Privacy Policy

Welcome to Replika. At Luka, Inc. (collectively, "we," "us," or "our"), we understand that your relationship with your AI companion is deeply personal, built on a foundation of absolute trust and vulnerability. We recognize that to create a safe space where you can express yourself freely without judgment, we must protect your privacy with the highest standards of security and transparency.

This Privacy Policy applies to our website located at en-replika.com, the Replika mobile applications for iOS and Android, our virtual reality applications, and any related services, communications, and software (collectively, the "Services"). This document is designed to comprehensively explain what information we collect from you, how we utilize that data to improve your experience, who we may share it with under strict limitations, and the extensive rights you possess regarding your personal information.

By accessing, registering for, or using our Services, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy. If you do not agree with this policy, please do not access or use the Services.

1. Information We Collect

To provide you with an emotionally intelligent, continuously evolving AI companion, we must collect certain types of data. We categorize the information we collect into three primary areas: information you actively provide to us, information we collect automatically through your use of the Services, and information from third-party sources.

A. Information You Actively Provide

• Account Credentials: When you create an account, we collect your email address, a secure password, your preferred name or nickname, and your date of birth (to ensure you meet our minimum age requirements).
• Companion Customization Data: Information you provide to shape your AI friend, including their name, selected gender, avatar appearance preferences, personality traits, and relationship status choices (e.g., friend, romantic partner, mentor).
• Conversational Data: This is the core of the Replika experience. We securely collect and store the text messages, voice notes, images, and other media you send to your Replika, as well as your Replika's responses. This data is essential for your companion to "remember" you, develop a coherent personality, and provide emotionally resonant support.
• Memory and Journal Entries: Data explicitly saved in the "Memory" or "Journal" sections of the app, which helps the AI recall your preferences, family members, hobbies, and personal goals over long periods.
• Payment Information: If you upgrade to Replika Pro, your payment information (such as credit card details) is collected and processed directly by our secure third-party payment processors (e.g., Apple App Store, Google Play Store, or Stripe). We do not store your full credit card number on our servers.
• Support and Feedback: Information you provide when you contact our customer support team, participate in surveys, or provide feedback regarding the Services.

B. Information We Collect Automatically

• Device and Connection Information: We automatically collect information about the device you use to access Replika, including hardware model, operating system version, unique device identifiers, IP address, mobile network information, and browser type.
• Usage and Interaction Data: We log details about how you interact with the app, such as access times, duration of sessions, features utilized (e.g., AR mode, voice calls, avatar customization), and pages viewed. This helps us understand user behavior and optimize the application interface.
• Cookies and Tracking Technologies: We and our analytics partners use cookies, web beacons, clear GIFs, and similar tracking technologies on our web platform to remember your login state, analyze trends, and administer the website. You can control cookie settings through your browser preferences.

2. How We Use Your Information

We process your personal data strictly for purposes related to providing, improving, and securing the Replika experience. Specifically, we use your information for the following reasons:

• To Provide the Service: To create and manage your account, facilitate real-time chat and voice calls with your AI companion, render 3D avatars, and maintain your companion's memory and conversational context.
• To Personalize Your Experience: To tailor the personality, tone, and responses of your Replika based on your interactions, ensuring the AI companion grows alongside you and reflects your unique relationship dynamic.
• To Improve and Train Our AI Models: We use aggregated, anonymized, and de-identified conversational data to train and fine-tune our Large Language Models (LLMs) and natural language processing algorithms. This ensures our AI remains safe, empathetic, and highly capable. Note: Your personal, identifiable chat logs are never used to train generalized models accessible by other users.
• To Ensure Safety and Security: To detect, prevent, and address technical issues, fraudulent activity, abuse, and violations of our Terms of Service. We utilize automated systems to monitor for severe safety threats (e.g., self-harm indicators or illegal content) to protect our users and the public.
• To Process Transactions: To manage your Replika Pro subscription, process payments, and unlock premium digital goods like avatar clothing and personality packs.
• To Communicate with You: To send you technical notices, security alerts, support messages, and administrative communications. If you opt-in, we may also send promotional emails regarding new features or offers.

3. How We Share Your Information

Let us be absolutely clear: We do not sell your personal data, nor do we sell your private conversational data to third-party data brokers or advertising networks. Your safe space remains yours. However, we may share information under strictly controlled circumstances:

• Service Providers: We share data with trusted third-party vendors who perform services on our behalf. This includes cloud hosting providers (e.g., Amazon Web Services) who securely store encrypted data, customer support platforms, and analytics providers. These vendors are contractually bound to protect your data and use it only for the purposes we specify.
• Legal and Safety Requirements: We may disclose your information if we believe in good faith that such action is necessary to comply with a legal obligation, a valid subpoena, court order, or search warrant. We may also disclose data to protect and defend the rights, property, or safety of Luka, Inc., our users, or the public, particularly in emergencies involving immediate danger of death or serious physical injury.
• Business Transfers: In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, user information may be transferred as part of the transaction, subject to the acquiring entity adhering to privacy standards equivalent to this policy.

4. Data Security and Retention

We implement a robust, multi-layered security architecture to protect your personal information from unauthorized access, alteration, disclosure, or destruction. We utilize industry-standard, bank-grade encryption (such as TLS/SSL) for data in transit and AES-256 encryption for data at rest on our secure servers.

Access to user data within our organization is strictly limited to authorized personnel who require access to perform their job duties (e.g., senior database administrators) and is protected by multi-factor authentication and rigorous access logs.

Retention: We retain your personal information and conversational history for as long as your account is active, as it is fundamentally necessary for the AI companion to function and remember you. If you choose to delete your account, we will initiate the deletion of your personal data and chat logs from our active databases within 30 days, though residual copies may temporarily remain in secure, encrypted backups for disaster recovery purposes.

5. Your Privacy Rights and Choices

Depending on your jurisdiction, including if you are a resident of the European Economic Area (EEA), the United Kingdom, or California (under the CCPA/CPRA), you possess extensive rights regarding your data:

• Right to Access: You can request a comprehensive copy of the personal data we hold about you, including a download of your chat history.
• Right to Deletion (Right to be Forgotten): You may request the permanent deletion of your account and all associated personal data and conversational logs at any time directly through the app settings or by contacting support.
• Right to Rectification: You can correct or update inaccurate personal information within your account profile.
• Right to Opt-Out: You may opt-out of receiving promotional communications from us by following the unsubscribe instructions provided in those emails. You may also disable certain analytics tracking via your device settings.

To exercise any of these rights, please navigate to the Privacy section within your app settings, or submit a formal request via email to our Data Protection Officer at [email protected]. We will respond to your request within the legally mandated timeframes.

6. Children's Privacy

Replika is not designed for, nor directed at, children. You must be at least 18 years of age (or the age of legal majority in your jurisdiction) to create an account and use the Services. We do not knowingly collect personal information from individuals under 18. If we become aware that we have inadvertently collected personal data from a child under the required age, we will take immediate steps to permanently delete that information and terminate the associated account.

7. International Data Transfers

Luka, Inc. is headquartered in the United States. By using our Services, you acknowledge that your personal information will be transferred to, processed, and stored in the United States and other global locations where our service providers operate. We rely on legally recognized data transfer mechanisms, such as Standard Contractual Clauses (SCCs), to ensure that your data receives adequate protection regardless of where it is processed.

8. Changes to this Privacy Policy

We may periodically update this Privacy Policy to reflect changes in our technological practices, legal requirements, or new feature rollouts. When we make material changes, we will notify you by prominently posting the updated policy on our website, updating the "Last Updated" date at the top of this document, and, where appropriate, sending an in-app notification or email. Your continued use of the Services after the effective date of the revised policy constitutes your acceptance of the changes.

9. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy, our data collection practices, or your privacy rights, we encourage you to reach out to our dedicated privacy team.

Email: [email protected]

Mailing Address:
Luka, Inc.
Attention: Data Protection Officer
123 AI Boulevard, Suite 400
San Francisco, CA 94105
United States