1. Who we are
This website, topgeargt.com, is operated by Top Gear General Trading L.L.C. (“Top Gear”, “we”, “us”, “our”), a limited liability company incorporated in Dubai, United Arab Emirates in 2014 and part of the Abbas Bin Haider (ABH) Group.
For the purposes of this policy we are the controller of your personal data (also referred to as the “data controller” under the UAE Personal Data Protection Law, and as the “Data Fiduciary” under India’s Digital Personal Data Protection Act). That means we decide why and how your personal data is used.
- Legal name
- Top Gear General Trading L.L.C.
- Registered office
- Office No. 13, 14 Road, 11 Al Budoor Bld., Baniyas Square, Dubai, United Arab Emirates
- Telephone
- +971 4 341 3396
- topgear@abhgt.com
- Parent group
- Abbas Bin Haider Group, a UAE family business established in 1979
2. Scope of this policy
This policy explains what we do with personal data collected through this website. Our business is business-to-business distribution: we import, warehouse and distribute toy, bicycle and ride-on brands within the United Arab Emirates and the wider GCC, and we work with brand owners and manufacturers internationally who are looking for a distribution partner in this region.
We do not sell products to consumers through this website. There is no shopping cart, no checkout and no payment processing here, so we never collect payment card details, bank details or delivery addresses through this site.
Because we actively invite enquiries from brand owners outside the region, this policy is written to meet the requirements of the UAE Personal Data Protection Law, the EU / UK General Data Protection Regulation, India’s Digital Personal Data Protection Act 2023, and applicable United States state privacy laws — whichever applies to you.
3. What we collect
We collect only what we need. In practice that is three things.
a. Information you give us in the enquiry form
When you use the “Get in touch” form, you provide:
| Field | Required? | What it is |
|---|---|---|
| Full name | Required | So we know who we are replying to. |
| Email address | Required | So we can reply. |
| Message | Required | Whatever you choose to tell us. Please do not include sensitive personal information. |
| Company | Optional | Helps us route the enquiry to the right team. |
| Phone number | Optional | Only used if you would prefer us to call. |
| Enquiry type | Optional | Distribution, stockist, supplier/trade, general or careers. |
If you email or telephone us directly instead, we hold whatever you choose to send us in that message or discuss on that call.
b. Technical information collected automatically
Like virtually every website, our hosting provider’s servers keep standard access logs. These record your IP address, the date and time of the request, the page requested, the referring page and your browser and operating system version. These logs exist to keep the site running securely and to diagnose faults; they are not used to build a profile of you.
c. Analytics — only if you agree
We do not currently run any analytics or advertising trackers on this site. We intend to add website analytics in future. If and when we do, it will load only after you have given consent through the cookie banner, and this policy and our Cookie Policy will be updated to name the tool before it goes live.
What we do not collect
- No payment card, bank or financial details.
- No special-category or sensitive data (health, biometrics, religious or political views, and so on). Please do not send it to us.
- No data bought from third-party list brokers.
- We do not sell or rent your personal data to anyone, and we never have.
4. Why we use it, and on what basis
| What we do | Data used | Our lawful basis |
|---|---|---|
| Read your enquiry, route it internally and reply to you | Form fields, email correspondence | Your consent, given when you tick the box and submit the form. Where an enquiry concerns a possible commercial relationship, also our legitimate interest in responding to business approaches. |
| Follow up on a distribution, stockist or supplier discussion you started | Name, company, email, phone | Legitimate interest in pursuing a business relationship you initiated, and steps taken at your request prior to entering a contract. |
| Consider a job application sent through the form | Whatever you send us | Steps taken at your request before a possible employment contract. |
| Keep the site available, secure and free of spam and abuse | Server logs, the form’s anti-spam field | Legitimate interest in the security and integrity of our systems. |
| Measure how the site is used (not yet active) | Analytics identifiers | Your consent, and only from the moment you give it. |
| Meet legal, tax and regulatory obligations, or establish or defend legal claims | Relevant correspondence | Legal obligation and legitimate interest. |
Where we rely on your consent, you can withdraw it at any time — see Your rights. Withdrawing consent does not make anything we did before you withdrew it unlawful.
We do not use your data for automated decision-making or profiling that produces legal or similarly significant effects on you.
5. Cookies and analytics
This site currently sets no advertising or tracking cookies. The only browser storage we use is a single entry recording your cookie-banner choice, so we do not ask you again on every visit.
Our fonts are served from our own server rather than a third-party font network, which means your IP address is not passed to an external font provider simply because you opened a page. The full detail is in our Cookie Policy.
6. Who we share it with
We share personal data only where we need to, and only with:
- Our hosting and email providers, who store the website and carry the messages the enquiry form generates. They process data on our instructions.
- Other companies within the Abbas Bin Haider Group, where an enquiry belongs to a different part of the group — for example a brand or category we do not handle ourselves. We will route your enquiry to the right team so you get a useful answer.
- Professional advisers (lawyers, accountants, auditors) where we are required to or need to take advice.
- Authorities, where the law requires us to disclose information, or to establish or defend legal claims.
We do not sell, rent or trade personal data, and we do not share it with advertising networks or data brokers.
7. International transfers
We are based in the United Arab Emirates, so if you contact us from the EU, the UK, India, the United States or anywhere else, your data will be transferred to and handled in the UAE. Our hosting and email providers may also store or process data on servers outside the UAE.
Where a transfer is subject to the GDPR, we rely on appropriate safeguards for transfers to countries without an EU adequacy decision — in practice, the European Commission’s Standard Contractual Clauses in our contracts with the relevant providers. Where a transfer is subject to the UAE PDPL or India’s DPDP Act, we transfer only in line with those laws. You may request further detail using the contact address below.
8. How long we keep it
| What | How long |
|---|---|
| Enquiries that do not lead to a business relationship | Up to 24 months from our last contact with you, then deleted. |
| Enquiries that become a commercial relationship | For the life of that relationship, then for as long as UAE commercial, tax and accounting law requires us to retain the records. |
| Job applications made through the form | Up to 12 months from the decision, unless you ask us to delete them sooner. |
| Server access logs | The short rolling period operated by our hosting provider, typically a matter of weeks. |
| Your cookie-banner choice | Stored in your own browser until you clear it or it expires after 12 months. |
You can ask us to delete your enquiry sooner than the periods above, and we will unless we are legally required to keep it.
9. How we protect it
The site is served over an encrypted HTTPS connection. Access to the mailbox that receives enquiries is limited to the staff who need it. The enquiry form carries an anti-spam measure, and the data submitted is stripped of markup before it is processed. We keep our hosting platform patched and up to date.
No method of transmission over the internet is completely secure, and we cannot guarantee absolute security. If a personal data breach occurs that is likely to present a risk to you, we will notify the relevant supervisory authority and, where the law requires it, you directly.
10. Your rights
Depending on where you are, you have some or all of the following rights over the personal data we hold about you:
- Access — ask for a copy of the data we hold about you and how we use it.
- Correction — have inaccurate or incomplete data corrected.
- Deletion — ask us to erase your data where there is no good reason for us to keep it.
- Restriction — ask us to pause our use of your data while a concern is resolved.
- Objection — object to processing we carry out on the basis of legitimate interests.
- Portability — receive the data you gave us in a structured, commonly used, machine-readable format.
- Withdraw consent — at any time, as easily as you gave it.
- Complain — to us first, and to your data protection authority if we have not put things right.
To exercise any of these, email topgear@abhgt.com with “Privacy request” in the subject line, or write to us at the address in section 1. We will respond within 30 days. There is no charge. We may need to verify your identity before we act, to make sure we are not disclosing your data to someone else.
11. Region-specific rights
United Arab Emirates — Federal Decree-Law No. 45 of 2021 (PDPL)
If you are in the UAE, the PDPL gives you the rights set out in section 10, including the right to receive information about processing, to request correction or erasure, to restrict or object to processing, and to data portability. The supervisory authority is the UAE Data Office, and you may raise a complaint with it if you are not satisfied with our response.
European Union and United Kingdom — GDPR
If you are in the EU or the UK, you hold the rights in section 10 under Articles 15 to 22 of the GDPR. You also have the right to lodge a complaint with the supervisory authority in the country where you live or work — or, in the UK, with the Information Commissioner’s Office. We would ask you to raise it with us first so we have the chance to resolve it.
India — Digital Personal Data Protection Act 2023
If you are in India, you have the right to access a summary of your personal data and our processing of it, to correction and erasure, to grievance redressal, and to nominate another person to exercise your rights in the event of death or incapacity. You may withdraw consent at any time using the contact address in section 15. If your grievance is not resolved, you may escalate it to the Data Protection Board of India.
United States — California and other states
We do not sell or share personal information for cross-context behavioural advertising, and we do not use or disclose sensitive personal information beyond the purposes permitted by law. Where a US state privacy law applies to you, you may request access to, correction of, or deletion of your personal information, and we will not discriminate against you for exercising those rights. Use the same contact route in section 10.
12. Children’s data
Many of the brands we distribute are made for children, but this website is aimed squarely at adults — brand owners, retailers, suppliers and job applicants. It is not directed at children, and we do not knowingly collect personal data from anyone under 18 through this site.
If you believe a child has sent us personal data through this website, please contact us and we will delete it.
13. Other websites
This site links to other websites — the Abbas Bin Haider Group site, the brands we represent, and the retail platforms that stock our products. Once you follow a link you are on someone else’s site, governed by their privacy policy, not ours. We are not responsible for how those sites handle your data, and we would encourage you to read their policies.
14. Changes to this policy
If we change how we handle personal data — for example when we switch on website analytics — we will update this page and change the “last updated” date at the top. Where a change is significant, we will make that clear on the site rather than leaving you to spot it.
15. How to contact us
For any question about this policy, to exercise your rights, or to make a complaint about how we have handled your data:
- topgear@abhgt.com — please put “Privacy request” in the subject line
- Telephone
- +971 4 341 3396
- Post
- Top Gear General Trading L.L.C., Office No. 13, 14 Road, 11 Al Budoor Bld., Baniyas Square, Dubai, United Arab Emirates
- Response time
- Within 30 days