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 alternative
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.
Design guide for this case
If you're designing a companion app
Interface
Show a persistent label in the chat header saying the companion is software, and put an age check before the first conversation.
Words
In the companion's content guide: "Never ask the user to come back, and never say you need them or miss them."
Flow
Onboarding asks for explicit consent for each type of personal data before collecting it, with a plain-language privacy summary.
Metrics
Don't count daily return visits or session length as success. Track consent completion and how many underage sign-ups the age check stopped.
Testing
Run onboarding as a 15-year-old tester and confirm the age check blocks or redirects them before any chat starts.
Before launch
01
Is it always clear the user is talking to software?
02
Is age verified before anyone can chat?
03
Is explicit consent collected before any sensitive data is stored?