Domain Registration Data Disclosure Policy + Guide

Jiinubi is committed to our customer’s privacy, including domain registration data. We also understand that there may be legitimate reasons for requesting domain registration data. To navigate these requests, we comply with laws governing what must, can and/or cannot be shared and the compliance requirements surrounding each request and resulting decision.

We have put together this policy as a guide for you if you are seeking domain registration data, formerly known as Whois data. This guide incorporates the various legal requirements that apply to Jiinubi.

Established Legal Mechanisms

US Court Order or Subpoena

Jiinubi will comply with all disclosure requests issued via a US court order or subpoena. If you have a US court order or subpoena, you may submit it directly to legal@Jiinubi.com. Also see: https://www.Jiinubi.com/court-order-and-subpoena-policy/.

Please note: Domain registration data is not required in order to file a lawsuit against a domain registrant. You may file a lawsuit using the domain name and then, once filed, submit a subpoena in relation to the case which requests domain registrant data. You do not need to name Jiinubi as a defendant in the lawsuit.

Uniform Dispute Resolution Policy (UDRP)

Jiinubi complies with the UDRP. Disclosure of domain registration data is part of the UDRP process. This information is not needed in order to file a UDRP complaint. Therefore, Jiinubi provides this information once a UDRP has been filed and a disclosure request is made by the assigned mediator. Disclosure is made directly to the mediator. Also see: https://www.Jiinubi.com/legal/domains/udrp/.

Non-US Court Order

Jiinubi reviews non-US court orders on a case by case basis to determine our obligations for disclosure and/or prohibitions against disclosure. If you are seeking domain registration data pursuant to a non-US court order, please submit your request along with the certified copy of the court order to legal@Jiinubi.com.

Please note that Jiinubi is wholly US based. All court orders must be in English or have an accompanying certified translation of the order into English. If Jiinubi is not subject to the jurisdiction of the issuing court, Jiinubi will apply a disclosure Balancing Test.

Law Enforcement

Jiinubi will disclose domain registration data to law enforcement pursuant to a US issued subpoena or other established law enforcement mechanisms. Requests that include a US issued​ subpoena or other established US law enforcement mechanism may be submitted directly to legal@Jiinubi.com.

For law enforcement based outside of the US, Jiinubi reviews requests on a case-by-case basis and will apply a Balancing Test. All other requests should be submitted to abuse@Jiinubi.com.

Digital Services Act (DSA)

Jiinubi will provide domain registration data under a valid DSA Request for Information. European governmental agencies who wish to issue a DSA Request for Information may submit the request to our dedicated DSA channel or our DSA Agent:

• Email at dsa@edsr.eu
• Writing to EDSR at Avenue Huart Hamoir 71, 1030 Brussels, Belgium
• Phone at +32 2 216 19 71

Also see: https://www.Jiinubi.com/support/knowledgebase/article.aspx/10713/5/dsa-notice-action-mechanism-submission-guidelines/.

All Other Requests

Balancing Test

For all other requests, Jiinubi will apply a legitimate interest balancing test where we apply the standards set by the General Data Protection Regulation (GDPR) (“Balancing Test”.) The Balancing Test weighs the requestor’s legitimate interest in obtaining (i.e. processing) personal data against the potential impact on the registrant’s (i.e. data subject’s) rights and freedoms. The test is applied on a case by case basis. Factors that Jiinubi considers include whether: the information is necessary to the legitimate interest being pursued by the requestor, there are less intrusive ways to achieve the same purpose, the information can be more appropriately provided under an existing legal mechanism, the requestor can be validated/verified by Jiinubi, the requestor is located in a country not deemed “adequate” under the GDPR, and whether the request included sufficient, specific details for the reason for the request.

Please note that these factors are not exhaustive. Also note that, while each factor will be weighed collectively, failure to include sufficiently detailed and supported reasons for the request will result in a denial of the request.

When submitting a disclosure request under the Balancing Test, you must include:

1. Domain: Identification of the domain, which must be registered with Jiinubi and actively in use.  
2. Data Elements Requested: Please list the specific domain registration data elements requested.
3. Requestor: Identity of the Requestor. Identity must include the name of the individual and the name of the entity/agency that the person is a part of and also the name of any third party that they represent.  
4. Type of Entity or Individual: Clarification of whether the Requestor is an individual or a business entity, including relevant details.
5. Authorization to Act: If you are asking on behalf of another party, you must provide the full name of the party, their relationship to the request and, if applicable, Power of Attorney or similar documents showing that the Requestor is authorized to act on behalf of another party
6. Contact Information: Full details of how the Requestor can be contacted (name, email). This must be an individual name and not a generic reference.
7. Detailed Explanation of the Legitimate Interest: A detailed explanation of the legitimate interest held by the Requestor seeking the domain registration information. This should include sufficient detail and, as needed, documentation supporting rights and/or allegations being made. Please also address why none of the established legal mechanisms can be used.
8. Request is in Good Faith: By submitting this request, you attest that your request is in good faith and meets all of the requirements and authorizations outlined in this submission.
9. Country Location: Your location and any/all locations where the information may be shared once provided.  
10. Further Disclosure: Provide details and explanation for any/all further disclosures that you will make and/or anticipate making.
11. Statement Under Perjury: A statement by the Requestor that, under penalty of perjury, the information in the notification is accurate, that you have the primary authorization to make a request for the information on behalf of the named party (if applicable) and as to this circumstance and related set of facts.
12. Agreement to Lawful Processing: Agreement by the Requestor that they will comply with any additional measures required by applicable law, as determined by Jiinubi, specifically including the lawful processing of such data under the GDPR and the Standard Contractual Clauses as approved by the European Union: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32021D0914.
13. Submit to: The Disclosure request should be submitted to disclosurerequests@Jiinubi.com.

NOTE: If your disclosure request involves an urgent situation where there is an imminent threat to life, serious bodily injury, critical infrastructure, or child exploitation – you MUST indicate this in the subject line. In your submission, you must provide the full details of the situation, share why disclosure of data is deemed necessary to combat or address the threat and include the name and contact information of the law enforcement agency/agent you are working with.

A confirmation reply will be provided promptly upon receipt of your request, and the outcome will be delivered via email within thirty (30) calendar days.

For all submissions, Jiinubi will determine, in its sole discretion, whether disclosure can be made.

Jiinubi also reserves the right to ban further requests from Requestors who are abusive, repeatedly misrepresent themselves and/or the facts and/or any other activity by a Requestor that Jiinubi believes creates a significant risk to the data subject’s rights and freedoms.