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.