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

€5,000,000Garante per la protezione dei dati personali14 May 2025Italy
final
Fine

General GDPR enforcement action

This case relates to broader data protection obligations, not specifically to cookie or consent banner compliance. It is not included in cookie statistics or the Risk Calculator.

Luka Inc. was fined €5 million in Italy for serious violations related to its AI chatbot, Replika. This case matters because it highlights the responsibility of tech companies to protect users, especially minors.

What happened

The company violated multiple GDPR articles regarding the processing of personal data for its chatbot service.

Who was affected

Users of the Replika chatbot, particularly minors, were affected by the company's actions.

What the authority found

The Italian data protection authority found that Luka Inc. did not comply with several GDPR requirements, including those related to user consent and data protection measures.

Why this matters

This ruling sets a strong precedent for tech companies regarding user safety and data protection. Businesses offering online services should implement strict age verification and data handling practices.

GDPR Articles Cited
Automatically processed
Art. 6(GDPR)
Art. 12(GDPR)
Art. 13(GDPR)
Art. 24(GDPR)
Art. 3(2)(a) GDPR
Art. 5(1)(a) GDPR
Art. 5(1)(c) GDPR
Art. 25(1) GDPR
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Art. 3(2)(a) GDPR
Art. 5(1)(a) GDPR
Art. 5(1)(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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Full Legal Summary
Detailed

US company Luka Inc. (the controller) made available Replika, a chatbot based on generative AI. Replika was meant to be a virtual companion that could help users track their mood, cope with stress, and work out their emotional and psychological problems. Replika could be configured to fulfil various roles, including therapist and romantic partner. Replika gained attention from international media after it allegedly encouraged minors to engage in self-harm. The news prompted an ex officio investigation from the DPA. In early 2023 the Italian DPA ordered the controller to halt the processing of personal data of all users in Italy, as a precautionary measure. In this early phase of the procedure, the DPA found evidence of possible GDPR violations and reserved the right to investigate further. Months later the DPA lifted the ban on the condition that the controller took steps to ensure Replika’s compliance with data protection law, including implementing an effective age verification system to prevent minors from accessing the service. The controller made Replika available again after the ban was lifted. In May 2025 the DPA issued a final decision and closed the procedure. The DPA reserved the right to further investigate certain aspects of the case in a different procedure. The DPA found violations of Articles 5(1)(a), 5(1)(c), 6, 12, 13, 24, and 25(1) GDPR. The DPA fined the controller €5,000,000. This is a notably high fine amounting to 2% of the controller’s global turnover - half the statutory maximum under the GDPR. On the scope of the decision In its decision, the DPA found violations of the principles of lawfulness and transparency based on the version of Replika’s privacy notice in force on February 2023 (the date of the DPA’s order to halt the processing). The controller later made changes to its notice. The DPA reserved the right to open a second investigation on lawfulness, based on the controller’s up-to-date notice. The DPA also found that the controller

Details

Fine Date

14 May 2025

Authority

Garante per la protezione dei dati personali

Fine Amount

€5,000,000

GDPRhub ID

gdprhub-9256

About this data

Data: GDPRhub (noyb.eu)
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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