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Zone File Access Policy


As the competent authority for the operation and maintenance of the registration of Portugal’s top level domain, complying, to this end, the law and the principles of transparency and publicity, it is up to DNS.PT Association, hereinafter referred to as .PT, to ensure the correct technical and legal management of the system of domain names under .pt and, to this extent, adopt the policies it deems necessary and adjusted to the achievement of this purpose.

It is in this context that we make this Policy known, whose purpose is to define a clear, informed and diligent position on how the possible .PT zone file accessing should be handled, ensuring, in parallel, that all potential stakeholders know .PT’s position and guiding principles on this issue, as well as the admissible exceptions.

Zone File

Each delegated Top Level Domain (TLD) corresponds to the management of a Domain Names Systems (DNS) zone; the details of those zones are stored in files commonly known as "zone file”.

The zone file is generated periodically and contains all the delegated .pt domain names and the corresponding technical information, introducing these delegations to the global domain name system. Strictly speaking, the zone file is the key aspect of the DNS system and the product of .PT’s work.

Fig. 1. Extract from the .PT zone file

Specificity of the zone file

.PT considers that the zone file deserves special treatment given that, although the data contained therein are not qualified as ‘personal’ in the sense of Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), as explained in the Technical Opinion - GDPR and .PT zone, which is an integral part of this policy, the zone file aggregates essential and vital data to .PT’s activity, dealing with core information on the technical management of Portugal's top level domain.

Said classification is reinforced by the fact that the information contained therein is particularly sensitive and valuable, commonly used in an abusive way, namely to send spam or non-consenting marketing emails, when its sharing or dissemination does not occur in a controlled environment, resorting to the signing of specific protocols and confidentiality agreements detailing the exact terms and conditions, technical and legal, in which said sharing should take place.

Accessing the zone file

.PT may give access to its zone file, in whole or in part, on an exclusive and not onerous basis, for non-commercial purposes, to persons or entities that show and prove the existence of a legitimate interest to access this information, designated but not exclusively, with public entities, security agencies, scientific or statistical research centres and researchers.

.PT can be contacted for matters related to the sharing of the zone file by email at request@pt.pt.

Notwithstanding the possibility of accessing the zone file, this file is .PT’s intellectual property and, to that extent, is protected in accordance with the applicable law.

Publication: 12 April 2022