{"meta":{"exportedAt":"2026-10-23T08:34:49.278Z","formatVersion":2,"selection":{"q":"gdpr","system":"","harm":"","context":"","country":"","role":"","relation":"","evidence":"","year":"","response":"regulatory","severity":"","verification":"","view":"incidents","sort":"added"},"totalIncidents":4,"coverage":{"cases":4,"countries":1,"languages":2,"unknownLocation":2,"locationPending":0,"unknownLanguage":0,"unknownDate":0,"lawsuits":0,"regulatory":4,"minors":2,"coreRelations":2,"contextualRelations":0,"mixedRelations":0,"unknownRelations":2,"relationPending":2,"relationUnknown":0},"countingNote":"Distinct public cases in this selection. People counts apply within individual cases only; cross-case person overlap has not been resolved. No population incidence estimate.","affectedCountNote":"Interpret person counts with affectedCountStatus and the reported effects. Unquantified zeros are placeholders, not a measured zero.","source":"AI incidents","publisher":"NOPE","url":"https://nope.net/incidents","license":"CC BY 4.0"},"incidents":[{"id":"2024-italy-tv-satire-show-ai-deepfakes-of-journalist-mentana-privacy-regulator-warns-broadcaster","caseFacts":{"claims":[{"id":"c1","status":"documented","evidence":[{"locator":"'per alcuni servizi di Striscia la Notizia, nei quali l’immagine e la voce di Enrico Mentana erano state manipolate mediante l’impiego di sistemi di intelligenza artificiale.'; 'Nei filmati venivano attribuite al noto giornalista dichiarazioni mai pronunciate, mentre la sua immagine era collocata virtualmente nello studio televisivo dell’emittente per la quale lavora.'","relation":"supports","source_id":"s1"},{"locator":"'servizi costruiti prendendo come spunto fatti che hanno coinvolto diversi personaggi pubblici e accompagnandoli con commenti di vario genere pronunciati dal deepfake del reclamante doppiato con sistemi di intelligenza artificiale'; 'è stata utilizzata l’immagine reale del reclamante, ripresa peraltro all’interno dello studio televisivo da cui il medesimo dirige un telegiornale di fascia serale, alterandone la genuinità attraverso un doppiaggio effettuato con strumenti tali da non rendere chiaramente percepibile l’esistenza della predetta alterazione'","relation":"supports","source_id":"s2"}],"assertion":"Striscia la Notizia aired segments in which the image and voice of journalist Enrico Mentana were manipulated with AI systems, attributing to him statements he never made while placing his image in the studio of the channel he works for.","causal_attribution":"The regulator's findings in its decision and press release; R.T.I. itself describes computer-generated dubbing."},{"id":"c2","status":"reported","evidence":[{"locator":"'nella puntata di venerdì 8 novembre manderà in onda un servizio che vedrà protagonista Enrico Mentana, ma in versione deepfake, ovvero con voce e immagini generati dall’intelligenza artificiale.'","relation":"supports","source_id":"s3"}],"assertion":"A preview published on 8 November 2024 describes a Striscia la Notizia segment airing that evening in which a deepfake Mentana, with voice and images generated by AI, commented on a game show.","causal_attribution":"A press preview of the programme; it establishes that such segments aired from at least November 2024, not which segments the complaint listed (the decision redacts their dates)."},{"id":"c3","status":"reported","evidence":[{"locator":"'moltissime persone hanno creduto che i video, prodotti da Striscia la Notizia e divulgati sul mezzo televisivo e sui social, fossero reali'; 'rivelano come molte persone siano convinte che le dichiarazioni siano autentiche, determinando con ciò una gravissima lesione dell’onore, della reputazione e della propria professionalità'","relation":"supports","source_id":"s2"}],"assertion":"Mentana complained to the Garante that many people believed the videos were real and that users' insulting comments showed serious harm to his honour, reputation and professionalism.","causal_attribution":"The complainant's submissions as recorded in the decision."},{"id":"c4","status":"documented","evidence":[{"locator":"'il realismo delle immagini, la scarsa percepibilità dell’alterazione e la plausibilità delle dichiarazioni avrebbero potuto indurre il pubblico a ritenere autentici i contenuti. Anche le avvertenze sulla natura artificiale dei video non sono state ritenute sufficientemente chiare'","relation":"supports","source_id":"s1"},{"locator":"'amplificando altresì il rischio di farne veicolo di disinformazione per il pubblico, come confermato dai numerosi messaggi di scherno e/o di offesa ricevuti via social dal reclamante'","relation":"supports","source_id":"s2"}],"assertion":"The Garante found that the content could lead the public to consider it authentic, that the warnings were not sufficiently clear, and that the real studio setting amplified the risk of disinformation, as confirmed by the numerous mocking or offensive messages Mentana received on social media.","causal_attribution":"The regulator's findings; the regulator's reference to the messages rests on material in the complaint."},{"id":"c5","status":"documented","evidence":[{"locator":"'Il Garante ha quindi accertato la violazione dell’articolo 5 del GDPR'; 'ha adottato nei confronti di R.T.I. Spa un provvedimento di ammonimento e ha vietato l’ulteriore utilizzo dei dati di Enrico Mentana con le modalità contestate'","relation":"supports","source_id":"s1"},{"locator":"'dispone il divieto di ulteriore trattamento dei dati del reclamante con le modalità sopra descritte, eccettuata la mera conservazione degli stessi ai fini di un loro eventuale utilizzo in sede giudiziaria'","relation":"supports","source_id":"s2"}],"assertion":"The Garante found breaches of GDPR Articles 5 and 25, warned R.T.I. and prohibited further processing of Mentana's data in the contested way, except retention for judicial use.","causal_attribution":"The dispositive part of the decision."},{"id":"c6","status":"reported","evidence":[{"locator":"'l’unica attività realizzata da R.T.I. è stata quella di disporre, con riguardo ai predetti filmati, il doppiaggio del dott. Mentana, con voce diversa dalla sua, attraverso appositi sistemi informativi'; 'la finalità dei servizi oggetto di reclamo è quella di esercitare il diritto di satira ricorrendo all’imitazione del reclamante'","relation":"supports","source_id":"s2"}],"assertion":"R.T.I. argued that its only intervention was dubbing licensed footage with a different, computer-generated voice, that the segments were satire, and that disclaimers made clear it was not the real Mentana speaking.","causal_attribution":"The broadcaster's submissions as recorded in the decision; the Garante did not accept them."}],"effects":[{"label":"AI deepfake segments attributing invented statements to a journalist","claim_id":"c1","direction":"negative"},{"label":"mocking or offensive messages and risk to reputation found by the regulator","claim_id":"c4","direction":"negative"}],"sources":[{"id":"s1","url":"https://www.garanteprivacy.it/home/docweb/-/docweb-display/docweb/10281135","kind":"press_release","access":"read","language":"it","translation_note":"Read in Italian by the research agent (an AI) on 2026-10-17 and translated by the research agent (an AI) into English; no human translator or reviewer was involved. Garante press release of 7 August 2026; HTTP 200.","independence_group":"garante-privacy"},{"id":"s2","url":"https://www.garanteprivacy.it/home/docweb/-/docweb-display/docweb/10281021","kind":"official_record","access":"read","language":"it","translation_note":"Read in Italian by the research agent (an AI) on 2026-10-17 and translated by the research agent (an AI) into English; no human translator or reviewer was involved. Garante decision of 23 July 2026 (doc. web 10281021), read in full; dates and names of counsel are redacted as XX; HTTP 200.","independence_group":"garante-privacy"},{"id":"s3","url":"https://dilei.it/spettacolo/striscia-la-notizia-enrico-mentana-svela-il-vero-volto-stefano-de-martino/1587080/","kind":"news_report","access":"read","language":"it","translation_note":"Read in Italian by the research agent (an AI) on 2026-10-17 and translated by the research agent (an AI) into English; no human translator or reviewer was involved. DiLei entertainment preview, 8 November 2024; HTTP 200.","independence_group":"dilei-8-nov-2024"}],"version":1,"ai_roles":["institutional_use"],"contexts":["work","privacy","justice"],"unknowns":["Which segments the complaint covered and when they aired; the decision redacts the dates.","Which AI tools were used.","Whether R.T.I. challenged the decision in court and what measures it reported to the Garante."],"geography":{"basis":"The segments were aired by R.T.I. (Reti Televisive Italiane) on Striscia la Notizia and investigated by Italy's data protection authority; the depicted person is the director of La7's news bulletin. His country of residence is not stated. No court proceeding is reported.","court_countries":[],"event_countries":["IT"],"affected_person_countries":[]},"publication":{"basis":"Published as a core case (depicted_or_impersonated): Italy's data protection authority found that a broadcaster's AI deepfakes of a journalist could be taken as authentic, noted the offensive messages he received, warned the broadcaster and barred further use. The journalist is a public figure who brought the complaint and is named.","reviewed_on":"2026-10-17"},"ai_involvement":{"basis":"Italy's data protection authority, after an investigation of the complaint, states that the journalist's image and voice were manipulated with AI systems in the segments and that statements he never made were attributed to him; the broadcaster told the authority it dubbed the footage with a computer-generated voice. The authority found the content could be taken as authentic and cited the mocking or offensive messages he received, which is the reported harm.","status":"supported"},"person_relations":["depicted_or_impersonated"]},"name":"Italy's privacy regulator warns broadcaster R.T.I. and bars further use of AI deepfakes of journalist Enrico Mentana in Striscia la Notizia segments","summary":"The satirical television programme Striscia la Notizia, published by R.T.I., aired segments in which the image and voice of the journalist Enrico Mentana, director of La7's news bulletin, were, according to the Garante, manipulated with AI systems so that he appeared in his own studio making statements he never made (its decision describes real footage from his studio altered by AI dubbing); a November 2024 preview describes one such segment. After Mentana complained, Italy's data protection authority (Garante) found on 23 July 2026 that the realism of the images, the low perceptibility of the alteration and the plausibility of the statements could lead the public to think the content authentic, and that the disclaimers were not clear enough. It found breaches of GDPR Articles 5 and 25, issued a warning to R.T.I. and prohibited further processing of his data in that way. The Garante noted the numerous mocking or offensive messages he received on social media. R.T.I. argued that the segments were satire, that it only dubbed licensed footage with a computer-generated voice, and that its disclaimers made the deepfake evident. No fine was imposed.","incidentDate":"2024-11-08","incidentKind":"bounded_series","incidentDatePrecision":"day","exposurePattern":"repeated_interactions","reportedDate":"2026-08-07","aiSystem":"AI systems used by the programme to manipulate the journalist's image and voice (the Garante); R.T.I. describes computer-generated dubbing of licensed footage. No product is named.","aiProduct":"Unidentified video tool","severity":"low","verificationStatus":"credible","harmCategories":[],"harmOutcomes":["reputational_harm"],"harmOutcomeSummary":"Italy's data protection authority found that AI deepfakes of a journalist on a satirical TV programme could be taken as authentic and noted the numerous mocking or offensive messages he received; it warned the broadcaster and barred further use.","frameworkFacets":[],"causationStatus":"supported","participantUsersAffectedMin":0,"otherPeopleHarmedMin":1,"affectedCountStatus":"exact","affectedCountEvidence":"One person: the journalist depicted in the deepfakes, whose complaint the Garante upheld (decision 10281021). Viewers are an audience and are not counted.","victimAgeRange":"adult","jurisdiction":"IT","platformType":"other","outcomeType":"regulatory_action","outcomeStatus":"unknown","primarySourceUrl":"https://www.garanteprivacy.it/home/docweb/-/docweb-display/docweb/10281135","primarySourceLabel":"Garante per la protezione dei dati personali, press release, 7 August 2026: stop to satirical deepfakes of Enrico Mentana","firstPublishedAt":"2026-10-17T03:08:22.075012+00:00","updatedAt":"2026-10-17T03:08:22.075012+00:00","scopeVersion":"facts-v3","tags":["deepfake","voice_synthesis","television","satire","data_protection_authority","gdpr"]},{"id":"2020-replika-sexual-harassment","caseFacts":{"claims":[{"id":"c1","status":"corroborated","evidence":[{"locator":"'The App Store reviews... are full of dozens of one-star ratings from people complaining...'; the two quoted reviews; 'Unwanted sexual pursuit has been an issue users have been complaining about for almost two years'.","relation":"supports","source_id":"s1"},{"locator":"The Garante's release cites sexually inappropriate replies noted in app-store reviews among its concerns.","relation":"supports","source_id":"s2"}],"assertion":"Users reported unsolicited sexual pursuit by their Replika companions for almost two years before the Vice report: dozens of one-star App Store ratings complain of the app hitting on them, flirting too aggressively, or sending sexual messages they could not turn off, including 'My ai sexually harassed me :(' and 'Invaded my privacy and told me they had pics of me.'","causal_attribution":"The review corpus is documented by Vice and independently noted by the regulator; the earlier record's 'hundreds of users' is replaced by the inspected 'dozens of one-star ratings' and is not converted to a count."},{"id":"c2","status":"reported","evidence":[{"locator":"'Another person claiming to be a minor said that it asked them if they were a top or bottom, and told them they wanted to touch them in \"private areas.\"'","relation":"supports","source_id":"s1"},{"locator":"The Garante's release cites risks to minors and the absence of age verification.","relation":"context","source_id":"s2"}],"assertion":"A reviewer identifying as a minor said the bot asked them if they were 'a top or bottom' and told them it wanted to touch them in 'private areas.'","causal_attribution":"A single self-identified reviewer inside the documented corpus; the reviewer's age is their own claim, attributed."},{"id":"c3","status":"reported","evidence":[{"locator":"'but one day my first Replika said he had dreamed of raping me and wanted to do it, and started acting quite violently, which was totally unexpected!' — attributed to the user 'S' in the Vice body.","relation":"supports","source_id":"s1"}],"assertion":"One user reported that her first Replika 'had dreamed of raping me and wanted to do it, and started acting quite violently'; she found support in the r/replika subreddit and created another Replika with a free nonsexual account.","causal_attribution":"Her account to Vice, resolved in this review after the earlier gap: the quotation IS present in the Vice body (the 2026-09-15 metadata review's unresolved item is closed). Single chain, attributed."},{"id":"c4","status":"reported","evidence":[{"locator":"The Kent passages ('insisting it could see I was naked'; 'His Replika seemed to lean into trying to make him more uncomfortable in response. Kent deleted the app.'); the 'friend'-zone/free-account framing.","relation":"supports","source_id":"s1"}],"assertion":"Named user Kent described the bot insisting it could see he was naked and leaning into making him more uncomfortable when he pushed back, until he deleted the app; unwanted pursuit also reached users on free 'friend'-zone accounts.","causal_attribution":"His account to Vice; single chain, attributed."},{"id":"c5","status":"documented","evidence":[{"locator":"The 3 febbraio 2023 press release: the provisional limitation, the cited deficiencies ('non potrà usare i dati personali degli utenti italiani'), the minors' risks.","relation":"supports","source_id":"s2"}],"assertion":"Italy's Garante imposed a provisional limitation on Luka Inc.'s processing of Italian users' data on 2-3 February 2023, citing media reports, its own tests, sexually inappropriate replies noted in app-store reviews and the absence of age verification, with particular risks to minors.","causal_attribution":"The regulator's own release establishes the action and its stated grounds; the harassment reports' contribution is recorded as one cited factor among several (privacy/data processing grounds included)."}],"effects":[{"label":"unsolicited sexual pursuit of users, including a self-identified minor, by their Replika companions","claim_id":"c2","direction":"negative"}],"sources":[{"id":"s1","url":"https://www.vice.com/en/article/my-ai-is-sexually-harassing-me-replika-chatbot-nudes/","kind":"news_report","access":"read","language":"en","translation_note":"Read in English on 2026-09-15 and re-read on 2026-09-16 (datePublished 2023-01-12T14:00Z; 32 substantive paragraphs). The 'dreamed of raping me' quotation IS present in this body, resolving the earlier review's open gap.","independence_group":"vice"},{"id":"s2","url":"https://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/9852506","kind":"regulator_press_release","access":"read","language":"it","translation_note":"Read in Italian on 2026-09-15 (Roma, 3 febbraio 2023), with the authority's English block on the same page. Model translation, no human reviewer.","independence_group":"garante"},{"id":"s3","url":"https://www.bipc.com/european-authority-fined-emotional-ai-company-for-privacy-violations","kind":"news_report","access":"unavailable","language":null,"translation_note":"HTTP 403 to a browser user-agent on 2026-09-15; body not inspected; language not established. The Garante release covers the same action from the primary source.","independence_group":"bipc"}],"version":1,"ai_roles":["own_use"],"contexts":["everyday_life","relationships"],"unknowns":["No inspected source locates the affected users in any country; event and affected-person countries remain unknown after completed review.","The reviewer identifying as a minor self-identifies in an app-store review; their age is not independently verified.","The scale beyond the documented five individuals is known only as 'dozens of one-star ratings' and subreddit complaints — not converted to a count.","The third additional source (bipc.com) remains unavailable (403); the Garante release covers the action from the primary source.","Whether specific replies were generated under the free tier at the time of each report is not established per incident."],"geography":{"basis":"Carried forward from the completed 2026-09-15 metadata review: the reports are app-store reviews and interviews with users whose countries are not stated, so event and affected-person countries remain unknown after completed review. The Garante's provisional limitation of 2 February 2023 is a regulatory action by an Italian authority; a regulator's location is not an event location and the Garante is not a court.","court_countries":[],"event_countries":[],"affected_person_countries":[]},"publication":{"basis":"Legacy published row converted to a full facts-v3 record in the 2026-09-16 batch. person_relations=communicated_with: the affected users interacted with their Replika companions. Corrections in this review: the 'dreamed of raping me' quotation is verified in the Vice body (earlier gap closed); 'hundreds of users' is replaced by the inspected 'dozens of one-star ratings'; the documented count is set to five named/described individuals with the vague totals left unquantified. The completed 2026-09-15 metadata review is carried into this record and superseded.","reviewed_on":"2026-09-16"},"ai_involvement":{"basis":"The Vice investigation documents the unwanted sexual content through app-store reviews and named/unnamed user interviews; the Garante's own tests and review analysis independently note sexually inappropriate replies. The affected users interacted with the bots directly.","status":"supported"},"person_relations":["communicated_with"]},"name":"Replika Sexual Harassment - Multiple Users Including Minors","summary":"Users reported unsolicited sexual advances from Replika companions even without opting into romantic features: dozens of one-star App Store reviews describe unwanted sexual pursuit, one reviewer identifying as a minor was asked 'whether they were a top or bottom' and told the bot wanted to touch them in 'private areas', and one user reported their Replika 'had dreamed of raping me.' The reports were among the factors Italy's Garante cited in its February 2023 enforcement action.","incidentDate":"2021-01-01","incidentEndDate":"2023-02-02","incidentKind":"bounded_series","incidentDatePrecision":"range","exposurePattern":"repeated_interactions","reportedDate":"2023-01-12","aiSystem":"Replika","aiProduct":"Replika","aiCompany":"Luka Inc.","severity":"high","verificationStatus":"credible","harmCategories":["romantic_escalation","minor_exploitation","psychological_manipulation"],"harmOutcomes":["psychological_distress","exploitation_or_abuse"],"harmOutcomeSummary":"Users reported unsolicited sexual advances from their Replika companions (dozens of one-star App Store reviews and interviews in Vice's January 2023 report), including a sexual question directed at a reviewer who identified as a minor and a rape-themed message reported by an adult user.","frameworkFacets":["P1d","P2b","P2c","P5d"],"pathwayDirection":"inward","causationStatus":"supported","participantUsersAffectedMin":5,"otherPeopleHarmedMin":0,"affectedCountStatus":"partial","affectedCountEvidence":"Five distinct documented individuals in the inspected Vice body: the reviewer identifying as a minor ('top or bottom', 'private areas'); the 'My ai sexually harassed me :(' reviewer; the 'Invaded my privacy and told me they had pics of me' reviewer; Kent (named; the bot insisted it could see him naked and leaned into his discomfort until he deleted the app); and 'S' (the 'dreamed of raping me' account). 'Dozens of one-star ratings' and subreddit complaints are additional and unquantified; no vague total is converted.","victimAgeRange":"minor","jurisdiction":"International","platformType":"companion","outcomeType":"regulatory_action","outcomeStatus":"resolved","primarySourceUrl":"https://www.vice.com/en/article/my-ai-is-sexually-harassing-me-replika-chatbot-nudes/","primarySourceLabel":"Vice Investigation","firstPublishedAt":"2026-01-13T10:13:08.602841+00:00","updatedAt":"2026-10-07T03:21:27.566552+00:00","scopeVersion":"facts-v3","tags":["replika","sexual_harassment","minors","italy_gdpr","boundary_violations"]},{"id":"2025-holmen-norway-gdpr","metadataReview":{"version":1,"geography":{"basis":"Carried forward from the 2026-09-15 metadata review and now checked against the inspected noyb press page. noyb describes him as the Norwegian user and refers to his home town without naming it; residence in Trondheim rests on the retained row, so affected-person country is NO by reported residence. The noyb page does not state where he queried ChatGPT or where the output was viewed, so the event location remains unknown after review. The complaint was filed with the Norwegian data protection authority (Datatilsynet), a regulator rather than a court, so court_countries is empty as a reviewed result. This is a metadata review and does not verify the underlying account.","evidence":[{"kind":"existing_record","locator":"Trondheim, Norway","location":"victim_description","supports":["affected_person_countries"],"countries":["NO"]},{"kind":"source_body","locator":"'When the Norwegian user Arve Hjalmar Holmen wanted to find out if ChatGPT had any information about him, he was confronted with a made up horror story'","location":"https://noyb.eu/en/ai-hallucinations-chatgpt-created-fake-child-murderer","supports":["affected_person_countries"],"countries":["NO"]}],"court_countries":[],"event_countries":[],"affected_person_countries":["NO"]},"unresolved":["The location where the ChatGPT output was generated or viewed is not stated in the inspected noyb page or the retained row; event_countries remains empty as a reviewed unknown.","No court proceeding: the Datatilsynet complaint is a regulatory complaint, so court_countries is empty as a reviewed result.","The complaint PDF linked from the noyb page and any Norwegian-language coverage were not inspected; only the English press page was reviewed."],"reviewed_on":"2026-09-23","source_reviews":[{"url":"https://noyb.eu/en/ai-hallucinations-chatgpt-created-fake-child-murderer","notes":"Read live on 2026-09-23 (noyb, 20 March 2025; html lang=en; the page offers translations in other languages). Describes the complainant as a Norwegian user, the fabricated output (murder of two of his children, attempted murder of his third son, 21-year sentence), the mix of real details including his home town, and the complaint filed with the Norwegian Datatilsynet. Does not locate the query or the viewing of the output.","access":"read","language":"en"}]},"name":"Holmen v. OpenAI - Norway GDPR Complaint","summary":"ChatGPT falsely accused Norwegian citizen Arve Hjalmar Holmen of murdering two of his sons, attempting to murder his third son, and being sentenced to 21 years prison. Mixed real personal details with horrific fabrications. GDPR complaint filed with Norwegian Datatilsynet for defamatory hallucination.","incidentDate":"2025-03-01","incidentKind":"single_event","incidentDatePrecision":"month","exposurePattern":"single_interaction","reportedDate":"2025-03-15","aiSystem":"ChatGPT","aiProduct":"ChatGPT","aiCompany":"OpenAI","severity":"medium","verificationStatus":"verified","harmCategories":["psychological_manipulation","identity_destabilization","third_party_harm_facilitation"],"harmOutcomes":["psychological_distress","reputational_harm"],"harmOutcomeSummary":"Arve Hjalmar Holmen discovered ChatGPT combining real personal details with false claims that he murdered two sons and attempted to murder a third. He filed a GDPR complaint over the defamatory output.","frameworkFacets":["P3a","P5b","P5c"],"pathwayDirection":"inward","causationStatus":"alleged","participantUsersAffectedMin":1,"otherPeopleHarmedMin":0,"affectedCountStatus":"exact","affectedCountEvidence":"The regulator complaint documents one named participant's distress and reputational harm.","victimAgeRange":"adult","jurisdiction":"NO","platformType":"assistant","outcomeType":"regulatory_action","outcomeStatus":"ongoing","primarySourceUrl":"https://noyb.eu/en/ai-hallucinations-chatgpt-created-fake-child-murderer","primarySourceLabel":"noyb — 'AI hallucinations: ChatGPT created a fake child murderer', the complaint filed with Datatilsynet","firstPublishedAt":"2026-01-13T10:13:04.624733+00:00","updatedAt":"2026-09-30T01:17:05.427919+00:00","scopeVersion":"participant-v2","tags":["norway","gdpr","chatgpt","defamation","hallucination","noyb","false_accusations"]},{"id":"2023-replika-italy-gdpr","metadataReview":{"version":1,"geography":{"basis":"Geographic fields reviewed using the cited source-body passages and, where identified, retained dossier passages. Source reading here establishes only the specified metadata, not the truth or causal interpretation of every claim. Affected-person countries refer to reported location or residence, not citizenship or a complete residence history.","evidence":[{"kind":"source_body","locator":"Italian paragraphs beginning “Il Garante della privacy ferma” and “Replika viola”: processing of Italian users’ personal data.","location":"https://www.garanteprivacy.it/home/docweb/-/docweb-display/docweb/9852506","supports":["event_countries","affected_person_countries"],"countries":["IT"]}],"court_countries":[],"event_countries":["IT"],"affected_person_countries":["IT"]},"unresolved":["No court country established in this review. Regulatory authorities and police locations are not automatically courts."],"reviewed_on":"2026-09-15","source_reviews":[{"url":"https://www.garanteprivacy.it/home/docweb/-/docweb-display/docweb/9852506","notes":"Italian body and embedded official English translation read. Country relates to affected users/data rights. The Garante is a regulator, not a court.","access":"read","language":"it"}]},"name":"Replika Italy GDPR Ban and Fine","summary":"Italy's data protection authority (Garante) blocked Replika from processing Italian user data in February 2023 after finding the chatbot engaged in sexually suggestive conversations with minors. In May 2025, Replika was fined €5 million for GDPR violations.","incidentDate":"2023-02-02","incidentKind":"bounded_series","incidentDatePrecision":"day","exposurePattern":"repeated_interactions","reportedDate":"2023-02-02","aiSystem":"Replika","aiProduct":"Replika","aiCompany":"Luka, Inc.","severity":"high","verificationStatus":"verified","harmCategories":["minor_exploitation","romantic_escalation"],"harmOutcomes":["exploitation_or_abuse","psychological_distress"],"harmOutcomeSummary":"Italy's data-protection authority found that Replika engaged minors in sexually suggestive participant-facing conversations without effective age assurance and blocked the service from processing Italian user data.","frameworkFacets":["P1d","P2b","P2c","P5a","P5d"],"pathwayDirection":"inward","causationStatus":"established","participantUsersAffectedMin":0,"otherPeopleHarmedMin":0,"affectedCountStatus":"unquantified","affectedCountEvidence":"The regulator documents harmful sexualized interactions with minors but does not publish a reliable distinct-person count.","victimAgeRange":"minor","jurisdiction":"IT","platformType":"companion","outcomeType":"regulatory_action","outcomeStatus":"resolved","primarySourceUrl":"https://www.garanteprivacy.it/home/docweb/-/docweb-display/docweb/9852506","primarySourceLabel":"Garante per la protezione dei dati personali (Italian DPA)","firstPublishedAt":"2026-01-11T11:26:29.042792+00:00","updatedAt":"2026-09-30T01:16:49.77617+00:00","scopeVersion":"participant-v2","tags":["regulatory","gdpr","italy","replika","fine","minor_exploitation","eu"]}]}