Last Updated: April 28th, 2026
Iterate is a custom survey tool created by Pickaxe LLC, a New York Limited Liability Company (“we,” “us,” “our,” etc. “Iterate” or “Company”). Iterate surveys appear on the web, in emails, and embedded in our Clients’ websites, or other places on the web. We recommend that Clients provide Iterate with only the necessary information and Personal Data as defined below (also referred to as “PII”), needed to create and administer the survey, and to withhold and protect all other PII. In addition, we recommend that Clients use this Privacy Policy as a guide for their own, and/or direct their customers to this page for privacy information.
We are providing you this Privacy Policy so that you can be informed about our policies regarding the collection, use, and disclosure of Personal Data and the choices you have associated with that data.
We may collect and use Personal Data about or provided by people who visit Iterate’s websites located at https://iteratehq.com and all pages and subdomains thereof (the “Website”) and any person who uses our Services. By our “Service” or “Services,” we mean the Website, downloadable software, and other services provided by us relating to our custom survey tool, or any digital media on which we display a link to this Privacy Policy.
Pickaxe LLC DBA Iterate complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Pickaxe LLC has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Pickaxe LLC has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
We may collect and use Personal Data about or provided by people who visit Iterate’s websites located at https://iteratehq.com and all pages and subdomains thereof (the “Website”) and any person who uses our Services. By our “Service” or “Services,” we mean the Website, downloadable software, and other services provided by us relating to our custom survey tool, or any digital media on which we display a link to this Privacy Policy.
We may use your data to provide and improve our Service or to provide technical support for people using our Service. By using the Service, you agree to the collection and use of information in accordance with this policy, and, if you are a Client, our Master Services Agreement. If you are a Client, this Privacy Policy is incorporated into and subject to our Master Services Agreement and any related agreements.
Iterate collects information from Clients who use the Services and from our Clients’ Customers (“Customers”) who visit Client websites and/or submit responses to Iterate and/or Client-hosted Iterate surveys. This Privacy Policy applies only to our Website and to our Services provided through our Website. It does not apply to any third party site or service, including the sites where Iterate surveys may appear.
2.1 Client and User Provided Information. We collect information to provide and improve our Service to you. We sometimes collect Personal Data including:
2.2 Information Collected by Clients. Our Clients may collect information that could directly or indirectly contain Personal Data through survey responses. We have no direct relationship with Customers or other visitors or users of our Client’s whose Personal Data a Client may collect or provide as part of Client Data. Each Client is responsible for providing notice to Users and individuals with whom it interacts concerning the purpose for which the Client collects their Personal Data and how this Personal Data is processed in or through the Service as part of Client Data.
2.3 Collected Information. By “Collected Information” we mean Registration Information, Cookie Information, Usage Data, Account Activities Information, Payment Information, Marketing Information, Disclosed Personal Information (including Client Data) and any information we may collect from you, from our affiliates, or from other parties or through any other means.
We use the Collected Information for purposes of improving our Service and as more fully described below:
3.1 General: Iterate uses Personally Identifiable Information to create user accounts, to communicate with Clients and Customers about our products and services, to offer surveys, and to analyze general consumer trends. We use cookies so that our Website can remember you and provide you with the information you’re most likely to need. For instance, when you return to our Website, cookies identify you and prompt the site you are visiting to offer you the survey. Finally, we use information gained through cookies to compile statistical information about use of our Website, such as the time users spend at the site and the pages they visit most often. Those statistics do not include PII. In general, we use Collected Information to improve our marketing and promotional efforts, to statistically analyze site usage, to improve our content and product offerings and to customize our Website’ content, layout and Service specifically for you. We may also use Collected Information to provide technical support to Clients or other services to Clients, including but not limited to investigating problems, and resolving disputes.
Except for depersonalized statistical data, we do not sell, rent, trade or exchange any Personal Data of our Clients, Users or Visitors.Your Collected Information may be transferred, stored, used and processed outside your home jurisdiction. In case of a merger with or transfer of business to another business entity, we will transfer your Collected Information to the entity that acquires the business. In such an event, the combined business may adopt or modify this Privacy Policy.
3.2 Registration Information: We may use your Registration Information or other Collected Information to provide services that you request or to contact you regarding additional services if we think that you might be interested in them. Specifically, we may use your email address, mailing address, phone number, mobile number or fax number to contact you regarding notices, surveys, product alerts, new service or product offerings and communications relevant to your use of our Website. We may also generate reports and analysis based on Registration Information for internal analysis, monitoring, and marketing decisions.
3.3 Cookie Information: As noted above, we use “cookies” to store specific information about you and track your visits to our Website. It is not uncommon for websites to use cookies to enhance identification of their users. A “cookie” is a small amount of data that is sent to your browser and stored on your computer’s hard drive. A cookie can be sent to your computer’s hard drive only if you access our Website or a website that has Iterate script installed using the computer. If you do not de-activate or erase the cookie, each time you use the same computer to access our Website, our web servers will be notified of your visit to our Website and in turn we may have knowledge of your visit and the pattern of your usage. We use automatically collected information and other information collected on the Service through cookies and similar technologies to: (i) personalize our Service, such as remembering a User’s or Visitor’s information so that the User or Visitor will not have to re-enter it during a visit or on subsequent visits; (ii) provide customized content, and information; (iii) monitor and analyze the effectiveness of Service and third-party marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) track your entries, submissions, or other activities on the Service. You can learn more about cookies generally by visiting http://www.allaboutcookies.org.
You can determine if and how a cookie will be accepted by configuring your browser, which is installed in the device you are using to access the Website. If you desire, you can change those configurations in your browser to accept all cookies, to be notified when a cookie is sent, or to reject all cookies. If you reject all cookies you may be required to re-enter your information on our Website more often and certain features of our Website may be unavailable.
Examples of Cookies we may use:
3.3 Usage Data: We may use Usage Data to provide value-added services to our Clients, Users, affiliates, or related entities, including without limitation to providing pattern and behavioral data to facilitate marketing initiatives and decision-making.
3.4 Account Activities Information: We use Account Activities Information to provide the Services that you request. We may also generate reports, statistics and analysis based on Account Activities Information to enhance and improve our Services.
3.5 Payment Information: We may use Payment Information to process Client payments or as necessary to provide the Services.
3.6 Statistical Information: We use Statistical Information to help diagnose problems with and maintain our computer servers, to manage our Services, and to enhance our Services based on the usage pattern data we receive. We also may generate reports and analysis based on the Statistical Information for internal analysis, monitoring and marketing decisions. We may provide Statistical Information to third parties. When we provide Statistical Information to third parties, we depersonalize or anonymize any Personal Data to prevent disclosure of personally identifying information without your permission.
3.8 Disclosed Personal Information: We provide custom survey tools to Clients. Our Services should not be used for personal or other uses. Uses of any Personal Data by any of our Clients or Users are subject to privacy laws in each of their respective jurisdictions. Each of our Clients is solely responsible for observing applicable laws and regulations in its respective jurisdictions to ensure that all use of the Website and Services are in compliance with the same. Each of our Clients is expressly prohibited from using any Personal Information for illegal activities.
4.1 Unrestricted Information. Any information included in a Public Area of the Service will be available to any Visitor or User who has access to that content.
4.2 Disclosure to Service Providers. We give certain third party vendors and partners access to Personally Identifiable Information. Those third parties assist us with data storage, analytics, web hosting, and other related technology services. We also may disclose PII to attorneys, collection agencies, or law enforcement authorities to address potential Acceptable Use Policy (AUP) violations, other contract violations, or illegal behavior. And we disclose any information demanded in a court order or otherwise required by law or to prevent imminent harm to persons or property. Finally, we may share PII in connection with a corporate transaction, like a merger or sale of our company, or a sale of all or substantially all of our assets or of the product or service line you received from us, or a bankruptcy.
We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to [email protected].
As noted above, we compile Website usage statistics from data collected through cookies. We may publish those statistics or share them with third parties, but they don’t include PII.
4.3 Business Transactions. If Company is involved in a merger, acquisition or asset sale, your Personal Data may be transferred as a result of that merger, acquisition, or asset sale. We will provide notice if Personal Data becomes subject to a different Privacy Policy.
4.4 Disclosure for Law Enforcement. Under certain circumstances, Company may be required to disclose or make public Collected Information, including Personal Data. For example, we may disclose Personal Data in the good faith belief that such action is necessary to:
4.5 Onward Transfer of Personal Data. We may transfer personal data to third-party service providers, business partners, or affiliates to facilitate the delivery of our services. Any such onward transfer is conducted in accordance with the EU-U.S. Data Privacy Framework, UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework Principles, particularly the Accountability for Onward Transfer Principle. Specifically:
Third-Party Service Providers: We engage third-party vendors to provide services such as data hosting, analytics, payment processing, and customer support. These vendors are contractually obligated to process personal data only on our behalf and in accordance with our instructions, the Data Privacy Framework Principles, and applicable privacy laws.
Purpose Limitation: Personal data will only be shared with third parties for purposes consistent with those outlined in this Privacy Policy, such as providing, improving, and securing our services.
Data Protection Obligations: We require all third parties to whom we transfer personal data to adhere to strict confidentiality obligations and to implement robust security measures to protect the data. Transfers are subject to contractual agreements ensuring compliance with the Data Privacy Framework Principles.
Liability for Onward Transfers: We remain liable under the Data Privacy Framework Principles if third-party service providers fail to process personal data in a manner consistent with these Principles, except where we can demonstrate that we are not responsible for the event giving rise to the damage.
Disclosure for Legal or Security Purposes: Personal data may also be disclosed to comply with legal obligations, such as responding to lawful requests from public authorities, including to meet national security or law enforcement requirements, as detailed in the “Government Access” section of this policy.
We may retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy or as reasonably necessary to provide, promote and support the Service. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
We may also retain Usage Data for internal analysis purposes. While Usage Data is generally retained for a shorter period of time, it may be retained for a long period of time if it is used to strengthen the security or to improve the functionality of our Service, or if we are legally obligated to retain this data for longer time periods.
We are a business with global customers, and your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside United States note that we store and process information in where we have operations or where we engage service providers, which includes primarily the United States. If you choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there. We take steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy and try to ensure that we do not transfer your Personal Data to an organization or a country without adequate controls in place including the security of your Personal Data and other personal information.
If you are located in the European Economic Area (“EEA”), the UK or Switzerland, we comply with applicable laws to provide an adequate level of data protection for the transfer of your Personal Data to the US. To facilitate compliance with data protection laws, we have established a Data Processing Amendment (DPA) available for our customers. This amendment aligns with the requirements of data protection regulations and is designed to ensure the lawful handling and transfer of personal data. For more information or to request a copy of the DPA, please contact us.
We employ the following data security tools to protect Personally Identifiable Information: all web traffic is transported via SSL/TLS, access to production data is restricted to authorized employees, and we conduct periodic security audits. Unfortunately, even with these measures, we cannot absolutely guarantee the security of PII against all potential intrusions or every human error.
Our Service does not address and is not directed towards anyone under the age of 13 (“Children”). We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that Children have provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent or other legal justification, we will take steps to remove that information from our servers.
We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
9.1 Modifying Personal Data. Whenever made possible, if you have registered to use our Service, you can update your Personal Data directly within your account settings section. If you are unable to change your Personal Data, please contact us to make the required changes.
9.2 Removing Personal Data. If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us. If you are a Customer or not otherwise a Client please initially contact the Client or User that provided the survey to which you responded or who otherwise collected or processed your Personal Data.
9.3 Data Portability. You have the right to data portability for the information you provide to Company. You can request to obtain a copy of your Personal Data in a commonly used electronic format so that you can manage and move it. We will provide such data as it may be reasonably available and technologically feasible to obtain or segregate from other data.
9.4 Other Data Subject Rights. In certain circumstances, you have the right:
Please note that we may ask you to verify your identity before responding to such requests. If you are a Customer or not otherwise a Client please initially contact the Client or User that provided the survey to which you responded or who otherwise collected or processed your Personal Data.
We may change this Privacy Policy at any time by posting a new version on this page or on a successor page. The new version will become effective on the date it’s posted, which will be listed at the top of the page as the new Effective Date. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
We do not sell California consumers’ information. Iterate’s processing of Personal Data complies with California Data Protection Laws (CCPA / CPRA).
In compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF), Pickaxe LLC commits to resolve complaints about our collection or use of your personal information transferred to the U.S. pursuant to the EU-U.S. DPF, the UK extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. EU, UK, and Swiss individuals with inquiries or complaints should first contact Pickaxe LLC.
Pickaxe LLC has further committed to refer unresolved DPF Principles-related complaints to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers for more information and to file a complaint. This service is provided free of charge to you.
If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf
In compliance with the EU-U.S. Data Privacy Framework, UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework, individuals in the European Union, United Kingdom, and Switzerland have the option to invoke binding arbitration under certain conditions as a last-resort mechanism for resolving disputes related to our compliance with the Framework Principles. See https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction for more information on this process.
This arbitration option is available only after:
Our organization is subject to the investigatory and enforcement powers of the United States Federal Trade Commission (FTC). This means that the FTC has the authority to investigate and enforce compliance with the principles of the EU-U.S. Data Privacy Framework, UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework.
If you believe we are not complying with the Framework Principles or our stated privacy commitments, you may file a complaint with us or escalate your concern to our designated independent recourse mechanism, BBB National Programs. If your issue remains unresolved, it may be referred to the FTC or other authorized U.S. enforcement bodies for further investigation.
If you have any questions about this Privacy Policy, please contact us by email at [email protected]. You may also contact us at our address:
Pickaxe, LLC / Iterate