Privacy Policy

Updated Sep 17, 2021

TopGear, are committed to protecting and respecting your privacy.

This policy sets out the basis, under applicable data protection law (including the General Data Protection Regulation (EU 2016/679), on which we will process any personal data we collect from you, or that you or your employer provides to us through your use of the TopGear online software platform and the accompanying software App (together the “Platform”).


In the normal course of our business we collect and process data in respect of

  • survey recipients who are typically employees who have been granted access to our Platform by their employer (where their employer is an existing client) and who are invited to complete engagement surveys (“Survey Recipients”);
  • administrative users of the Platform dashboard who are acting on behalf of their relevant employer (where their employer is an existing client) (“Client Users”); and
  • trial users or potential new users of the Platform, including those who we have identified as possible future clients and to whom we are marketing or promoting the Platform and our services (“Marketing Contacts”).

When we refer to “personal data” in this policy, we mean any information relating to you from or in relation to which you may be identified (directly or indirectly). This might include, for instance, your contact details, your biographical details, online identifiers, and factors specific to your physical, mental, economic, cultural or social identity. Your personal data may also include any comments or opinions made by you or about you.

Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting or using the Platform you are accepting and consenting to the activities and data usage as described in this policy.


In the case of Survey Users, TpGear ApS and/or one its subsidiary companies has entered into an agreement with your employer to grant you access to the Platform and / or to engagement surveys completed on or via the Platform (the “Employer Agreement”), and your employer is the data controller of your personal data. We will process your personal data on behalf of your employer and in accordance with its lawful instructions. The information you provide to us and/or upload to the Platform (whether or not it constitutes personal data) will also be governed by the Employer Agreement.

In the case of Marketing Contacts, we are the data controller in respect of your personal data.

We are also the data controller in respect of contact information for each client contact which we hold for account and contract management purposes, including for contract queries and billing purposes.

References in this policy to “your employer” shall refer to the entity who has entered into the Employer Agreement with us, whether or not as a matter of law you are an employee of that entity, and such references are not intended to characterise or prejudice your status vis-à-vis that entity.


For Survey Recipients and Client Users: we will collect and process the following data about you as follows.

  • Information you give us. You may give us information about you:
  • when using the Platform’s functions, including by filling in forms or completing surveys on or via the Platform. The extent of the information collected in engagement surveys is set by your employer. This information may include your name, age, company email address, company telephone number, job title, level of seniority, department, work start date, salary and primary office location, as well as any views you provide to us about you or your performance in your role, or information regarding your employer, your colleagues or other third parties during the course of completing engagement surveys or otherwise using the Platform;
  • if you contact or correspond with us (for example, using any support function made available by us) and we may keep a record of that correspondence (either directly or through our service providers).