How This Briefing Works
This report opens with key findings, then maps the gaps between what Adelement discloses and what BLACKOUT observed at runtime. From there: what it means for your organization, what to do about it, and the detection data and evidence underneath.
Key Findings
Pre-Consent Activity
Adelement was observed loading and executing before user consent was obtained on 4% of sites where it was detected.
Claims vs. Observed Behavior
pending
“Requires claims extraction via CDT”
Live website analysis pending
What This Means For You
What To Do About It
Role-specific actions based on observed behavior
If You Use Adelement
- →Require Adelement to execute post-consent only
- →Implement 14-day data retention for ad engagement metrics
- →Add behavioral tracking disclosure to privacy policy
If You're Evaluating Adelement
- →Review DPA for ad engagement data controller/processor responsibilities
- →Assess first-party ad tracking vs. third-party optimization platforms
Negotiation Leverage
- →Behavioral tracking without consent violates GDPR Article 6 - require post-consent execution or contract termination
- →Limited data collection reduces risk vs. session recording vendors, but ePrivacy Directive violations remain - demand technical consent controls
- →Ad engagement data has competitive value - require disclosure of any data sharing beyond core optimization function
Runtime Detections
BLACKOUT observed this vendor's JavaScript executing in a live browser and classified each hostile behavior using our BTI-C (Behavioral Threat Intelligence — Capability) taxonomy. These are not theoretical risks — each code below was triggered by something we watched this vendor's code actually do.
Keystroke/mouse tracking
Impact: Captures ad interaction micro-behaviors (hover patterns, engagement timing) for optimization. Creates GDPR personal data processing obligations without documented legal basis.
Ignoring CMP signals
Impact: Executes behavioral tracking before consent collection. Documented in pre-consent timeline analysis. Violates ePrivacy Directive tracking consent requirements.
IOC Manifest
Indicators of compromise across 3 categories. Use for detection rules, CSP policies, or Pi-hole blocklists.
Ecosystem & Supply Chain
Evidence Artifacts
Artifacts collected during analysis, available with evidence-tier access.
Complete network capture with all requests and responses
59 detection signatures across scripts, domains, cookies, and network endpoints