Privacy Policy
Last updated: November 11, 2026
1. Who We Are
The Denominator (“we,” “us” or “our”) operates the website located at thedenominator.ai and the related services described in this Privacy Policy (the “Policy”). The Denominator is the controller of the Personal Data processed under this Policy.
2. About The Denominator
The Denominator is an intelligence company that provides reporting, analysis and data on the AI economy. Our mission is to provide executives with actionable intelligence and data to inform their decisions. Our websites, content, answer engine, indices and related services are designed for executives and business professionals who use artificial intelligence within their organizations.
Individuals who register to use our Services become members (“Members”). Members may receive access to content and features not otherwise available, which may include articles, downloadable materials, videos, events and lists. Membership is provided without charge. In exchange, Members receive content, offers and communications tailored to their professional interests, including from the companies that are our customers, such as sponsors and technology vendors, which may offer products or services relevant to those interests (“Partners”).
3. Scope of This Policy
This Policy applies to the Personal Data of visitors to our website and of Members, collected through our website and related services, including by means of cookies and similar technologies (together, the “Services”). “Personal Data” means any information relating to an identified or identifiable natural person, as defined by the data protection law applicable to you.
Our newsletters are governed by a separate policy, which describes how they are delivered and how to unsubscribe. This Policy does not apply to third-party websites or services linked from the Services, which are governed by their own privacy policies.
4. Personal Data We Collect
We collect Personal Data from business professionals who visit our website, register as Members, read or interact with our content, or express interest in our Services. This generally consists of business contact information, such as name, job title, company and business contact details. We collect Personal Data directly from you, automatically when you use the Services, and from third-party sources and publicly available sources, and we may combine Personal Data from these sources to maintain accurate and complete records. Depending on your use of the Services, we may collect the following categories of Personal Data:
- Personal details: name, preferences and account settings.
- Contact details: business email address, telephone number, business address and social media profile details.
- Professional details: professional profile, job title, role, company, industry, association memberships, qualifications and information about your organization.
- Device details: device and browser type and settings, browsing information, IP address, language and time-zone settings, and connection times.
- Usage and network activity: information about your use of the Services, including registrations, pages viewed, content read, clicks and other interactions, searches, questions submitted, downloads, video activity, and the website that referred you.
- Inferred data: the approximate location and organization associated with an IP address, and the topics and interests indicated by your activity.
- Analysis data: keywords, topics, trends, and measures of the quality and relevance of content.
- Views and interests: comments, ratings, survey responses, topics you follow, and views or opinions you submit through the Services or post publicly on social media platforms.
- Sign-in details: the name, email address and, where available, profile photograph that a third-party provider shares with us when you choose to sign in through an account you hold with that provider.
We do not request sensitive Personal Data, as that term is defined under applicable law.
If you sign in through an account you hold with a third-party provider, that provider’s collection and use of your information are governed by its own terms and privacy policy, not by this Policy. We do not receive the password for that account.
5. How We Use Personal Data
Subject to applicable law, we may process Personal Data for the following purposes:
- Providing the Services: to operate the website and provide the Services, including verifying business email addresses and signing you in.
- Account management: to create, maintain and update Member accounts; to remember your settings and sign-in information; to associate your activity on the Services, including indications of interest in products and services, with your account; and to supplement the Personal Data we hold about you.
- Personalization: to personalize content and recommendations, including sponsored content from Partners.
- Online behavioral advertising: to deliver or display content, advertisements and other materials, including sponsored materials, that correspond to your professional interests and responsibilities.
- Data and research: to create data, insights and research concerning the interests of organizations and Members, for our clients and Partners.
- Sale and sharing of Personal Data: to sell or share Personal Data with third parties, including Partners and clients, as described in Section 9.
- Marketing: to conduct direct marketing and sales by us and by our Partners, on the basis of your consent or our legitimate interests.
- Analytics and improvement: to analyze, secure and improve the Services, including by means of log files recording IP addresses and activity on the Services.
- Product development: to develop our products, services and technology, including artificial intelligence and machine-learning models, as described in Section 6.
- Security, compliance and administration: to maintain the security of the Services, prevent fraud, manage our finances, comply with legal obligations, and notify you of changes to the Services or this Policy.
6. Use of Artificial Intelligence
We use artificial intelligence technologies in our business, including to research, draft, edit and illustrate our content, to analyze data and produce our insights and indices, to operate our answer engine, and to personalize the Services. Content we publish is reviewed by our editors, and The Denominator holds editorial responsibility for the content it publishes. Images generated with artificial intelligence are labeled as such.
When you submit a question to our answer engine or otherwise interact with an AI-enabled feature, we process your input and the resulting output to provide the feature, and we may retain them in accordance with Section 10. Your input may be processed by service providers that supply artificial intelligence technology to us under contract, which are not permitted to use it for their own purposes. Do not submit confidential information or sensitive Personal Data through AI-enabled features.
We do not currently use Members’ questions or activity on the Services to train artificial intelligence or machine-learning models. If we do so in the future, we will update this Policy before we begin and, where required by applicable law, obtain your consent or offer you the opportunity to object. We do not use artificial intelligence to make decisions that produce legal or similarly significant effects for you.
7. Automated Decision-Making, Including Profiling
We use automated, algorithm-based technologies and proprietary analysis to personalize your experience based on the interests you state and those indicated by your activity, and to group Members and organizations by role, company and topic. This processing does not produce legal or similarly significant effects for you.
8. Legal Bases for Processing
If you are located in the United Kingdom, the European Economic Area or Switzerland, we rely on one or more of the following legal bases, depending on the circumstances, when processing your Personal Data for the purposes described in this Policy:
- Consent. Where you are a Member, we may rely on your consent to process your Personal Data to provide the Services, for direct marketing and sales communications by us and our Partners, and to provide you with relevant content. Consent may be obtained at registration or by third parties acting on our behalf, including through affiliated websites and co-branded campaigns. You may withdraw your consent at any time, after which we will cease the processing that relied on it (GDPR, Article 6(1)(a)).
- Legitimate interests. We may process Personal Data where necessary for our legitimate interests in operating, improving and promoting our business, creating our data and insights, and, in certain cases, sharing Personal Data with Partners, provided those interests are not overridden by your rights and interests. You may object to such processing at any time (GDPR, Article 6(1)(f)).
- Contract. We may process Personal Data where necessary to provide the Services you request and to perform our Terms and Conditions (GDPR, Article 6(1)(b)).
- Legal obligation. We may process Personal Data where necessary to comply with a legal obligation, including to maintain appropriate technical and organizational measures to protect Personal Data, to investigate and report actual or suspected breaches of those measures, and to meet regulatory requirements (GDPR, Article 6(1)(c)).
- Vital interests. We may process Personal Data where necessary to protect the vital interests of any person (GDPR, Article 6(1)(d)).
9. Disclosure of Personal Data
We may disclose Personal Data to the following categories of recipients:
- Partners. We disclose Personal Data, including information about your activity on the Services, to Partners for their own direct marketing and sales, based on your interests and interactions with the Services. We currently disclose Members’ Personal Data to Partners only where the Member is located in the United States. Partners are contractually required to use it for business-to-business purposes only and to honor your opt-out requests.
- Clients. We disclose data, insights and research concerning the interests of organizations, which do not identify individuals, and aggregated or de-identified data, to clients for market research, trend analysis and insight into industry topics and growth opportunities.
- Service providers. We disclose Personal Data to service providers and contractors that perform services for us under contract, such as hosting, communications, analytics, security, data and artificial intelligence services. We review such providers to confirm that their policies and procedures are consistent with our data governance standards.
- Business transfers. We may disclose or transfer Personal Data in connection with a merger, acquisition, financing, reorganization or sale of all or part of our business or assets, in which case the recipient will be bound by this Policy.
- Legal requirements. We may disclose Personal Data where required by law, regulation or legal process, or where we believe in good faith that disclosure is necessary to protect our rights, property or safety, or those of our users or others.
10. Data Retention
We retain Personal Data for as long as necessary to provide the Services, comply with our legal obligations, resolve disputes and enforce our agreements. We retain a Member’s Personal Data for as long as the Member’s account remains active and as needed to provide the Services. After an account is closed, we may retain Personal Data where reasonably necessary to comply with legal or regulatory requirements, to prevent fraud and abuse, or to enforce our Terms and Conditions, and for a limited period where requested by a government agency or law enforcement. When Personal Data is no longer required, we delete or de-identify it.
11. Data Security
We maintain administrative, technical and physical safeguards designed to protect Personal Data against loss, misuse and unauthorized access, disclosure, alteration and destruction, including encryption and access controls, and we review those safeguards periodically. No method of transmission or storage is completely secure, and we cannot guarantee the absolute security of Personal Data. We will notify you of a security incident affecting your Personal Data where required by applicable law.
12. Use of Tracking Technologies
In accordance with applicable law, the Services use cookies, tracking pixels, chat features and similar technologies to collect information and to improve your experience. If you use our answer engine or another chat feature, your conversation may be monitored and recorded, and we will tell you within the feature when it is. These technologies may also be used to determine whether our emails have been opened or previewed and whether your email client can display HTML; if it cannot, the tracking element will not function. Consent is not required for technologies that are strictly necessary to provide a feature or service you have requested. Section 13 describes our use of cookies.
13. Cookies and Similar Technologies
Cookies are small data files placed on your device when you visit a website. Cookies and similar technologies enable us to identify and authenticate you, remember your preferences, deliver advertisements relevant to your professional interests, provide aggregated auditing, research and reporting to Partners and clients, understand and improve the Services, and determine whether content has been shown to you. Some cookies are set by us and others by third parties with which we work. Because your browser may request advertisements and similar content directly from third-party advertising servers, those third parties may read, modify or set their own cookies. Advertisements we serve may also set third-party cookies.
We use the following categories of cookies:
- Strictly necessary cookies: necessary for the website to function and to remain secure, including to keep you signed in.
- Performance cookies: measure visits and traffic sources and show how visitors use and navigate the website.
- Functional cookies: remember your choices and personalize content.
- Targeting cookies: personalize advertising and measure its effectiveness, on our website and elsewhere; these may be set by our Partners.
You may manage your choices at any time through the Privacy Manager, available from the Cookie Preferences link in the footer of every page. Where required by law, we use cookies other than strictly necessary cookies only with your consent. You may also configure your browser to refuse or delete cookies. If you decline or delete cookies, certain features of the Services may not function properly, and you may continue to see advertisements, but they will not be tailored to your interests. The Services do not respond to browser Do Not Track signals. Third parties’ use of their own cookies is governed by their own privacy policies.
14. Global Privacy Control
We may sell or share Personal Data for marketing and advertising purposes. Where required by applicable law, we treat a Global Privacy Control signal sent by your browser or device as a request to opt out of the sale or sharing of Personal Data and of targeted advertising with respect to that browser or device.
15. International Data Transfers
We are located in the United States, and the Services are operated from the United States. Personal Data you provide to us or that we collect through the Services is processed in the United States and may be processed in other countries where our service providers operate, whose data protection laws may differ from those of your country.
16. Your Rights in the United Kingdom, the European Economic Area and Switzerland
Subject to applicable law, you have the right to request access to and a copy of your Personal Data; to request its correction or deletion; to restrict or object to its processing, including for direct marketing and disclosure to Partners; to receive it in a portable format; and to withdraw your consent at any time, without affecting the lawfulness of processing before withdrawal. You also have the right to lodge a complaint with a data protection supervisory authority; in the United Kingdom, this is the Information Commissioner’s Office.
17. Your California Rights
If you are a California resident, you have the right to request that we disclose the categories and specific pieces of Personal Data we have collected, used, disclosed, sold and shared about you; to request that we delete or correct it; and to opt out of its sale or sharing through the Do Not Sell or Share My Personal Information link in the footer of every page. We will not discriminate against you for exercising these rights. You may submit a request by email to general@thedenominator.ai. We will verify your identity before responding.
In the preceding 12 months, we have collected the following categories of Personal Data described in the California Consumer Privacy Act, from the sources and for the purposes described in Sections 4 and 5, and retained them as described in Section 10:
- Identifiers, such as name, business email address and IP address. Sold or shared with Partners and disclosed to service providers.
- Professional or employment-related information, such as job title, role and company. Sold or shared with Partners and disclosed to service providers.
- Internet or other electronic network activity, such as pages viewed, content read and interactions with the Services. Sold or shared with Partners and disclosed to service providers.
- Approximate geolocation, derived from IP address. Disclosed to service providers.
- Inferences, such as professional interests drawn from your activity. Sold or shared with Partners and disclosed to service providers.
We do not collect sensitive personal information, and we do not knowingly sell or share the Personal Data of consumers under 16 years of age.
Notice of financial incentive. Membership is provided free of charge in exchange for the Personal Data you provide at registration and our disclosure of it to Partners, as described in this Policy. You opt in by registering and accepting the registration terms, and you may withdraw at any time by closing your membership or by opting out of the sale or sharing of your Personal Data. We estimate the value of a Member’s Personal Data as approximately equal to the value of the content and services provided through membership.
18. Rights in Other US States
Residents of certain other US states have rights under their state privacy laws, which may include the rights to access, correct and delete Personal Data and to opt out of its sale and of targeted advertising. You may submit a request by email to general@thedenominator.ai.
19. Authorized Agents
An authorized agent may submit a request on your behalf by providing your signed written permission. We may require you to verify your identity directly with us, and we may deny a request from an agent that does not provide proof of authorization.
20. Children
The Services are intended for business professionals and are not directed to children. Individuals under 18 years of age are not permitted to use the Services, and we do not knowingly collect Personal Data from children. If you believe we have collected Personal Data from a child, please contact us and we will delete it.
21. Changes to This Policy
We may update this Policy from time to time. We will post the updated Policy on this page and revise the “Last updated” date. If we make material changes, we will notify Members 30 days before the changes take effect.
22. Contact Us
If you have questions about this Policy or wish to exercise your rights, please contact us at general@thedenominator.ai. If there is any conflict between the English version of this Policy and a translation, the English version governs.

