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HL-004

affect.bond

Public example

An AI companion app fined €5 million

Italy's data protection authority fined the company behind Replika €5 million for processing user data without a legal basis and failing to verify users' ages.

High severity

Fined or settled

What happened

01

Replika is a companion app that communicates in an emotional, personal way.

02

In February 2023 the Italian authority temporarily blocked it.

03

In April 2025 it issued a €5 million fine.

04

Reasons: no legal basis for processing, an inadequate privacy policy, and no age verification.

Why this is a design failure

Emotional companion apps collect very sensitive data and can reach minors without protections.

The fair design

Make clear it is software, verify age, and obtain explicit consent before collecting data.

Do

State it is software and verify users' ages.

Don’t

Do not ask users to return or say you need them.

Company response

No published response from the company.

About this example

Product

Replika

Company

Luka Inc.

Date

2025-04

Category

Fake feelings

Pattern

affect.bond

Where

AI companion app

Sources

European Data Protection Board, May 2025 ↗

Use this example

In a workshop or design review. Cite the source.

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