"The anonymized data is used only internally and is not used to train third-party large language models or other AI systems."
Their words, not yet tested. privacy policy · read from their site on 2026-11-12
MINIMUM AGE AND MINORS
"If you are under 18 (or the age of majority where you live, if higher), you are not authorized to use the Services, with or without registering."
Their words, not yet tested. terms of service · read from their site on 2026-11-12
AUTO-RENEW, REFUNDS AND CANCELLING
"Paid subscriptions renew automatically at the end of each billing period at the then-current price for your plan, until cancelled."
Their words, not yet tested. terms of service · read from their site on 2026-11-12
OFFICIAL DECISION · 2025-04-10
Garante per la protezione dei dati personali
Official record: Garante per la protezione dei dati personali, case "10130115", dated 2025-04-10 on the authority's own page; respondent or addressee: Luka Inc.; procedural status as of 2026-11-08: under appeal.
Screen recordings submitted to Abouit by users who stated they show cancelling or deleting their own account. Abouit did not record them and cannot verify who made them. Screens are counted by our published method. Submitted recordings are reported evidence: never a receipt, never part of a grade.
No receipt about Replika yet. read — waiting for review First look from Germany on 2026-11-09 · privacy policy read 2026-11-12 · terms of service read 2026-11-12
Published by Luka, Inc. (no exact match in GLEIF).
Found clauses are waiting for the jury, the legal review and a notice to the company.
Area by area
Read the details
What we checked in each of the six areas, and what we found there. Not a score: an empty area means not tested yet; "their words" means we quote their documents below but have not tested it. Planet is a seventh row of measured facts from the same first look: what the homepage weighs before any tap, and a CO2e range with its method.
How Replika's own help pages say you can reach a person, quoted as written on the date given. We did not contact them. Not tested by us; not a score.
Cancel article: not read: the site's robots.txt or the site itself refused our reader, and we never get around a refusal (page) Close-account article: not read: the site's robots.txt or the site itself refused our reader, and we never get around a refusal (page)
What the stores and its help centre say
The company's own declarations, copied as shown on the date given, with a link to the source and the hash of our archived copy. Not tested by us; not a score.
App Store (US), as the listing showed it
“Data Used to Track You”: “Identifiers”, “Usage Data”
“Data Linked to You”: “Identifiers”, “Usage Data”, “Location”, “Contact Info”
“Data Not Linked to You”: “Usage Data”, “Identifiers”, “Diagnostics”
Age rating: “18+”
In-app purchases listed: “MONTHLY” “$7.99”; “Annual” “$69.99”; “YEARLY” “$49.99”; “Monthly” “$14.99”; “Annual” “$49.99”; “Backpack of Gems” “$5.99”; “Pouch of Gems” “$0.99”; “Duffel Bag of Gems” “$19.99”; “Suitcase of Gems” “$14.99”; “ Replika Platinum” “$89.99”
Google Play Data safety page: not read: the site's robots.txt or the site itself refused our reader, and we never get around a refusal. 2026-11-09 · source
Cancelling, per its help centre: not read: the site's robots.txt or the site itself refused our reader, and we never get around a refusal. 2026-11-09 · source
Closing the account, per its help centre: not read: the site's robots.txt or the site itself refused our reader, and we never get around a refusal. 2026-11-09 · source
Inside the Android app
What an independent analysis of the published app file lists for Replika (Android version 12.18.0, report of 2026-10-27). A permission says what the app can ask the phone for, not what it does with it. A newer version may differ.
Whole sentences copied exactly from Replika's own documents, grouped by subject. Their words, not yet tested: this is quotation, not a finding, and no jury has looked at it. Each sentence links to the archived copy it came from.
AI TRAINING ON YOUR CONTENT
"This includes collecting and immediately anonymizing user feedback, and small portions of Messages and Content data to train our proprietary safety algorithms, enhance chatbot performance, prevent inappropriate outputs, and ensure compliance with safety standards."
"Our website sign-up flow also asks for your age (to confirm that you may use the Services) and your gender (to personalize your experience), and for your email address before showing you subscription options, so that we can create your account after purchase and — where you consent or where the law otherwise allows — send you marketing communications."
"We may share information with application store providers and payment processors for purposes of managing payments, subscriptions, and resolving user-initiated disputes or refund requests."
"If you subscribe in our iOS or Android apps, billing, renewal, payment-method management, and refunds are handled by Apple or Google under their terms, and you can manage or cancel the subscription only through your App Store or Google Play account settings."
"Further, this Arbitration Agreement does not preclude you from bringing issues to the attention of federal, state, or local agencies, and such agencies can, if the law allows, seek relief against us on your behalf."
"You agree that, by entering into these Terms of Service, you and Replika are each waiving the right to a trial by jury or to participate in a class action."
"We may also use information about your visit to our Website to promote our Services, but we will never use or disclose the content of your Replika conversations for marketing or advertising purposes, and our advertising partners will never have access to your conversations with your Replika AI companion or any photos or other content you submit through the Apps."
"Should you disclose third parties’ personal data through the Services, you are solely responsible for ensuring that such individuals receive appropriate notice of this Privacy Policy and any applicable data processing activities, and such disclosure shall be immediately notified to us."
"However, please remember that the manner in which Social Networking Services use, store and disclose your information is governed solely by the policies of such third parties, and Replika shall have no liability or responsibility for the privacy practices or other actions of any third party site or service that may be enabled within the Service."
"Understanding how the Services are used in order to provide, maintain, and improve them: measuring events our own systems observe — such as sign-ups, subscription events, feature usage, and retention — processed on our servers and keyed to your account."
"We will retain your personal information for only as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements."
"You agree that any termination of your access to the Service under any provision of these Terms of Service may be effected without prior notice, and acknowledge and agree that Replika may immediately deactivate or delete your account and all related information and files in your account and/or bar any further access to such files or the Service."
"We process this information only as described in this Privacy Policy, for instance and as better clarified in detail in section 2 below, to allow you to have individualized and safe conversations and interactions with your Replika AI companion and to allow your AI companion to learn from your interactions to improve your conversations."
BEFORE · CAPTURED 2026-02-06"Additional rights , such as your right to object to the processing of your personal data for the processing activities based on our legitimate interest and to request that we restrict our use of you personal data."
AFTER · CAPTURED 2026-03-06"Additional rights , such as your right to object to the processing of your personal data for the processing activities based on our legitimate interest and to request that we restrict our use of your personal data."
BEFORE · CAPTURED 2026-02-06"We share your personal data with companies and individuals that provide services to us or on our behalf or help us operate the Services or our business (such as hosting, information technology, customer support, email delivery, and website analytics services)."
AFTER · CAPTURED 2026-03-06"We share your personal data with companies and individuals that provide services to us or on our behalf or help us operate the Services or our business (such as hosting, information technology, third-party artificial intelligence language models, customer support, email delivery, and website analytics services)."
Example in the loop: TikTok's record (Data Protection Commission, Ireland).
Read the details
Garante per la protezione dei dati personali · case "10130115"
Official record: Garante per la protezione dei dati personali, case "10130115", dated 2025-04-10 on the authority's own page; respondent or addressee: Luka Inc.; procedural status as of 2026-11-08: under appeal.
Legal entity named
Luka Inc.
Linked to Replika through
its confirmed legal entity Luka, Inc. (confirmed by entity-gate v1 (2026-11-09))
Jurisdiction
IT
Penalty, as written
"€5 million"
Procedural status
under appeal
Decision dated
2025-04-10
Published by the authority
2025-05-19
Procedural status checked on
2026-11-08
Retrieved by us
2026-11-09
Approved for this page by
records-gate v1 (automatic: verified word for word on the authority's own site, 2 of 3 models agreed; proof stored), 2026-11-09
Source
Official pagearchived copy SHA-256 92764b1f7d6c7880…
Each case reference, date and penalty above appears word for word in our archived copy of the official page. Official decisions are context: they never change a grade.
Can ask for your microphone, precise location, approximate location
4 kinds of data linked to you
Up to $299.99 for one in-app purchase
2 kinds of data used to track you across other companies' apps
