How This Briefing Works
This report opens with key findings, then maps the gaps between what Bannerflow 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
Bannerflow was observed loading and executing before user consent was obtained on 17% of sites where it was detected.
Consent Compliance
17.9% of detections show pre-consent tracking
Undisclosed Party
Not in privacy policy
Undisclosed Sharing
Hidden data recipients
Compliance Claim Mismatch
False certification claims
Claims vs. Observed Behavior
Consent Compliance
“GDPR compliant, IAB TCF participant (ID 273)”
17.9% of detections show pre-consent tracking
Runtime scans show Emerse, Gravite, and HubSpot loading before consent obtained
Disclosure Gap
“Privacy policy discloses data processors”
Emerse and Gravite not mentioned despite active tracking
Runtime detection of Emerse and Gravite on bannerflow.com not disclosed in privacy policy
What This Means For You
What To Do About It
Role-specific actions based on observed behavior
If You Use Bannerflow
- →Audit your CMP configuration to ensure Bannerflow scripts only fire after valid consent
- →Request updated subprocessor list directly from Bannerflow and compare against runtime detections
- →Verify your DPA covers Emerse and Gravite as potential subprocessors
- →Review data flows across the 100+ publishing networks for undisclosed vendor exposure
If You're Evaluating Bannerflow
- →Request complete vendor and subprocessor list before any engagement
- →Verify IAB TCF compliance against 17.9% pre-consent detection rate
- →Compare with other creative management platforms on vendor transparency
- →Require contractual guarantees on consent enforcement across all publishing destinations
Negotiation Leverage
- →IAB TCF vs pre-consent: TCF participant (ID 273) yet 17.9% of detections show pre-consent tracking — use this contradiction to negotiate enhanced consent enforcement guarantees
- →Undisclosed vendors: Emerse and Gravite fire pre-consent on bannerflow.com — require named vendor disclosure and DPA coverage for all detected vendors
- →100+ network exposure: Publishing ads across 100+ networks multiplies undisclosed vendor risk — negotiate vendor disclosure requirements for each publishing destination
- →Creative data sensitivity: Display ad creatives and performance data reveal campaign strategy — negotiate restrictions on campaign intelligence sharing across the network
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.
Evasion infrastructure, auditor bypass
Keystroke/mouse tracking
Identity stitching
Ignoring CMP signals
Device identification
IOC Manifest
Indicators of compromise across 4 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
163 detection signatures across scripts, domains, cookies, and network endpoints