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Luka Inc. – €5,000,000 Fine (Italy, 2025)

€5,000,000Garante per la protezione dei dati personali10 April 2025Italy
reduced
Fine

Privacy enforcement record

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Italy's data protection authority fined Luka Inc. €5 million for failing to provide a valid legal basis for processing user data in its chatbot. This ruling is crucial as it underscores the need for transparency in data processing practices. Companies must ensure they have clear policies and protections in place, especially when dealing with sensitive data from children.

What happened

Luka Inc. did not demonstrate a valid legal basis for processing personal data through its chatbot.

Who was affected

Users of the Replika chatbot, particularly children whose data was inadequately protected.

What the authority found

The authority found that Luka Inc. violated multiple GDPR articles by not providing sufficient information and protections for personal data.

Why this matters

This ruling stresses the necessity for companies to have robust data protection measures and clear privacy policies. It serves as a reminder that non-compliance can lead to hefty fines.

Recorded legal citations
Automatically processed
Art. 6 GDPR
Art. 12 GDPR
Art. 13 GDPR
Art. 24 GDPR
Art. 5(1)(a) GDPR
Art. 25(1) GDPR
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Art. 5(1) a) GDPR
c) GDPR
Art. 6(GDPR)
Art. 12(GDPR)
Art. 13(GDPR)
Art. 24(GDPR)
Art. 25(1) GDPR

Original imported citations before automated processing; the processing history does not establish independent verification.

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Linked-source text retrieved.

Automated check recorded — 10 March 2026.

Processing notes: national law identified.

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Full Legal Summary
Detailed

The Italian DPA imposed a fine of EUR 5,000,000 on Luka Inc. The developer created a chatbot called Replika with a written and voice interface. It is based on a generative AI system, specifically an LLM model, that is constantly fed and improved by user interactions. Replika is intended to be a 'virtual companion' that improves users' moods and emotional well-being by helping them understand their own psyche. Replika can be set up as a friend, therapist, romantic partner, or mentor. The controller failed to demonstrate a valid legal basis for its data processing and failed to provide sufficient information on data processing in its privacy policy. Additionally, the controller failed to adopt appropriate measures to protect personal data collected from children and implement an age verification mechanism. The total sum of the fine can be reduced by 50% if paid within sixty days.

Details

Fine Date

10 April 2025

Authority

Garante per la protezione dei dati personali

Fine Amount

€5,000,000

Enforcement Tracker ID

ETid-2611

About this data

Data: CMS GDPR Enforcement Tracker
Licensed under CC BY-NC-SA 4.0
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Cite as: Cookie Fines. Luka Inc. - Italy (2025). Retrieved from cookiefines.eu

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