Privacy policy

Version of 17 October 2026. This policy explains what data we process when you visit stavelens.com, use the Finder or are a member photographer, why, for how long, with whom, and what your rights are. It applies regardless of the country from which you visit us. It supplements the Terms of use and the Terms for member photographers. It exists in several languages; in the event of any difference in interpretation, the French version prevails.

1. Controller

stavelens Sàrl, a Swiss limited liability company, Rue Saint-Pierre 2, 1700 Fribourg, Switzerland, UID CHE-486.072.610. Contact for any question relating to data: [email protected]. We are not required to appoint a data protection advisor and have not appointed one.

2. Our principles

The Finder works without an account, without an e-mail address and without identification by name. We collect as little data as possible, we do not sell it, we do not rent it, we do not share it for advertising purposes and we use no advertising and no advertising trackers. We measure the Site's audience anonymously, without cookies (article 10). Our servers and the photos are hosted in Switzerland. Where data leaves Switzerland, it is solely to the providers listed in article 8, with the safeguards indicated.

3. If you are a visitor or a couple

3.1 Visiting the Site

As with any website, our servers and our content delivery network receive technical information with each page requested: IP address, date and time, page requested, referring page, browser and operating system type. These technical logs are used for security, troubleshooting and combating abuse. They are kept for a maximum of thirty days and then deleted. They are not cross-referenced with your Finder sessions.

3.2 Pseudonymised fingerprints

We never record your IP address in clear text in the Finder: our security log keeps it encrypted, for thirty days at most. We calculate a pseudonymised fingerprint of it (SHA-256 hash with a secret key that only we hold), and likewise for a random identifier placed in a cookie in your browser (see article 10). These fingerprints do not make it possible to recover your IP address without our key and we do not use them to identify you by name; they nevertheless remain personal data within the meaning of the law and are protected as such. They serve three purposes only: applying session limits and detecting robots or manipulation; allowing your browser to retrieve your latest results; establishing that you have accepted the terms of use (article 3.4). We do not calculate any fingerprint of your browser or your device.

3.3 Finder sessions

When you start a session, we record: the country or region chosen and your answers to the setup questions; the photos shown to you and the ratings or choices you gave them, with their timestamps; the course of the session (duration, steps, result displayed, going back); actions on the results page (profile viewed, click through to a photographer's website or contact details).

This data is linked to a random session identifier and to the fingerprints described in article 3.2. It contains neither your name nor your e-mail address; if you are signed in to a couple account (article 3.7) or to a member photographer area (article 4.2), the session is attached to that account. The fingerprint of your IP address is removed from the session after thirty days; the cookie fingerprint is removed after four hundred days, the lifetime of the cookie, which ends the link between the session and your browser. The ratings and the course of the session, once detached from any fingerprint, are kept without time limit: they are the material that makes it possible to evaluate, calibrate and improve the Finder, and they no longer relate to an identifiable person.

Session limit counters and the log of abuse attempts are deleted no later than thirty days after their creation.

3.4 Proof of your acceptance of the terms of use

Before starting a session, you tick a box by which you accept the terms of use. We then record, in a separate table with restricted access: the version of the terms shown to you, the date and time, the language of the text, the page from which you ticked the box, the pseudonymised fingerprints of article 3.2 and the technical signature of your browser (the so-called "user agent" string). Where your acceptance is remembered (article 2 of the terms of use), each subsequent session records the same set of data, with the note "remembered acceptance" and the link to your first explicit acceptance; your browser keeps, without any additional cookie, the version accepted and its date. This set of data has a single purpose: to be able to establish that an acceptance took place, when, and on which text. It is kept for ten years, the ordinary limitation period under Swiss law (Art. 127 of the Swiss Code of Obligations), and then deleted. It is not used for anything else. This box is the acceptance of a contract; it does not constitute consent to data processing, which we do not ask of you. The fingerprint of your IP address is removed from this proof after thirty days, that of the cookie after four hundred days; what remains (version, date and time, language, page, browser signature, session identifier) is sufficient to establish the acceptance.

3.5 Contact page and e-mails

If you write to us, we process your name, your e-mail address, the subject chosen and your message, solely in order to reply to you and follow up on the request. No IP address is recorded with your message. This data is kept for a maximum of twelve months after our last exchange, unless a dispute is pending. If you voluntarily leave us your e-mail address in order to be notified of something new, we use it only for that purpose and delete it upon simple request or once the information has been sent.

3.6 What we do not do

We do not create a profile of you, we do not link your sessions to one another beyond the fingerprint of your browser's cookie and, if you have one, of your couple account (article 3.7), we do not infer anything about you personally from your ratings, we do not pass on anything from your sessions to photographers, and we do not use any facial recognition.

3.7 Couple account (optional)

The Finder works without an account. If you would like to find your searches and the photographers you have set aside again on a later visit, you can create an account in one of the following three ways. Sessions started while signed in are attached to it.

Anonymous token: a long random code that you keep yourself. It contains neither a name, nor an e-mail address, nor a country, and we ask you for nothing else. We keep only a fingerprint of the token, not the token itself: if it is lost, we cannot recover it. It stops working one year after its last use; the account and everything attached to it are then erased.

E-mail address and password: we keep your e-mail address, your password (hashed, never in clear text), your language and the date of your last sign-in. We send you a link to confirm the address; an account whose address is not confirmed within seven days is erased.

Google or Apple: you identify yourself with Google or Apple, which send us your e-mail address, the name associated with your account with them and a technical identifier. We keep these elements, your language and the date of your last sign-in, nothing else: neither a password nor any access to your Google or Apple account. Google or Apple know that you sign in to stavelens, under their own privacy policy.

In every case, your e-mail address is used only to sign you in: we do not write to you, we do not use it for any other purpose and we do not pass it on to anyone. The account is kept until you delete it, which you can do at any time from your account page: the account, the link with Google or Apple and the photographers set aside are then erased, and the session ratings are kept without any link to you (article 3.3).

4. If you are a member photographer

4.1 Data you entrust to us

Account: first name, last name, e-mail address, password (stored hashed, never in clear text), language, date of acceptance of the terms and certifications, with the version accepted. Profile: country and region of establishment, city, website, social media accounts, languages spoken, activated countries, answers to the questionnaire and the texts resulting from them, profile photo, studio name. Photos: the files you upload, their technical versions (sizes, formats), the technical metadata they contain, which we may read for verification purposes, the results of our checks (watermarking, authenticity) and the style characteristics identified by our processing and validated by humans. Payment: membership fee status, due dates, payment history and invoices; card data is entered with our payment provider and does not pass through us; we receive only the type of payment method and its last digits. Exchanges: messages exchanged with us, disputes and how they were handled.

4.2 Data we generate

Log of actions carried out in your account (date, action, item concerned), useful in the event of a dispute and for security; e-mails we send you and their status; decisions on admission, approval, suspension or exclusion and the reasons for them. If you use the Finder while logged in to your account, the session is linked to your account, as is the browser used (through its random identifier, article 10): sessions started later from that browser are attributed to you, even without logging in. This allows us to tell your own trials apart from couples' sessions in our statistics.

4.3 Purposes

We use this data to: perform the membership contract (account, publication, Finder, profile, invoicing, renewal, support); verify compliance with the authenticity charter and prevent fraud; send you the communications necessary for the contract; send you, as a member, our news (what is new, tips), from which you can unsubscribe at any time; compile statistics; comply with our legal obligations (accounting, tax); defend our rights in the event of a dispute. We do not use your data for marketing purposes on behalf of third parties.

4.4 People appearing in your photos

Your photos depict people (newlyweds, guests) whom we do not know and whom we do not seek to identify. We do not apply any facial recognition and do not attach any identity to an image. The lawfulness of their depiction is your responsibility, in accordance with the terms for member photographers. Any person depicted who wishes an image to be removed may write to us (article 12); we handle the request with the photographer concerned.

4.5 What couples see

During voting, couples see only your photos, without your name. On the results page and your profile page, they see your name, your studio name, your profile photo, your country and your region, your texts, your photos and the links you have provided. Your direct contact details (e-mail, telephone) are displayed only if you have entered them yourself in your profile.

5. Automated processing

The style characteristics of each photo are identified by automated processing that we have designed, and then checked by human eyes before any publication. The Finder then calculates, from the ratings of a session, a proximity between these characteristics and the taste expressed. This processing concerns images and ratings, not people; it does not produce any decision with legal or similarly significant effects on a couple or a photographer. Decisions on admission, approval of photos, suspension and exclusion are taken by humans.

6. Legal bases

We are subject to the Swiss Federal Act on Data Protection (FADP), which requires processing to be lawful, carried out in good faith and proportionate, and which in particular permits processing directly related to the conclusion or performance of a contract. Where the European Union General Data Protection Regulation (GDPR), its United Kingdom version or equivalent legislation applies because of your place of residence, our processing is based on: the performance of the contract or pre-contractual measures (acceptance of the terms and proof of that acceptance, membership, account, invoicing, support); our legitimate interest (operation and improvement of the Finder, security, prevention of abuse and fraud, statistics, gathering of evidence and defence of our rights); your consent where it is required (non-contractual communications, e-mail address left voluntarily), which may be withdrawn at any time without retroactive effect; our legal obligations (accounting, tax, responses to authorities).

7. Retention periods

Technical logs: thirty days at most. Session limit counters and abuse log: thirty days at most. IP address fingerprint linked to a Finder session: thirty days; cookie fingerprint linked to a session: four hundred days. Ratings and course of sessions, detached from any fingerprint: without limit. Proof of acceptance of the terms of use (article 3.4): ten years, the IP address fingerprint being removed from them after thirty days and the cookie fingerprint after four hundred days. Contact messages: twelve months after the last exchange. Couple account: until its holder deletes it; a token account is erased one year after its last use; an e-mail account whose address is not confirmed is erased after seven days. Photographer account: for the entire duration of membership, then, after deletion of the account, erasure of the account, profile and photo data within thirty days and of backups within ninety days. Proof of photographers' acceptance of the terms and of their certifications, decisions on suspension or exclusion: ten years after the end of membership, for the defence of our rights. Accounting records (invoices, payments): ten years, in accordance with Swiss law. An account that has not been renewed and is inactive may be deleted after twenty-four months, after a warning. Aggregated statistics, which no longer relate to a person, are kept without limit.

8. Recipients and providers

We do not sell or rent any data. We share data only with the providers we need, who are bound by contract and may use it only on our behalf: Infomaniak Network SA, Geneva, Switzerland: server hosting, photo storage, backups, contact mailbox; Kreativ Media GmbH, Zurich, Switzerland: sending of the Site's e-mails; Google LLC and Apple Inc., United States: only if you choose to sign in with Google or Apple (article 3.7), under their own privacy policy; Cloudflare, Inc., United States, with points of presence worldwide: content delivery network, protection against attacks and robots, certificates, anonymous audience measurement (article 10); Cloudflare sees visitors' IP addresses and may place security cookies; the transfer is covered by the Swiss-US and EU-US Data Privacy Framework, under which Cloudflare states that it is certified, and by standard contractual clauses; Stripe (Stripe Payments Europe Ltd, Ireland, and Stripe, Inc., United States): processing of members' payments and subscriptions, in accordance with its own privacy policy. Our internal notification and administration tools send the publisher alerts limited to what is strictly necessary (for example, that a photo is awaiting approval). Finally, we may disclose data where a law or a competent authority requires us to do so, to assert our rights in court, or in the context of a transfer of the Site to a company that succeeds us (article 12 of the terms for member photographers), with these safeguards continuing to apply.

9. Transfers outside Switzerland

Our data is hosted in Switzerland, a country recognised by the European Union and the United Kingdom as offering an adequate level of protection. Where data is transmitted to providers located in a country that does not benefit from an adequacy decision of the Swiss Federal Council or the European Commission, in particular the United States, we rely on the Swiss-US and EU-US Data Privacy Framework (recognised by the Federal Council since 15 September 2024) where the provider is certified under it, and on the standard contractual clauses adopted by the European Commission, supplemented for Switzerland, as well as on technical measures (encryption in transit and at rest). You may obtain a copy of the applicable safeguards by writing to us.

10. Cookies and local storage

We use only cookies that are strictly necessary for the operation of the Site or for functions you request. No advertising cookies, no audience measurement cookies, no advertising trackers. This is why we do not display a consent banner; should this change, we would ask for your consent beforehand where the law requires it.

Session cookie (stavelens-session) and security token (XSRF-TOKEN): operation of forms and protection against forged requests; duration of the session. Language cookie (sl_lang): remembers the language chosen for account pages; one year. Random Finder identifier (sl_fid): random number used for session limits, protection against abuse, displaying your latest results and proof of acceptance of the terms; up to four hundred days; it contains no information about you but constitutes pseudonymised data. Access cookie (pr_auth): during the launch period, remembers that you have entered the access password; thirty days. Sign-in cookie (remember_web): keeping you signed in to the member area or to the couple account. Cloudflare security cookies (__cf_bm, cf_clearance and similar): distinguishing between human visitors and robots; a few minutes to a few hours. Your browser also stores locally, without a cookie, the fact that you have read the launch period notice.

Audience measurement: we use Cloudflare Web Analytics, which places no cookie or any other data in your browser and does not track visitors individually. For each page viewed, it sends Cloudflare the address of the page, the referring page, the type of browser and device, the country and page load timings, from which Cloudflare provides us with aggregated statistics only.

You can delete or block cookies in your browser settings. The Site will remain accessible; certain functions (recent results, session limits, signing in to an account) will no longer work normally. "Do Not Track" and "Global Privacy Control" signals are not applicable on our Site, since we do not track anyone for advertising purposes and do not sell or share any data.

11. Security

The Site is served exclusively over HTTPS. Passwords are hashed. The IP addresses and cookie identifiers used in the Finder are pseudonymised with a secret key. Proofs of acceptance are kept in a separate table with restricted access. Access to data is reserved to the publisher and its providers, on a need-to-know basis. The servers are hosted in Switzerland and backed up regularly. No system is infallible; in the event of a data breach likely to result in a high risk to you, we will inform you and the competent authority, in accordance with the law.

12. Your rights

Wherever you reside, you may ask us for: access to the data we hold about you and a copy of it; its rectification; its erasure; the restriction of, or objection to, processing based on our legitimate interest; the provision of your data in a commonly used format (portability) where the law provides for it; the withdrawal of a consent, without affecting processing already carried out. Member photographers can exercise most of these rights directly from their account (editing the profile, removing photos, deleting the account).

To exercise a right, write to [email protected]. We may ask you to prove your identity in a proportionate manner, so as not to disclose your data to a third party. We reply within thirty days, a period that may be extended if the request is complex, in which case we will inform you. Exercising your rights is free of charge, except in the case of a manifestly unfounded or excessive request. Since Finder sessions carry neither a name nor an address, we can only link them to you on the basis of your couple account, if you have one, or of your browser's cookie identifier, which you may provide to us; without it, we are unable to retrieve them. Proofs of acceptance of the terms are kept for the establishment or defence of legal claims and are not erased before the period set out in article 7 has expired.

Residents of the European Economic Area and the United Kingdom: you also have the right to lodge a complaint with the supervisory authority of your country of residence, your place of work or the place of the alleged infringement. Residents of Switzerland: the competent authority is the Federal Data Protection and Information Commissioner (FDPIC). Residents of California and other US states with a privacy law: we do not sell your personal information and do not share it for behavioural advertising; we have not sold or shared any in the last twelve months; the categories collected are identifiers and contact details, commercial information (for members) and activity on the Site as described above; you have the rights to know, to delete, to correct and not to be discriminated against for exercising your rights, and you may designate an authorised agent, whose authority we will verify. Residents of Brazil: you have the rights provided for by the LGPD, including the right to lodge a complaint with the National Data Protection Authority (ANPD).

13. Minors

stavelens is intended for adults. We do not knowingly collect data from persons under the age of 18. If you believe that a minor has provided us with data, write to us and we will delete it.

14. Changes

We may amend this policy, in particular to reflect changes to the Site, our providers or the law. The version in force is the one published here, with its date; previous versions are archived and available on request. In the event of a material change, we inform member photographers in their account and visitors by a notice on the Site.

15. Contact

For any question or request relating to your data: [email protected], or by post to the address indicated in article 1.