AI Policy

Last updated: 20 July, 2026

AI is not new to Xponent21. It is part of how we work and part of what we build. We use AI tools to make our team faster and sharper, and we design and sell AI products of our own, including CARL Intelligence and the broader CARLverse suite. This policy covers how we use AI in our own work and the standards we hold ourselves to as a company that builds AI products.

How We Use AI

AI as a tool, not a replacement

AI supports our team. It does not replace the judgment, strategy, or creative thinking our clients hire us for. We use AI to move faster through repetitive or time-consuming work so our strategists, writers, and producers can spend more time on the parts of the job that require real expertise: strategy, creative direction, and client relationships.

Accuracy and verification

AI-generated output, whether it's a first draft, a data pull, or a piece of research, is a starting point, not a finished product. Every piece of client-facing or published work that involves AI assistance goes through human review before it ships. We verify facts, figures, and claims against primary sources rather than relying on AI-generated summaries at face value. This applies to our agency work and to our own published content.

Client confidentiality and data protection

Protecting client information is non-negotiable. Where AI features rely on third-party AI providers to process content, we only send what's needed to complete that specific task, and we do not authorize those providers to use client content to train their models. We do not use client data to train or fine-tune our own AI tools. Client data is stored in a secure, access-controlled cloud environment, and access is limited to authorized team members.

When a client engagement ends, we remove access and remove their data within a defined retention window.

Transparency

We'll tell you when and how AI was used on your project if you ask. We're not going to hide it, and we're not going to oversell it either. Part of our job is helping clients understand what these tools are actually good at and where they still fall short.

How We Build AI

Xponent21 doesn't just use AI tools built by other companies. We build our own. CARL Intelligence and the CARLverse suite (CARL AIO, CARL Writes, CARL Optimize, and CARL CMS) came out of a simple observation: brands need a real tech stack to compete in an AI-driven search and marketing landscape, and most agencies were only ever going to rent that stack from someone else. We built ours instead.

What that means for how we build

  • We design our tools to solve problems we've actually hit running an agency, not problems we think might be interesting.
  • We test internally before anything ships to clients.
  • We stay honest about what our tools can and can't do yet. Features still in development are labeled as such, not marketed as finished.

Governance

Decisions about how we build, deploy, and govern our AI products sit with our leadership team, with input from the people building and using these tools day to day. As our AI product suite grows, that oversight grows with it.

Staying Current

AI is moving fast, and this policy will keep moving with it. We review this document regularly, not on a fixed schedule dictated by convenience, but whenever our tools, our practices, or the regulatory landscape change enough to warrant it. We comply with applicable data protection laws, including GDPR and CCPA where they apply to our work.

Community and Collaboration

Will Melton, our CEO, founded AI Ready RVA to bring together Richmond business leaders, startups, academic institutions, and researchers working on responsible AI adoption. That same thinking shapes how we approach AI internally: openly, collaboratively, and with an eye toward getting it right rather than just getting it done first.

We welcome the chance to work with industry partners, regulators, clients, and our own team to keep building AI practices worth trusting.

Have feedback on this policy, or want to talk about a collaboration? We'd like to hear from you. Contact us.