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Policy · data disclosure

When we disclose registrant data, and to whom

The data we hold about a domain holder, the only routes by which it leaves us, and who gets nothing. Written for customers, complainants and authorities alike.

Last updated: · 10 min read

Quick answer

When does PanamaRegistrar disclose registrant data?

PanamaRegistrar releases the data it holds only when Panamanian law requires it (a Panamanian court or prosecutor's order), or in a UDRP case, as of October 2026. What it holds is one verified email per domain and the account records. Our registrar partner and the registry hold their own records. Bulk requests are refused.

Data disclosure at a glance

What we holdOne verified email per domain, a random account number, your domains and DNS settings, your balance, payment records
What we do not holdName, postal address, phone number, identity document: the email is the only contact data
Disclosure ruleOnly when Panamanian law requires it: a Panamanian court order or a prosecutor's (Ministerio Público) order under CPP arts. 338-A, 338-C; or in a UDRP case
Other holdersOur registrar partner and the registry, under their own rules
UDRP or URSThe dispute provider receives the registrant details of record for the disputed domain
Foreign requestsOnly through Panamanian process: MLAT, Budapest Convention, letters rogatory, exequatur
Bulk requestsNever admitted (Law 81 of 2019, art. 24)
Customer noticeYou are told before any action on your domain, unless the law or the court order forbids it
ReportingData requests counted by origin country and outcome in the transparency report

What registrant data does PanamaRegistrar hold?

Very little, and that limits what any order can obtain. We hold:

  • one email address per domain, which you confirm; ICANN requires registrars to verify it within 15 days;
  • a random account number that we generate;
  • your domains, their DNS settings and your balance;
  • payment records: the amount, coin and network of each crypto top-up;
  • messages you send us, and the complaints and orders received about your domains.

The email is the only contact data we collect: we do not ask for a name, a postal address, a phone number or an identity document. Where a registry requires a name and address, the domain is sold with Domain protection, and the registry receives our company's details. The full inventory is on what we hold.

When does registrant data leave PanamaRegistrar?

Our rule, in the words we use on every page: We release the data we hold only when Panamanian law requires it (a Panamanian court or prosecutor's order), or in a UDRP case. Our registrar partner and the registry hold their own records, under their own rules.

In detail, three routes, each one written down here:

  1. A Panamanian court order. Our rule: we confirm every order with the court or prosecutor's office that issued it, through its official contact details, before acting. Article 24 of Law 81 of 2019 obliges controllers to give the competent judicial authorities the information duly requested.
  2. A prosecutor's order, from Panama's Ministerio Público. Today that means an order under article 338-A (preservation) or 338-C (production) of the Code of Criminal Procedure, both added by Law 478 of 2025. We check it like a court order and count it separately.
  3. A UDRP or URS provider, which receives the registrant details of record for the disputed domain, as ICANN's dispute rules require.

A foreign court, a foreign police force or a foreign lawyer reaches us through the first or second route only. That means exequatur for a civil judgment, or a treaty request turned into a Panamanian order. The routes are on the court orders page.

What happens to an ordinary disclosure request?

It gets an answer on time, and without Panamanian process that answer is a refusal. The Registration Data Policy (§10.5) asks registrars to acknowledge a reasonable disclosure request within 2 business days. A response follows within 30 calendar days of acknowledgement at most. Our accredited registrar partner is bound by those limits, and we answer within them. The refusal explains which Panamanian route would work for the requester.

ICANN ran a voluntary lookup service, the Registration Data Request Service (RDRS), as a two-year pilot from November 2023 to November 2025. ICANN reports more than 3,700 requests: 32 % for intellectual property, 16 % from law enforcement, and about a quarter approved overall. If a request reaches us through RDRS, the same rule applies.

Who can obtain what: requester → without Panamanian process → with it

RequesterWithout Panamanian processWith Panamanian process
Brand, company or individual with a complaintNothing; the complaint is forwarded to the holderWhat a Panamanian court order names
Foreign lawyer or foreign civil courtNothing; a reply explaining exequaturAfter exequatur by the Sala Cuarta: what the judgment names
Foreign police or prosecutorNothing; a reply explaining the treaty routeThrough the MLAT, Budapest or letters rogatory, then a Panamanian order
Panamanian Ministerio PúblicoIts order is Panamanian processPreservation (art. 338-A) or production (art. 338-C) of what we hold
Panamanian courtIts order is Panamanian processWhat the order names, after verification
UDRP or URS providerRegistrant details of record for the disputed domainNot needed
A court in our registrar partner's countryNot through us: it can order the partner under its own lawNot needed
Anyone asking for bulk dataRefusedRefused (Law 81 of 2019, art. 24)

"What we hold" is listed above: one verified email per domain, account number, domains, balance, payment records. Nothing more can be released.

What does RAA §3.7.7.3 mean for Domain protection?

It means our company carries a liability that you would otherwise carry, and we say so plainly. With Domain protection, DomaineGoat LLC is the registrant of record and you are the beneficial owner.

ICANN's 2013 Registrar Accreditation Agreement, §3.7.7.3, deals with this case. A registrant of record that licenses a name to someone else accepts liability for harm caused by its wrongful use. The exception: it discloses the licensee's contact details and identity within 7 days to a party that gives reasonable evidence of actionable harm.

Three honest points follow.

  • The clause sets who is liable; it does not order disclosure. Our rule stays the same: a Panamanian court or prosecutor's order, or a UDRP case. When we do not disclose, our company is the one exposed to the claim.
  • The clause is not a shield for you. A Panamanian court can still order disclosure, and the strict exceptions still apply to protected domains.
  • The contact we would disclose is one verified email. It is the only contact data we hold for you.

For domains without Domain protection, you are the registrant of record, and the clause concerns you, not us. ICANN's specification on privacy and proxy registrations asks providers to publish when they reveal a customer. This page is that publication.

Why does PanamaRegistrar refuse bulk data requests?

Because Panamanian law forbids them: article 24 of Law 81 of 2019 says bulk requests are never admitted ("no admitiéndose en ningún caso solicitudes masivas"). The same article obliges us to answer requests from competent judicial authorities that are duly made.

A bulk request asks for data not tied to named domains: every customer paying in a given coin, every domain with a keyword, every account created in a month. Each request must name the domains concerned. A Panamanian order covering many named domains is still possible; a fishing expedition is not.

Do you tell the customer when their data is disclosed?

Yes: we tell you before any action on your domain, unless the law or the court order forbids it. The notice names the requester, the legal basis, the data released and the date.

Three cases delay or prevent notice:

  • a court order that forbids it, for the period it sets;
  • a Ministerio Público preservation order under CPP article 338-A, which the custodian must keep confidential;
  • a UDRP case, where the rules bar notifying the respondent before the lock is applied; we tell you once it is.

The transparency report, published every quarter, counts data requests by origin country and outcome. The first one covers launch to 31 December 2026. No figure exists yet.

What do the registry and our registrar partner disclose?

They answer to the law of their own countries, not to our policy.

  • Our registrar partner. Domains are registered through our ICANN-accredited registrar partner, shown in the RDAP record. It keeps the registration record, its own legal duties and its own abuse contact, and a court of its own country can order it directly.
  • The registry. Each registry keeps its own copy of the registration. A thick registry, such as .org (Public Interest Registry, United States) or .io (Identity Digital), receives the registrant record: built from your verified email, or our company's details with Domain protection. The .com and .net registries (Verisign, United States) are thin: they receive no registrant contact data. DENIC, which runs .de, is in Germany.

The registry jurisdiction index lists the country of each of our 43 extensions. Their prices, with or without Domain protection, are on the price list.

Questions about data disclosure

Will you give my email to a company that says I infringe its rights?

No, not on its request alone. Without a Panamanian court order, a complainant gets nothing; we forward its complaint to you instead. For a trademark dispute, it can file a UDRP or URS complaint, and the provider then receives the registrant details of record, as ICANN requires.

Can a foreign police force get my data?

Only through Panama. A foreign authority uses the US–Panama MLAT, the Budapest Convention or letters rogatory. A Panamanian authority then issues the order that reaches us. Under Law 81 of 2019, article 33 (No. 8), a transfer in international judicial cooperation is lawful.

Is the Ministerio Público order an exception to the court-order rule?

It is part of the rule: We release the data we hold only when Panamanian law requires it (a Panamanian court or prosecutor's order), or in a UDRP case. Since Law 478 of 2025, that means orders under CPP articles 338-A and 338-C. We verify them like court orders and count them in a separate line.

What happens to an urgent request?

An urgent request (an imminent threat to life, serious bodily injury, child abuse material) goes to [email protected] with the subject "URGENT" and is handled first. The data we hold still leaves us only on a Panamanian court or prosecutor's order: in Panama, the Ministerio Público can order preservation or production directly (CPP arts. 338-A, 338-C).

Does Domain protection mean you never disclose?

No. With Domain protection the registry and WHOIS show our company, never you, and the only contact data we hold is your verified email. The disclosure rule stays the same: We release the data we hold only when Panamanian law requires it (a Panamanian court or prosecutor's order), or in a UDRP case. Under RAA §3.7.7.3, our company carries the liability when it does not disclose.

Do you sell or share data with advertisers?

No. We do not sell, rent or share customer data for advertising, and the site carries no advertising trackers. Data leaves us only on the routes listed on this page; our registrar partner and the registry hold what their own rules require. The privacy policy sets this out in full.

Can I see what you would disclose about me?

Yes. Article 42 of the Constitution of Panama and Law 81 of 2019 give you a right of access. Write to [email protected] from the domain's verified email. You will see the same records an order would reach: email, account number, domains, balance and payment records.

Sources (7)
  1. Ley 81 de 26 de marzo de 2019, protección de datos personales (arts. 11, 24, 33) — Gaceta Oficial No. 28743-A (Legispan copy, Superintendencia de Bancos) (29 March 2019, checked 2026-10-19)
  2. Ley 478 de 4 de agosto de 2025 (Código Procesal Penal arts. 338-A, 338-C) — Gaceta Oficial No. 30337 (5 August 2025, checked 2026-10-19)
  3. Constitución Política de la República de Panamá, Texto Único (art. 42) — Gaceta Oficial No. 25176 (November 2004, checked 2026-10-19)
  4. Registration Data Policy (§4, §10.5, §10.7.2, Implementation Note 11.1) — ICANN (effective 21 August 2025, updated 12 May 2026, checked 2026-10-19)
  5. 2013 Registrar Accreditation Agreement (§3.7.7.3; Specification on Privacy and Proxy Registrations) — ICANN (checked 2026-10-19)
  6. ICANN's RDRS two-year pilot: what we learned and where we go next — ICANN (3 March 2026, checked 2026-10-19)
  7. Rules for Uniform Domain Name Dispute Resolution Policy (para. 4) — ICANN (effective 31 July 2015, checked 2026-10-19)

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