How This Briefing Works
This report opens with key findings, then maps the gaps between what CHEQ 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
Compliance Fraud
88.3% pre-consent tracking rate, consent rejection ignored, 29 cookies set before consent interaction
Subprocessor Fraud
24+ vendors detected on cheq.ai including Clearbit, ZoomInfo, Hotjar, Meta, Google, LinkedIn, Bing, ChiliPiper, etc.
Consent Theater
All tracking cookies persist after Reject All. Clearbit shows isReadied: true post-rejection. DataLayer shows denied but scripts continue.
Pre-Consent Activity
CHEQ was observed loading and executing before user consent was obtained on 88% of sites where it was detected.
Undisclosed Surveillance
Clearbit actively de-anonymizes business visitors. ZoomInfo provides person-level identification. Hotjar records sessions.
Claims vs. Observed Behavior
Compliance Fraud
“SOC2 Type II, ISO 27001, GDPR, CCPA compliant”
88.3% pre-consent tracking rate, consent rejection ignored, 29 cookies set before consent interaction
Runtime detection data shows 103 CHEQ detections with 88.3% pre-consent rate. Forensic analysis documents 29 cookies set while consent banner visible, all persist after Reject All.
Subprocessor Fraud
“Subprocessor list: AWS, Microsoft Azure, Zendesk (3 vendors)”
24+ vendors detected on cheq.ai including Clearbit, ZoomInfo, Hotjar, Meta, Google, LinkedIn, Bing, ChiliPiper, etc.
Runtime scan vs subprocessor list comparison. Cookie policy partially discloses some vendors but subprocessor list (GDPR Article 28 required) lists only 3.
Consent Theater
“Honors user consent choices via Ensighten”
All tracking cookies persist after Reject All. Clearbit shows isReadied: true post-rejection. DataLayer shows denied but scripts continue.
CHEQ-LIVE-FORENSICS-2026-01-04.md documents exact cookie values before and after consent rejection - identical.
Undisclosed Surveillance
“Not disclosed: B2B de-anonymization, identity resolution”
Clearbit actively de-anonymizes business visitors. ZoomInfo provides person-level identification. Hotjar records sessions.
Clearbit object in DOM shows persist:true, maxage:31536000000 (1 year). ZoomInfo detected in runtime scans.
Privacy Marketing Fraud
“Privacy is a top concern for us and is baked into everything we do”
18 vendors fire pre-consent on own website. CNAME cloaking via takingbackjuly.com obfuscates tracking.
Trust Center quote vs runtime detection data. takingbackjuly.com DNS analysis shows CNAME to CHEQ infrastructure.
What This Means For You
What To Do About It
Role-specific actions based on observed behavior
If You Use CHEQ
- →AUDIT IMMEDIATELY: Run a runtime scan on your properties to verify what CHEQ's JavaScript actually loads and whether it respects consent rejection
- →DEMAND DISCLOSURE: Request complete list of all subprocessors and CHEQ subsidiaries (Deduce, ClickCease, Ensighten) — not the 3-vendor facade
- →TEST CONSENT: Verify consent rejection actually stops CHEQ tracking on your site — it does not on theirs (29 cookies persist after Reject All)
- →REVIEW CONTRACTS: Check if CHEQ's DPA terms hold them liable for their own non-compliance and consent bypass behavior
- →DOCUMENT EVERYTHING: Preserve evidence of claims versus behavior gap before they remediate — this protects your organization
If You're Evaluating CHEQ
- →REQUEST SOC2 REPORT: Verify if pre-consent tracking and consent rejection bypass are addressed in the audit scope
- →TEST THEIR SITE: Visit cheq.ai and reject consent — observe cookie persistence yourself to understand their compliance posture
- →ASSESS THE IRONY: A GTM Security vendor operating undisclosed surveillance creates unique liability when cited in your vendor assessments
- →CONSIDER ALTERNATIVES: Evaluate bot detection vendors that do not operate identity resolution subsidiaries (Deduce) or consent management tools (Ensighten)
- →COMPARE COMPETITORS: PerimeterX, DataDome, and Akamai offer bot detection without the surveillance conglomerate structure
Negotiation Leverage
- →Consent architecture audit: CHEQ's own site ignores consent rejection — 29 cookies persist after Reject All. Require independent verification that CHEQ's JavaScript on your property respects your CMP signals, with documented test results before deployment.
- →Surveillance scope limitation: CHEQ owns Deduce (identity resolution), ClickCease, and Ensighten (consent management). Require contractual guarantee that data from your property does not flow to any CHEQ subsidiary or affiliate for cross-site intelligence.
- →Subprocessor disclosure: CHEQ discloses 3 subprocessors while operating extensive undisclosed tracking. Require complete enumeration of all CHEQ entities and third-party vendors that receive data from their JavaScript deployed on your property.
- →Compliance theater remediation: SOC2, ISO 27001, and GDPR badges alongside 88.3% pre-consent rate and consent bypass constitutes misrepresentation. Require SOC2 report access and verification that audit scope covers pre-consent behavior and consent rejection handling.
- →Evidence preservation: Document CHEQ's claims versus behavior gap before any remediation — this evidence protects your organization if regulatory action targets CHEQ's customer base.
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
Full session replay
Identity stitching
Ignoring CMP signals
Device identification
Long-lived identifiers
PII deanonymization
Container/loader (neutral)
IOC Manifest
Indicators of compromise across 7 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
230 detection signatures across scripts, domains, cookies, and network endpoints