Skip to main content

PRIVACY POLICY

Last updated October 01, 2026

This Privacy Notice for Hara Enterprises Limited (doing business as Ten's

Friends) ('we', 'us', or 'our'), describes how and why we might access,

collect, store, use, and/or share ('process') your personal information when

you use our services ('Services'), including when you:

Download and use our mobile application (Ten's Friends), or any

other application of ours that links to this Privacy Notice

Engage with us in other related ways, including any marketing or

events

Questions or concerns? Reading this Privacy Notice will help you

understand your privacy rights and choices. We are responsible for making

decisions about how your personal information is processed. If you do not

agree with our policies and practices, please do not use our Services. If

you still have any questions or concerns, please contact us at

admin@tensfriends.com.

SUMMARY OF KEY POINTS

Settings

This summary provides key points from our Privacy Notice, but you

can find out more details about any of these topics by clicking the

link following each key point or by using our table of contents below

to find the section you are looking for.

What personal information do we process? When you visit, use, or

navigate our Services, we may process personal information depending on

how you interact with us and the Services, the choices you make, and the

products and features you use. Learn more about personal information you

disclose to us.

Do we process any sensitive personal information? Some of the

information may be considered 'special' or 'sensitive' in certain jurisdictions,

for example your racial or ethnic origins, sexual orientation, and religious

beliefs. We may process sensitive personal information when necessary

with your consent or as otherwise permitted by applicable law. Learn more

about sensitive information we process.

Do we collect any information from third parties? We do not collect any

information from third parties.

How do we process your information? We process your information to

provide, improve, and administer our Services, communicate with you, for

security and fraud prevention, and to comply with law. We may also

process your information for other purposes with your consent. We process

your information only when we have a valid legal reason to do so. Learn

more about how we process your information.

n what situations and with which parties do we share personal

information? We may share information in specific situations and with

specific third parties. Learn more about when and with whom we share

your personal information.

What are your rights? Depending on where you are located

geographically, the applicable privacy law may mean you have certain

rights regarding your personal information. Learn more about your privacy

rights.

How do you exercise your rights? The easiest way to exercise your

rights is by submitting a data subject access request, or by contacting us.

We will consider and act upon any request in accordance with applicable

data protection laws.

Want to learn more about what we do with any information we

collect? Review the Privacy Notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR

PERSONAL INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL

INFORMATION?

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

6. HOW LONG DO WE KEEP YOUR INFORMATION?

7. WHAT ARE YOUR PRIVACY RIGHTS?

8. CONTROLS FOR DO-NOT-TRACK FEATURES

9. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY

RIGHTS?

10. DO WE MAKE UPDATES TO THIS NOTICE?

11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE

COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you

express an interest in obtaining information about us or our products and

Services, when you participate in activities on the Services, or otherwise

when you contact us.

Personal Information Provided by You. The personal information that we

collect depends on the context of your interactions with us and the

Services, the choices you make, and the products and features you use.

The personal information we collect may include the following:

names

email addresses

mailing addresses

contact preferences

Sensitive Information. When necessary, with your consent or as

otherwise permitted by applicable law, we process the following categories

of sensitive information:

Application Data. If you use our application(s), we also may collect the

following information if you choose to provide us with access or permission:

Geolocation Information. We may request access or permission to

track location-based information from your mobile device, either

continuously or while you are using our mobile application(s), to 

provide certain location-based services. If you wish to change our

access or permissions, you may do so in your device's settings.

Mobile Device Data. We automatically collect device information

(such as your mobile device ID, model, and manufacturer), operating

system, version information and system configuration information,

device and application identification numbers, browser type and

version, hardware model Internet service provider and/or mobile

carrier, and Internet Protocol (IP) address (or proxy server). If you

are using our application(s), we may also collect information about

the phone network associated with your mobile device, your mobile

device’s operating system or platform, the type of mobile device you

use, your mobile device’s unique device ID, and information about

the features of our application(s) you accessed.

Push Notifications. We may request to send you push notifications

regarding your account or certain features of the application(s). If

you wish to opt out from receiving these types of communications,

you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation

of our application(s), for troubleshooting, and for our internal analytics and

reporting purposes.

All personal information that you provide to us must be true, complete, and

accurate, and you must notify us of any changes to such personal

information.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer

our Services, communicate with you, for security and fraud prevention, and

to comply with law. We process the personal information for the following

purposes listed below. We may also process your information for other

purposes only with your prior explicit consent.

We process your personal information for a variety of reasons,

depending on how you interact with our Services, including:

To request feedback. We may process your information when

necessary to request feedback and to contact you about your use of

our Services.

To send you marketing and promotional communications. We

may process the personal information you send to us for our

marketing purposes, if this is in accordance with your marketing

preferences. You can opt out of our marketing emails at any time.

For more information, see 'WHAT ARE YOUR PRIVACY RIGHTS?'

below.

To deliver targeted advertising to you. We may process your

information to develop and display personalised content and

advertising tailored to your interests, location, and more.

To identify usage trends. We may process information about how

you use our Services to better understand how they are being used

so we can improve them.

To save or protect an individual's vital interest. We may process

The General Data Protection Regulation (GDPR) and UK GDPR require us

to explain the valid legal bases we rely on in order to process your personal

information. As such, we may rely on the following legal bases to process

your personal information:

Consent. We may process your information if you have given us

permission (i.e. consent) to use your personal information for a

specific purpose. You can withdraw your consent at any time. Learn

more about withdrawing your consent.

Legitimate Interests. We may process your information when we

believe it is reasonably necessary to achieve our legitimate business

interests and those interests do not outweigh your interests and

fundamental rights and freedoms. For example, we may process

your personal information for some of the purposes described in

order to:

Send users information about special offers and discounts on

our products and services

Develop and display personalised and relevant advertising

content for our users

Analyse how our Services are used so we can improve them

to engage and retain users

Understand how our users use our products and services so

we can improve user experience

Legal Obligations. We may process your information where we

believe it is necessary for compliance with our legal obligations, such

as to cooperate with a law enforcement body or regulatory agency,

exercise or defend our legal rights, or disclose your information as

evidence in litigation in which we are involved.

Vital Interests. We may process your information where we believe

it is necessary to protect your vital interests or the vital interests of a

third party, such as situations involving potential threats to the safety

of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission

(i.e. express consent) to use your personal information for a specific

purpose, or in situations where your permission can be inferred (i.e. implied

consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable

law to process your information without your consent, including, for

example:

If collection is clearly in the interests of an individual and consent

cannot be obtained in a timely way

For investigations and fraud detection and prevention

For business transactions provided certain conditions are met

If it is contained in a witness statement and the collection is

necessary to assess, process, or settle an insurance claim

For identifying injured, ill, or deceased persons and communicating

with next of kin

If we have reasonable grounds to believe an individual has been, is,

or may be victim of financial abuse

If it is reasonable to expect collection and use with consent would

compromise the availability or the accuracy of the information and

the collection is reasonable for purposes related to investigating a

breach of an agreement or a contravention of the laws of Canada or

a province

If disclosure is required to comply with a subpoena, warrant, court

order, or rules of the court relating to the production of records

If it was produced by an individual in the course of their employment,

business, or profession and the collection is consistent with the

your information when necessary to save or protect an individual’s

vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO

PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is

necessary and we have a valid legal reason (i.e. legal basis) to do so under

applicable law, like with your consent, to comply with laws, to provide you

with services to enter into or fulfil our contractual obligations, to protect

your rights, or to fulfil our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us

to explain the valid legal bases we rely on in order to process your personal

information. As such, we may rely on the following legal bases to process

your personal information:

Consent. We may process your information if you have given us

permission (i.e. consent) to use your personal information for a

specific purpose. You can withdraw your consent at any time. Learn

more about withdrawing your consent.

Legitimate Interests. We may process your information when we

believe it is reasonably necessary to achieve our legitimate business

interests and those interests do not outweigh your interests and

fundamental rights and freedoms. For example, we may process

your personal information for some of the purposes described in

order to:

Send users information about special offers and discounts on

our products and services

Develop and display personalised and relevant advertising

content for our users

Analyse how our Services are used so we can improve them

to engage and retain users

Understand how our users use our products and services so

we can improve user experience

Legal Obligations. We may process your information where we

believe it is necessary for compliance with our legal obligations, such

as to cooperate with a law enforcement body or regulatory agency,

exercise or defend our legal rights, or disclose your information as

evidence in litigation in which we are involved.

Vital Interests. We may process your information where we believe

it is necessary to protect your vital interests or the vital interests of a

third party, such as situations involving potential threats to the safety

of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission

(i.e. express consent) to use your personal information for a specific

purpose, or in situations where your permission can be inferred (i.e. implied

consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable

law to process your information without your consent, including, for

example:

If collection is clearly in the interests of an individual and consent

cannot be obtained in a timely way

For investigations and fraud detection and prevention

For business transactions provided certain conditions are met

If it is contained in a witness statement and the collection is

necessary to assess, process, or settle an insurance claim

For identifying injured, ill, or deceased persons and communicating

with next of kin

If we have reasonable grounds to believe an individual has been, is,

or may be victim of financial abuse

If it is reasonable to expect collection and use with consent would

compromise the availability or the accuracy of the information and

the collection is reasonable for purposes related to investigating a

breach of an agreement or a contravention of the laws of Canada or

a province

If disclosure is required to comply with a subpoena, warrant, court

order, or rules of the court relating to the production of records

If it was produced by an individual in the course of their employment,

business, or profession and the collection is consistent with the purposes for which the information was produced

If the collection is solely for journalistic, artistic, or literary purposes

If the information is publicly available and is specified by the

regulations

We may disclose de-identified information for approved research or

statistics projects, subject to ethics oversight and confidentiality

commitments

4. WHEN AND WITH WHOM DO WE SHARE YOUR

PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this

section and/or with the following third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We

may share your data with third-party vendors, service providers,

contractors, or agents ('third parties') who perform services for us or on

our behalf and require access to such information to do that work.

The third parties we may share personal information with are as follows:

Advertising, Direct Marketing, and Lead Generation

Google AdSense

We also may need to share your personal information in the following

situations:

Business Transfers. We may share or transfer your information in

connection with, or during negotiations of, any merger, sale of

company assets, financing, or acquisition of all or a portion of our

business to another company.

5. WHAT IS OUR STANCE ON THIRD-PARTY

WEBSITES?

In Short: We are not responsible for the safety of any information that you

share with third parties that we may link to or who advertise on our

Services, but are not affiliated with, our Services.

The Services may link to third-party websites, online services, or mobile

applications and/or contain advertisements from third parties that are not

affiliated with us and which may link to other websites, services, or

applications. Accordingly, we do not make any guarantee regarding any

such third parties, and we will not be liable for any loss or damage caused

by the use of such third-party websites, services, or applications. The

inclusion of a link towards a third-party website, service, or application does

not imply an endorsement by us. We cannot guarantee the safety and

privacy of data you provide to any third-party websites. Any data collected

by third parties is not covered by this Privacy Notice. We are not

responsible for the content or privacy and security practices and policies of

any third parties, including other websites, services, or applications that

may be linked to or from the Services. You should review the policies of

such third parties and contact them directly to respond to your questions.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the

purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary

for the purposes set out in this Privacy Notice, unless a longer retention

period is required or permitted by law (such as tax, accounting, or other

legal requirements).

When we have no ongoing legitimate business need to process your

personal information, we will either delete or anonymise such information,

or, if this is not possible (for example, because your personal information

has been stored in backup archives), then we will securely store your

personal information and isolate it from any further processing until deletion

is possible.

7. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some

regions, such as the European Economic Area (EEA), United Kingdom

(UK), Switzerland, and Canada, you have rights that allow you greater

access to and control over your personal information. You may review,

change, or terminate your account at any time, depending on your country,

province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have

certain rights under applicable data protection laws. These may include the

right (i) to request access and obtain a copy of your personal information,

(ii) to request rectification or erasure; (iii) to restrict the processing of your

personal information; (iv) if applicable, to data portability; and (v) not to be

subject to automated decision-making. If a decision that produces legal or

similarly significant effects is made solely by automated means, we will

inform you, explain the main factors, and offer a simple way to request

human review. In certain circumstances, you may also have the right to

object to the processing of your personal information. You can make such a

request by contacting us by using the contact details provided in the

section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.

We will consider and act upon any request in accordance with applicable

data protection laws.

If you are located in the UK and are unhappy with how we have handled

your personal information, you can make a complaint directly to us. This is

in addition to the rights you have under the UK General Data Protection

Regulation and the Data Protection Act 2018.

How to contact us:

Online: https://hara.enterprises

Email: admin@tensfriends.com

Post: See 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?'

What happens after you complain

We will acknowledge your complaint within 30 days of receiving it.

We will investigate without unjustifiable or excessive delay.

We will keep you informed of progress and explain the outcome.

If you are not happy with our final response, you can refer your complaint

to the Information Commissioner's Office, the UK supervisory authority.

Website: ico.org.uk/make-a-complaint

Helpline: 0303 123 1113

Post: Information Commissioner's Office, Wycliffe House, Water

Lane, Wilmslow, Cheshire, SK9 5AF

If you are located in the EEA or UK and you believe we are unlawfully

processing your personal information, you also have the right to complain

to your Member State data protection authority or UK data protection

authority.

If you are located in Switzerland, you may contact the Federal Data

Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process

your personal information, which may be express and/or implied consent

depending on the applicable law, you have the right to withdraw your 

consent at any time. You can withdraw your consent at any time by

contacting us by using the contact details provided in the section 'HOW

CAN YOU CONTACT US ABOUT THIS NOTICE?' below.

However, please note that this will not affect the lawfulness of the

processing before its withdrawal nor, when applicable law allows, will it

affect the processing of your personal information conducted in reliance on

lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can

unsubscribe from our marketing and promotional communications at any

time by or by contacting us using the details provided in the section 'HOW

CAN YOU CONTACT US ABOUT THIS NOTICE?' below. You will then be

removed from the marketing lists. However, we may still communicate with

you — for example, to send you service-related messages that are

necessary for the administration and use of your account, to respond to

service requests, or for other non-marketing purposes.

If you have questions or comments about your privacy rights, you may

email us at admin@tensfriends.com.

8. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile

applications include a Do-Not-Track ('DNT') feature or setting you can

activate to signal your privacy preference not to have data about your

online browsing activities monitored and collected. At this stage, no uniform

technology standard for recognising and implementing DNT signals has

been finalised. As such, we do not currently respond to DNT browser

signals or any other mechanism that automatically communicates your

choice not to be tracked online. If a standard for online tracking is adopted

that we must follow in the future, we will inform you about that practice in a

revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser

DNT signals. Because there currently is not an industry or legal standard

for recognising or honouring DNT signals, we do not respond to them at

this time.

9. DO UNITED STATES RESIDENTS HAVE SPECIFIC

PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut,

Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota,

Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island,

Tennessee, Texas, Utah, or Virginia, you may have the right to request

access to and receive details about the personal information we maintain

about you and how we have processed it, correct inaccuracies, get a copy

of, or delete your personal information. You may also have the right to

withdraw your consent to our processing of your personal information.

These rights may be limited in some circumstances by applicable law. More

information is provided below.

Categories of Personal Information We Collect

The table below shows the categories of personal information we have

collected in the past twelve (12) months. The table includes illustrative

examples of each category and does not reflect the personal information

we collect from you. For a comprehensive inventory of all personal

information we process, please refer to the section 'WHAT INFORMATION

DO WE COLLECT?'


Inferences drawn from any of the

collected personal information listed

above to create a profile or summary

about, for example, an individual’s

preferences and characteristics


We may also collect other personal information outside of these categories

through instances where you interact with us in person, online, or by phone

or mail in the context of:

Receiving help through our customer support channels;

Participation in customer surveys or contests; and

Facilitation in the delivery of our Services and to respond to your

inquiries.

We will use and retain the collected personal information as needed to

provide the Services or for:

Category K - As long as the user has an account with us

Sources of Personal Information

Learn more about the sources of personal information we collect in 'WHAT

INFORMATION DO WE COLLECT?'

How We Use and Share Personal Information

Learn more about how we use your personal information in the section,

'HOW DO WE PROCESS YOUR INFORMATION?'

We collect and share your personal information through:

Targeting cookies/Marketing cookies

Click redirects: TBA.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers

pursuant to a written contract between us and each service provider. Learn

more about how we disclose personal information to in the section, 'WHEN

AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?'

We may use your personal information for our own business purposes,

such as for undertaking internal research for technological development

and demonstration. This is not considered to be 'selling' of your personal

information.

We have disclosed the following categories of personal information to third

parties for a business or commercial purpose in the preceding twelve (12)

months:

The categories of third parties to whom we disclosed personal information

for a business or commercial purpose can be found under 'WHEN AND

WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?'

We have sold or shared the following categories of personal information to

third parties in the preceding twelve (12) months:

The categories of third parties to whom we sold personal information are:

The categories of third parties to whom we shared personal information

with are:

Advertising, Direct Marketing, and Lead Generation

Google AdSense

Your Rights

You have rights under certain US state data protection laws. However,

these rights are not absolute, and in certain cases, we may decline your

request as permitted by law. These rights include:

Right to know whether or not we are processing your personal data

Right to access your personal data

Right to correct inaccuracies in your personal data

Right to request the deletion of your personal data

Right to obtain a copy of the personal data you previously shared

with us

Right to non-discrimination for exercising your rights

Right to opt out of the processing of your personal data if it is used

for targeted advertising (or sharing as defined under California’s

privacy law), the sale of personal data, or profiling in furtherance of

decisions that produce legal or similarly significant effects ('profiling')

Depending upon the state where you live, you may also have the following

rights:

Right to access the categories of personal data being processed (as

permitted by applicable law, including the privacy law in Minnesota)

Right to obtain a list of the categories of third parties to which we

have disclosed personal data (as permitted by applicable law,

including the privacy law in California, Delaware, and Maryland)

Right to obtain a list of specific third parties to which we have

disclosed personal data (as permitted by applicable law, including

the privacy law in Minnesota and Oregon)


Right to obtain a list of third parties to which we have sold personal

data (as permitted by applicable law, including the privacy law in

Connecticut)

Right to review, understand, question, and depending on where you

live, correct how personal data has been profiled (as permitted by

applicable law, including the privacy law in Connecticut and

Minnesota)

Right to limit use and disclosure of sensitive personal data (as

permitted by applicable law, including the privacy law in California)

Right to opt out of the collection of sensitive data and personal data

collected through the operation of a voice or facial recognition

feature (as permitted by applicable law, including the privacy law in

Florida)

How to Exercise Your Rights

To exercise these rights, you can contact us by submitting a data subject

access request, by emailing us at admin@tensfriends.com, by visiting

https://hara.enterprises, or by referring to the contact details at the bottom

of this document.

You can opt out from the selling of your personal information, targeted

advertising, or profiling by disabling cookies in Cookie Preference Settings.

Under certain US state data protection laws, you can designate an

authorised agent to make a request on your behalf. We may deny a

request from an authorised agent that does not submit proof that they have

been validly authorised to act on your behalf in accordance with applicable

laws.

Request Verification

Upon receiving your request, we will need to verify your identity to

determine you are the same person about whom we have the information

in our system. We will only use personal information provided in your

request to verify your identity or authority to make the request. However, if

we cannot verify your identity from the information already maintained by

us, we may request that you provide additional information for the purposes

of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorised agent, we may need to

collect additional information to verify your identity before processing your

request and the agent will need to provide a written and signed permission

from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action

regarding your request, you may appeal our decision by emailing us at

admin@tensfriends.com. We will inform you in writing of any action taken

or not taken in response to the appeal, including a written explanation of

the reasons for the decisions. If your appeal is denied, you may submit a

complaint to your state attorney general.

California 'Shine The Light' Law

California Civil Code Section 1798.83, also known as the 'Shine The Light'

law, permits our users who are California residents to request and obtain

from us, once a year and free of charge, information about categories of

personal information (if any) we disclosed to third parties for direct

marketing purposes and the names and addresses of all third parties with

which we shared personal information in the immediately preceding

calendar year. If you are a California resident and would like to make such

a request, please submit your request in writing to us by using the contact

details provided in the section 'HOW CAN YOU CONTACT US ABOUT

THIS NOTICE?'

10. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant

with relevant laws.

We may update this Privacy Notice from time to time. The updated version

will be indicated by an updated 'Revised' date at the top of this Privacy

Notice. If we make material changes to this Privacy Notice, we may notify

you either by prominently posting a notice of such changes or by directly

sending you a notification. We encourage you to review this Privacy Notice

frequently to be informed of how we are protecting your information.

11. HOW CAN YOU CONTACT US ABOUT THIS

NOTICE?

If you have questions or comments about this notice, you may email us at

admin@tensfriends.com or contact us by post at:

Hara Enterprises Limited

1 Yau Cheung Road

21A Block 2, The Coronation

Tau Ma Tei, Kowloon

Hong Kong

12. HOW CAN YOU REVIEW, UPDATE, OR DELETE

THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the

US, you may have the right to request access to the personal information

we collect from you, details about how we have processed it, correct

inaccuracies, or delete your personal information. You may also have the

right to withdraw your consent to our processing of your personal

information. These rights may be limited in some circumstances by

applicable law. To request to review, update, or delete your personal

information, please fill out and submit a data subject access request.