Italian Supervisory Authority Imposes Administrative Fine on the Developer of the Chatbot Replika

According to the decision issued by the Italian Supervisory Authority (“Authority”) on 10 April 2025, an administrative fine of EUR 5 million has been imposed on Luka Inc., the developer of the AI-based chatbot Replika, for infringing articles 5(1)(a), 6, 12, 13, 5(1)(c), 24, and 25(1) of the General Data Protection Regulation (GDPR).

• The chatbot Replika enables users to generate an "artificial companion" that can take on the role of a trusted friend, therapist, romantic partner, or mentor.
• The investigation confirmed that the alleged infringements, which led to the application's blocking in February 2023, did, in fact, occur.
• Luka Inc. failed to identify any legal basis for the data processing activities carried out through Replika until 2 February 2023.
• The privacy policy provided by the company was found to be inadequate in several respects.
• Despite the company’s declaration that minors were not permitted to use the service, no age verification mechanisms were implemented—neither at registration nor during use.

You can access the full text of the decision here.

Kind regards,

Zumbul Attorneys-at-Law

info@zumbul.av.tr

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