How This Briefing Works
This report opens with key findings, then maps the gaps between what Adyntel 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
Adyntel was observed loading and executing before user consent was obtained on 100% 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 Adyntel
- →Require Adyntel to execute post-consent only
- →Document third-party data sources for GDPR Article 14 disclosure requirements
- →Add data enrichment disclosure to privacy policy with field-level detail
- →Implement 30-day retention for behavioral tracking data
If You're Evaluating Adyntel
- →Review DPA for enrichment data controller/processor responsibilities
- →Audit third-party data sources for GDPR compliance
- →Assess first-party enrichment vs. third-party append risk
Negotiation Leverage
- →Behavioral tracking without consent violates GDPR Article 6 - require post-consent execution
- →Data enrichment expands GDPR liability scope - demand documentation of all third-party data sources
- →Enriched profiles sold to third parties create competitive intelligence risk - require complete buyer list with pricing transparency
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 site engagement behaviors for profile enrichment. Creates GDPR personal data processing obligations without documented legal basis when combined with demographic appends.
Ignoring CMP signals
Impact: Executes behavioral tracking before consent collection. 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
22 detection signatures across scripts, domains, cookies, and network endpoints