Replika is the companion app that started the category: a personal AI you name, shape and talk to over months, made by Luka Inc of Delaware, on the web and in iOS and Android apps, with a Free Use tier, a Pro subscription that opens the relationship features, and an Ultra tier above it. It is also the companion app with the longest regulatory record, and that record is why a proxy company has to write this page carefully rather than cheerfully.
Two documents set the terms of the discussion. One is the Italian data-protection authority's order of February 2023 and its EUR 5 million fine of May 2025. The other is Replika's own terms of service, revised 30 March 2026, which name proxy IP addresses as something a blocked user may not use. Between them they leave a proxy one narrow, legitimate job on Replika, and this page describes that job and refuses the rest.
Italy: an order, then a fine
In February 2023 the Garante issued urgent measure 39/2023 restricting Replika's processing of Italian users' data under Article 58(2)(f) of the GDPR, a measure the authority itself describes as having ordered the application blocked. On 19 May 2025 it fined Luka Inc EUR 5 million. Its press release lists the findings: as at 2 February 2023 the company had not identified the legal bases for its processing, its privacy policy was inadequate in several respects, and it had no mechanism whatsoever for verifying users' age, despite the app's declared exclusion of minors. The authority also opened a separate inquiry into how the generative model behind the service processes data. We searched for a later act lifting the 2023 order and found none.
Set that next to the terms. Replika's terms of service say that if you are blocked by Replika from accessing the services, including by blocking your IP address, you agree not to implement any measures to circumvent such blocking, and the examples in the clause are masking your IP address or using a proxy IP address. A user in Italy routing around the block would be crossing a regulator's order and Replika's contract at once. The mechanics of a residential address in another country are not in doubt; what the address would be used for is, and this is a case we decline.
2023-02-02
Garante urgent measure 39/2023
processing of Italian users' data restricted; app ordered blocked
2025-01-28
FTC complaint filed by advocacy groups
a request for investigation, not a ruling
2025-05-19
EUR 5 million fine
no legal basis, inadequate privacy policy, no age verification
2026-03-30
Terms of service revised
under-18s excluded; no circumventing IP blocks by proxy
What the contract and the help centre settle
Replika's terms bar anyone under 18 from the services, prohibit data mining, robots, scraping and similar extraction, and carry the IP-block clause above. Its help centre describes the tiers: Free Use gives limited access at no cost and, in the help centre's own words, access to Free Use may be denied at Replika's discretion; Pro gives full access to the relationship status, premium activities, selfies, image generation, voice messaging, background calls, daily gems and premium voices; an Ultra tier sits above Pro.
Everything in that list is decided on the account. An address does not add gems, unlock a relationship status, or restore Free Use once Replika has withdrawn it. And the extraction ban means the unofficial scrapers of Replika conversations are a terms problem no IP solves. We make the same point about every AI service in this series and it needs no special argument here.
Reputation is not the wall
Most companion sites in this series sit behind Cloudflare and turn away shared addresses at the edge; Character.AI refused half of the free exits we sent it. Replika does not. replika.com answered our requests without Cloudflare's headers, and in our test on 24 August 2026 the site served its ordinary front page to all 22 free exits that reached it, no challenge, no block. That tells you something useful about where Replika's walls are: not at the network edge but in the account, the age rule, and, in one country, the regulator.
It does not make free proxies a good idea. A Replika account holds months or years of private conversation behind one login, and a free proxy is a server run by someone you cannot see, sitting on that login's traffic. The case against it is in are free proxies safe, and it is stronger here than almost anywhere.
A clean, static IP moves
A network that filters Replika
school, office, a restrictive ISP; account otherwise in good standing
Where a paid account appears from
one place, every day
It never touches
The Italian order
a regulator's measure, and the terms forbid circumvention
Free Use, Pro and Ultra features
per account; Free Use may be denied at Replika's discretion
The 18+ rule
in the terms, and the very finding the Garante fined
The scraping ban
an address is not permission
The narrow case that remains
A school, an office or a restrictive ISP that filters replika.com or the app's servers is a reachability problem, and for an adult account in a country where Replika is offered, a proxy is the fix. The app follows a proxy only through the phone's Wi-Fi settings (Android, iPhone); the website follows the browser or the operating system (Chrome, Windows). The address should be static, yours alone, and kept from sign-in to sign-out, because a companion account is the last thing that should look like it is being used from three countries at once. Confirm the exit with the proxy checker before the first login.
Where HProxy fits
For that case the purchase is small: an ISP line of your own for $2.70/IP a month, or a residential session in a country where Replika is offered, priced from $0.44/GB, either one billed on use with no KYC. A chat app barely registers on a bandwidth meter.
For Italy, for Free Use that Replika has withdrawn, for a second account, or for anyone under 18, the answer from us is no, and the reasons are written in Replika's own contract and in a regulator's fine. A proxy company that will sell into those is not reading the documents. We did, and this page is what they say.
Sources
- Garante per la protezione dei dati personali, press release of 19 May 2025: the EUR 5 million fine on Luka Inc, the February 2023 block, and the findings on legal basis, privacy policy and age verification.
- IAPP, Italy's DPA reaffirms ban on Replika: measure 39/2023 under Article 58(2)(f) GDPR.
- Replika, Terms of Service, last updated 30 March 2026: the under-18 exclusion (6.4), the scraping ban and the IP-block circumvention clause (8.1).
- Replika Help Center, Choosing a subscription: Free Use, Pro and Ultra.
- TIME, Replika FTC complaint, 28 January 2025.
- Apple App Store, Replika: AI Companion Chat: developer, 18+ rating, subscriptions.
- HProxy measurement, 24 August 2026: 50 free proxies from our list pointed at replika.com; all 22 exits that reached the site received a normal page; no Cloudflare headers observed.