We study the setup where each of $n$ users holds an element from a discrete set, and the goal is to count the number of distinct elements across all users, under the constraint of $(ε, δ)$-differentially privacy: - In the non-interactive local setting, we prove that the additive error of any protocol is $Ω(n)$ for any constant $ε$ and for any $δ$ inverse polynomial in $n$. - In the single-message shuffle setting, we prove a lower bound of $Ω(n)$ on the error for any constant $ε$ and for some $δ$ inverse quasi-polynomial in $n$. We do so by building on the moment-matching method from the literature on distribution estimation. - In the multi-message shuffle setting, we give a protocol with at most one message per user in expectation and with an error of $\tilde{O}(\sqrt(n))$ for any constant $ε$ and for any $δ$ inverse polynomial in $n$. Our protocol is also robustly shuffle private, and our error of $\sqrt(n)$ matches a known lower bound for such protocols. Our proof technique relies on a new notion, that we call dominated protocols, and which can also be used to obtain the first non-trivial lower bounds against multi-message shuffle protocols for the well-studied problems of selection and learning parity. Our first lower bound for estimating the number of distinct elements provides the first $ω(\sqrt(n))$ separation between global sensitivity and error in local differential privacy, thus answering an open question of Vadhan (2017). We also provide a simple construction that gives $\tildeΩ(n)$ separation between global sensitivity and error in two-party differential privacy, thereby answering an open question of McGregor et al. (2011).