How This Briefing Works
This report opens with key findings, then maps the gaps between what Clevr 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
Clevr was observed loading and executing before user consent was obtained on 15% of sites where it was detected.
Claims vs. Observed Behavior
consent
“Pending claims extraction via CDT”
Session recording, tag manager, behavioral tracking, and consent bypass detected
disclosure
“Pending privacy policy review”
Session recording for personalization observed—requires explicit disclosure verification
What This Means For You
What To Do About It
Role-specific actions based on observed behavior
If You Use Clevr
- →IMMEDIATE: Audit Clevr deployments to verify session recording is disabled or explicitly disclosed in privacy policy
- →Implement strict consent-gating for ALL Clevr behavioral tracking and personalization
- →Disable session recording features in Clevr settings—use aggregated analytics only
- →Configure tag manager allowlisting to prevent unauthorized script injection
- →Enable data minimization controls to limit behavioral data retention to active personalization campaigns only (30 days)
- →Conduct monthly audits of session recording and tag manager behavior
- →Consider server-side personalization alternatives that do not require client-side behavioral tracking
If You're Evaluating Clevr
- →Request DPA with explicit prohibitions on session recording and cross-customer behavioral benchmarking
- →Require technical documentation on session recording scope and data retention procedures
- →Verify Clevr honors consent signals before initiating behavioral profiling
- →Demand contractual indemnification for GDPR fines and wiretapping liability arising from session recording
- →Assess alternative personalization platforms without session recording capabilities
- →Negotiate right to audit Clevr consent processing and session recording retention compliance
Negotiation Leverage
- →Clevr session recording (BTI-C07) for personalization creates wiretapping liability—require immediate technical verification that recording is disabled or demand contractual indemnification
- →Tag manager (BTI-C15) enables undisclosed script injection—require contractual restrictions on dynamic tag loading
- →Consent bypass (BTI-C09) with behavioral profiling creates regulatory exposure—require technical implementation of consent verification before tracking
- →Behavioral biometrics (BTI-C06) enables fingerprinting—negotiate contractual prohibition on persistent profiling or explicit user disclosure requirement
- →Request documentation on data retention periods and whether personalization behavioral data is used for Clevr's own optimization benchmarks
- →Negotiate maximum 30-day retention for session recordings with automated deletion and cryptographic verification
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 mouse movements, scroll patterns, interaction timing, and content engagement to build profiles for dynamic personalization targeting.
Full session replay
Impact: Records user sessions to analyze content preferences and navigation patterns for personalization optimization—potentially capturing sensitive interactions without consent.
Ignoring CMP signals
Impact: Initializes personalization tracking infrastructure before consent collection, creating automatic legal violations for behavioral profiling.
Container/loader (neutral)
Impact: Deploys tag management infrastructure that can dynamically inject personalization scripts and analytics trackers beyond declared functionality.
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
235 detection signatures across scripts, domains, cookies, and network endpoints