Privacy Policy

This Privacy Policy describes how Denomly LLC ("Denomly," "we," "us," or "our") collects, uses, stores, and protects information across (1) the public website at www.denomly.com, including its calculators and lead forms, and (2) the Denomly Diagnostic and Implementation Services, including D2 (connected CRM with a private executive dashboard) and D3 (a licensed, company-wide Denomly AI Operating System deployment) (collectively, the "Services").

1. Scope: Two Different Data Environments

Because Denomly now operates two distinct data environments, this Policy is organized accordingly:

• Public site data — information collected simply from visiting www.denomly.com or using the public calculators and lead forms, described in Section 2.
• Customer business data — information Customer connects, uploads, or grants access to as part of a paid Diagnostic, D2 build, or D3 AI Operating System deployment, described in Section 3.

If you are an individual whose personal information is processed by Denomly on behalf of a business customer (for example, because you are an employee, contact, or lead in a Customer's connected CRM), Section 3 and Section 8 apply to you, and you should direct privacy requests to that business, as described below.

2. Public Site Data

No accounts required. There are no logins for the public calculators. Numbers you type into a calculator are computed locally in your browser and are not transmitted to Denomly's servers as part of that computation.

Leads. If you choose to download a full report or book a working session, we record the email address you provide and which calculator you were using, so we can follow up. The document itself downloads directly in your browser; we do not email it to you, and your revenue, cost, or other business figures entered into a calculator are not saved by us.

Callback requests. If you request a callback rather than booking a specific time, we also record the name, phone number, and contact preference you provide, and use them only to reach you about the session you requested.

How rate data works. Market rate data (e.g., bitcoin and gold pricing) is fetched through our own server function from public market sources. Your calculator inputs are not sent with those requests.

Analytics. We use Google Analytics 4 to measure site traffic. It is cookie-based, sets cookies to count visits and track which pages and controls are used, and records general details such as approximate region and device type. Calculator inputs are never sent to Analytics, and it is not used to identify you by name. Blocking or clearing analytics cookies does not affect site functionality.

3. Customer Business Data (Diagnostic, D2, and D3 Services)

When a business engages Denomly for a Diagnostic, a D2 turnkey CRM build, or a D3 AI Operating System deployment, Denomly may collect, access, process, and/or store substantially more data than described in Section 2, including:

• Business and operational data shared during diagnostic interviews, discovery sessions, and workflow review;
• CRM data, including contact records, communications, deal/pipeline data, and related business records, whether migrated into a new Denomly-built CRM or connected to an existing one;
• Data from connected third-party systems and APIs that Customer authorizes Denomly to integrate with (for example, existing CRM, email, calendar, accounting, or other business software);
• Personal data of Customer's own personnel, customers, or contacts contained within the above systems, to the extent Customer's own data includes it;
• Usage and system data generated by Customer's use of the D2 dashboard or D3 AI Operating System, including agent activity logs, audit trails, and system performance data.

3.1 Roles and Responsibilities

For Customer business data, Customer is the data controller/business with respect to its own end customers, employees, and contacts, and Denomly acts as a service provider/data processor, processing that data solely to provide the Services, under the terms of the applicable Engagement Terms and, where required, a separate Data Processing Agreement ("DPA"). Customer is responsible for ensuring it has the necessary rights, consents, and legal basis to share any personal data with Denomly for this purpose, including data belonging to its own employees or customers.

3.2 Purpose of Processing

Denomly processes Customer business data solely to:

• Deliver the Diagnostic, including producing findings, opportunity registers, and roadmaps;
• Build, configure, connect, and maintain the D2 CRM and executive dashboard, or the D3 AI Operating System;
• Provide ongoing technical administration and customer success support;
• Improve the reliability and security of the Services (in de-identified or aggregated form wherever feasible).

Denomly does not sell Customer business data, and does not use it to train models or products for the benefit of any party other than that Customer, except as expressly agreed in writing.

3.3 Third-Party Sub-Processors and Integrations

Delivering D2 and D3 Services may involve engaging third-party infrastructure and software providers (for example, cloud hosting, AI model providers, and the third-party systems Customer chooses to connect via API). Denomly will:

• Maintain a current list of material sub-processors, available on request or at denomly.com/subprocessors;
• Enter into appropriate data protection terms with sub-processors that process Customer data on Denomly's behalf;
• Remain responsible for sub-processors' handling of Customer data to the extent required by the applicable DPA.

Customer's use of third-party systems it separately connects (e.g., an existing CRM or email platform) remains subject to that third party's own terms and privacy practices, which Denomly does not control.

3.4 Data Security

Denomly maintains administrative, technical, and physical safeguards designed to protect Customer business data, including access controls limiting dashboard and system access to authorized users behind Customer's own login, and encryption of data in transit and, where applicable, at rest. No system is completely secure, and Denomly cannot guarantee absolute security.

3.5 Data Retention and Deletion

Denomly retains Customer business data for as long as needed to provide the Services and for a reasonable period afterward for legitimate business or legal purposes, as further specified in the applicable Engagement Terms or DPA. Upon termination of an engagement, Denomly will delete or return Customer business data within the timeframe specified in that agreement, except where retention is required by law.

3.6 AI Processing Disclosure

Where D3 AI Operating System agents process Customer business data to automate or augment workflows (e.g., follow-up, reporting, routing), that processing is performed to carry out Customer's own instructions and configured workflows. Denomly does not use Customer business data to train models shared across other customers, except with Customer's express written consent.

4. Your Contact Details (Public Site)

An email captured through the lead flow, or any name/phone number provided through the callback form, is used only to follow up and arrange a working session. This information is not sold or shared with third parties for their own marketing purposes.

5. Cookies and Similar Technologies

The Site uses cookies solely for Google Analytics 4 traffic measurement, as described in Section 2. We do not use cookies for cross-site advertising or ad targeting. You can manage cookie preferences through your browser settings; doing so does not affect Site functionality.

6. Children's Privacy

The Site and Services are intended for business use and are not directed to individuals under 18. Denomly does not knowingly collect personal information from children.

7. International Data

Denomly is based in the United States, and data collected through the Site or Services is generally processed and stored in the United States.

8. Your Privacy Rights

Public site visitors: To have your lead or callback information removed, contact us through the booking form on the home page or at jeff@denomly.com.

Individuals whose data appears within a Customer's connected CRM or AI Operating System: Because Denomly processes this data as a service provider on behalf of its business Customer, requests to access, correct, or delete such data should be directed to that business (the data controller). Denomly will support its Customers in responding to such requests as required by the applicable DPA and law.

State privacy law rights. Depending on your state of residence, you may have rights to know, access, delete, or opt out of certain uses of your personal information (for example, under the California Consumer Privacy Act, as amended).

9. Changes to This Policy

We may update this Policy as the Services evolve, including as D2 and D3 offerings mature. Material changes will be reflected by an updated "Last updated" date. For Customers under active Engagement Terms or a DPA, changes materially affecting how their business data is processed will be communicated directly, not solely through a website update.

10. Contact

Questions about this Policy, or requests regarding your personal information, can be directed through the booking form at denomly.com or to jeff@denomly.com.

Denomly LLC · 30 N Gould St Ste R, Sheridan, WY 82801, USA