You are right in that access to the core "gapps" is commercially restricted to whose who have deals in place with Google.

Speaking as a purely practical matter, as an end-used you can easily get "gapps" builds for virtually any Android device though technically you will be violating copyright (unless you are using those "gapps" as a replacement for a 'backup' of the distribution that came with your phone originally).

After a botched cease-and-desist on Cyanongenmod back a few years ago (2009?) Google turns a blind eye to this sort of sharing of gapps. I've never heard of them taking any action against any gapps provider since that whole C&D debacle despite the fact that these files are shared openly all over the place.