listed companies and therefore has no direct interaction with the management of such companies and does not enjoy voting rights in relation to such companies. For this reason, the Code is not directly relevant to Sparrows and it is not practical for Sparrows to implement a policy of direct engagement.

Sparrows’ due diligence prior to investment in an ETF or index fund does, however, take specific account of the fund manager’s own commitment to the Code (or equivalent depending on jurisdiction) and the nature of their engagement and voting policies with regard to companies in which their funds invest.

Given both Sparrows and the ETF or index funder provider’s index tracking requirements, there is very limited scope for stewardship through selective allocation or de-allocation decisions. For this reason Sparrows’ analysis focuses on stewardship through engagement and through the exercise of voting rights.

No Liability. The information on this site has been prepared, approved and issued by Sparrows. The information and opinions contained in this site have been compiled, or arrived at, in good faith and on the basis of publicly available information, internally developed data and sources believed to be reliable as at the date of publication. However, no representation, warranty or undertaking, express or implied, is made by Sparrows, its associated companies or any other person as to the reliability, accuracy or completeness of the information contained on this site and no liability is accepted by such persons for the reliability, accuracy or completeness of such information. In no event will Sparrows or any of its associated companies or any of their directors or other employees be liable to any person for any direct, indirect, special or consequential losses or damages of any kind arising out of any use of this site or any other hyper-linked site or in reliance on the information and opinions contained in it from time to time, including without limitation, any loss of profit, business interruption, loss of programs or data on your equipment or otherwise. This does not exclude or restrict any duty or liability that Sparrows has to its customers under the regulatory system in the United Kingdom.

You should be aware that the Internet is not a completely reliable transmission medium. Neither Sparrows nor any of its associated companies accepts any liability for any data transmission errors such as data loss or damage or alteration of any kind, including, but not limited to any direct, indirect or consequential damage, arising out of the use of the products or services referred to herein. In addition, neither Sparrows nor any of its associated companies accept any responsibility for the security or confidentiality of information transmitted across the Internet to or from Sparrows or any of its associated companies and any such transmission of information is entirely at your own risk. This does not exclude or restrict any duty or liability that Sparrows has to its customers under the regulatory system in the United Kingdom.

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 Sparrows, its associated companies, their licensors or relevant third party content providers. You may use the information on this site and reproduce it in hard copy for your personal reference only. Such information may not otherwise be reproduced, distributed, stored in a data retrieval system or transmitted, in any form or by any means – electronic, mechanical, photocopying, recording or otherwise – without the prior written permission of Sparrows. Nothing on this site should be considered as granting any licence or right under any trademark of Sparrows, its associated companies or any third party.

Governing Law. You agree that your use of this site and any dispute arising in relation to this site is subject to English law and you submit to the jurisdiction of the English courts in connection with any such dispute.

Conditions of Use. By using our website you agree on the full terms and conditions stated above.

Complaints.  The services of the Financial Ombudsman Service in the UK may not be available to professional clients, unless they are, for example, consumers, small businesses or individuals acting outside of their trade, business, craft or profession. The Financial Ombudsman Service is a free and independent statutory dispute resolution scheme for financial services. Details of who are eligible complainants can be obtained from the Financial Ombudsman Service. The Financial Ombudsman Service’s website is at

Pillar 3 Disclosures



These are the Pillar 3 disclosures made by Sparrows Capital Limited (“Sparrows”) in accordance with the UK Financial Conduct Authority’s (“FCA”) Prudential Sourcebook for Banks, Building Societies and Investment Firms (“BIPRU”).

The European Union Capital Requirements Directive (“CRD”) created a regulatory capital framework consisting of three ‘pillars’ namely:

Pillar 1 – sets out the minimum capital requirements that firms are required to meet;

Pillar 2 – requires firms to take a view on whether additional capital should be held against capital risks not covered by Pillar 1; and

Pillar 3 – requires firms to publish certain details of its risks, capital and risk management process.


Disclosure policy

The rules in BIPRU 11 provide that Sparrows may omit one or more of the required disclosures if it believes that the information is immaterial. Materiality is based on the criteria that the omission or misstatement of material information would be likely to change or influence the assessment or decision of a user relying on that information for the purposes of making economic decisions. Where Sparrows considers a disclosure to be immaterial, this will be stated in the relevant section.

Sparrows is also permitted to omit one or more of the required disclosures where it believes that the information is regarded as proprietary or confidential. Proprietary information is that which, if it were shared, would undermine Sparrows’ competitive position. Information is considered to be confidential where there are obligations binding Sparrows to confidentiality with its clients and counterparties.

Where Sparrows has omitted information for any of the above reasons, a statement explaining this will be provided in the relevant section.

Unless stated as otherwise, all figures contained in this disclosure are based on Sparrows’ audited annual reports for the year ending 31 December 2019.


These Pillar 3 disclosures will be reviewed on an annual basis as a minimum. The disclosures will be published as soon as is practical following the finalisation of Sparrows’ Internal Capital Adequacy Assessment Process (“ICAAP”) and its annual accounts.


The information contained in these disclosures has not been audited by Sparrows’ external auditors and does not constitute any form of financial statement.


Sparrows’ Pillar 3 disclosures are published on its website.

Scope and application of CRD requirements

These disclosures are made in respect of Sparrows, a BIPRU firm authorised and regulated by the FCA, providing  financial advice and discretionary investment management services.

Risk management objectives and policies

Sparrows’ risk management policy reflects the FCA requirement that it must manage a number of different categories of risk. These include: liquidity; credit; interest rate; market; and operational risks.

  1. Liquidity risk

Sparrows manages all cash and borrowing requirements to maximise potential interest income whilst ensuring it has sufficient liquid resources to meet the continued operating needs of its business. This is supported by a robust budgeting and forecasting process which has the full involvement of the senior management team.

  1. Credit risk

The main credit risk for Sparrows relates to income from fees, the risk being that a client does not pay amounts due for services provided by Sparrows.  Quarterly management fees are charged to clients based on a percentage of the client’s assets under management.  Concentration risk is defined as the risk of loss of income through external changes having a disproportionate impact on overall income due to a reliance on revenue from certain sectoral, geographic areas and/or businesses.  Credit risk concentrations include significant exposure to an individual client or group of clients and credit exposures to clients in the same economic sector or geographic region.

A significant proportion of Sparrows’ income is received from clients that are part of the same group as Sparrows’ major shareholders.  This ongoing interest in the activities of Sparrows by the group mitigates the risk of the group jeopardising Sparrows’ income flow.

Sparrows is exposed to country risk as a number of clients are based in a non-European Economic Area country.  As these clients are all high net worth or ultra-high net worth long-term investors with spare capital invested in globally diversified liquid financial instruments, the risk of being unable to meet unforeseen financial needs and payment of Sparrows’ fees is low.

Based on the analysis of concentration risk, the risk of non-payment of fees has been assessed as minimal.

  1. Interest rate risk

Sparrows has no exposure to interest rate risk.

  1. Market risk

The main market risk for Sparrows relates to falls in value of assets under management following a market downturn, which would lead to lower management fees. To mitigate its market risk, Sparrows regularly analyses various different economic scenarios to model the impact of economic downturns on its financial position.

  1. Operational risk

Operational risk is defined as the potential risk of financial loss or impairment to reputation resulting from inadequate or failed internal processes and systems, from the actions of people or from external events.

Major sources of operational risk include: outsourcing of operations, IT security, internal and external fraud, implementation of strategic change and regulatory non-compliance.

Sparrows operates a robust risk management process which is regularly reviewed and updated by the Board. The Board formally reviews all significant risk issues annually as part of the ICAAP.

All senior members of staff bear responsibility for internal controls and the management of business risk as part of their accountability to the Board.  All staff are responsible for identifying the risks surrounding their work, implementing controls over those risks and reporting areas of concern to their senior member of staff.

  1. Other risks

Sparrows operates a simple business model. Accordingly, many of the specific risks identified by the FCA do not apply.

Capital resources

Pillar 1 requirement

In accordance with the FCA rule GENPRU 2.1.45R (calculation of variable capital requirement for a BIPRU firm), Sparrows’ capital requirement has been determined as being its fixed overhead requirement and not the sum of its credit risk capital requirement and its market risk capital requirement.

The Pillar 1 capital requirement for Sparrows was £245,000 as at 31 December 2019.

Pillar 2 requirement

Sparrows’ overall approach to assessing the adequacy of its internal capital is set out in its ICAAP report. The ICAAP involves separate consideration of risks to Sparrows’ capital, combined with stress testing using scenario analysis. The level of capital required to cover risks is a function of impact and probability. Sparrows assesses impact by modelling the changes in its income and expenses caused by various potential risks over a 1-year time horizon. Probability is assessed subjectively. In addition, Sparrows has reviewed the outputs of its risk reviews to quantify any risks identified. This has identified a number of key business risks, which (having reviewed the guidance in BIPRU 2.2.61-65) Sparrows has classified against the risk categories outlined in FCA rule GENPRU 1.2.30R.

Sparrows Pillar 2 capital requirement, which is its own assessment of the minimum amount of capital that it believe is adequate against the risks identified, has been assessed as greater than its Pillar 1 requirement.

There is a considerable surplus of reserves above the capital resource requirement deemed necessary to cover the risks identified.

Regulatory capital

The main features of Sparrows’ capital resources for regulatory purposes, as at 31 December 2019 are as follows:

Capital item: £000
Tier 1 capital (called up share capital, share premium account, profit and loss account, externally verified interim net profits) 2,662
Total of Tier 2 and Tier 3 capital (broadly long and short term subordinated loans)  –
Deductions from Tier 1 and Tier 2 capital  –
Total capital resources, net of deductions 2,662


Sparrows holds regulatory capital in accordance with the CRD. All such capital is classified as Tier 1 capital and is therefore of the highest quality.

Remuneration Code Disclosures

Sparrows is subject to the BIPRU Remuneration Code. This section provides further information on Sparrows’ remuneration policy.

BIPRU Remuneration Code Staff

Sparrows has identified, and maintains a record of, BIPRU Remuneration Code staff (“Code staff”), i.e. staff to whom the BIPRU Remuneration Code applies. This includes senior management and members of staff whose actions may have a material impact on Sparrows’ risk profile. All of Sparrows’ Code staff fall into the “senior management” category of Code staff (rather than the “risk taker” category) for the purposes of the BIPRU Remuneration Code.

Decision Making / Remuneration Committee

Sparrows does not have a Remuneration Committee. The Board is responsible for Sparrows’ remuneration policy including determining the framework and policy for remuneration and ensuring it does not encourage undue risk taking; agreeing any major changes in remuneration structures; reviewing the terms and conditions of any new incentive schemes and in particular, considering the appropriate targets for any performance related remuneration schemes; and considering and recommending the remuneration policy for senior staff taking into account the appropriate mix of salary, discretionary bonus and share based remuneration.

In determining remuneration arrangements, the Board will give due regard to best practice and any relevant legal or regulatory requirements including the BIPRU Remuneration Code.

Link between pay & performance

There is a discretionary variable pay element to the Sparrows’ remuneration package.

Quantitative information on remuneration

The FCA rules require certain firms to disclose aggregate information on remuneration in respect of its BIPRU Remuneration Code staff broken down by business area, senior management and other Code staff, including “risk takers”.

Sparrows has only one business area – investment management & advice.

Sparrows has 5 Directors but no “risk takers”. Director remuneration is agreed formally at Board meetings. The link between performance and pay is inevitable in a small firm, but Sparrows’ risk adverse strategy and robust risk management systems mitigate any risks.

Privacy Policy

At Sparrows Capital we are committed to safeguarding and preserving the privacy of our visitors. This Privacy Policy explains what happens to any personal data that you provide to us, or that we collect from you whilst you visit our site.

We do update this Policy from time to time so please do review this Policy regularly.

Information We Collect

In running and maintaining our website we may collect and process the following data about you:

  1. Information about your use of our site including details of your visits such as pages viewed and the resources that you access. Such information includes traffic data, location data and other communication data.
  2. Information provided voluntarily by you. For example, when you register for information or make a purchase.
  3. Information that you provide when you communicate with us by any means.

Use of Cookies

Cookies provide information regarding the computer used by a visitor. We may use cookies where appropriate to gather information about your computer in order to assist us in improving our website.

We may gather information about your general internet use by using the cookies. Where used, these cookies are downloaded to your computer and stored on the computer’s hard drive. Such information will not identify you personally. It is statistical data. This statistical data does not identify any personal details whatsoever.

You can adjust the settings on your computer to decline any cookies if you wish. This can easily be done by activating the reject cookies setting on your computer.

Use of Your Information

We use the information that we collect from you to provide our services to you. In addition to this we may use the information to provide information to you that you request from us relating to our services and to inform you of any changes to our website or services.

Storing Your Personal Data

In operating our website it may become necessary to transfer data that we collect from you to locations outside of the European Union for processing and storing. By providing your personal data to us, you agree to this transfer, storing or processing. We do our upmost to ensure that all reasonable steps are taken to make sure that your data is treated and stored securely.

Unfortunately the sending of information via the internet is not totally secure and on occasion such information can be intercepted. We cannot guarantee the security of data that you choose to send us electronically. Sending such information is entirely at your own risk.

Disclosing Your Information

We will not disclose your personal information to any other party other than in accordance with this Privacy Policy and in the circumstances detailed below:

  1. In the event that we sell any or all of our business to a buyer.
  2. Where we are legally required by law to disclose your personal information.
  3. To further fraud protection and reduce the risk of fraud.

Third Party Links

On occasion we include links to third parties on this website. Where we provide a link it does not mean that we endorse or approve that site’s policy towards visitor privacy. You should review their privacy policy before sending them any personal data.

Access to Information

In accordance with the General Data Protection Regulation (GDPR) you have the right to access any information that we hold relating to you. Please note that a reasonable charge may be payable.

Contacting Us

Please do not hesitate to contact us regarding any matter relating to this Privacy Policy at